Unraveling federal award terminations: evidence from the Louis Stokes Alliances for Minority Participation

The National Science Foundation (NSF) ended funding for more than 1,600 projects as of 8 July 2025. Approximately 5% of the terminated NSF grants were of Louis Stokes Alliances for Minority Participation. NSF LSAMP can be used to understand the federal decision-making in determining which grants to terminate or maintain. We assessed eight metrics: (1) total cost of an award, (2) the amount already spent on an award, (3) proportion remaining on an award, (4) number of months remaining in an award, (5) the type of award, (6) location of award, (7) inclusion in the Ted Cruz-led senate investigation, and (8) verbiage in the abstract. We found no correlations between the data and project terminations. We find that the terminations of LSAMP grants were not evidence based and therefore should be overturned per existing precedent and in accordance with the Administrative Procedure Act (1946). We recommend that higher education institutions use the presented data as evidence for litigation and LSAMP award reinstatement.

Introduction

The Trump administration issued a significant change in governmental priorities in January 2025 with Executive Order (EO) 14,151 titled “Ending Radical and Wasteful Government DEI Programs and Preferencing” (EO 14,151: Ending DEI Spending) (The White House, 2025a). In the statement, diversity, equity, and inclusion (DEI) in federal employment, equity initiatives and programs, and equity-centered grants were notified to end as soon as possible (The White House, 2025a). As of 21 May 2025, the Trump administration had eliminated more than 58,000 jobs across dozens of federal agencies and terminated thousands of federal grants, citing a need for government efficiency and changes in executive priorities (Gewin, 2025).

The actions of the Trump administration have had a profound impact on universities and research institutions, triggering federal funding freezes, mass layoffs, and reduced research capacity (Gewin, 2025; Moody, 2025). The National Science Foundation (NSF) alone ended funding for more than 1,600 projects as of 8 July 2025 (Grant Watch, 2025). The NSF award terminations often cited “[broadening participation] efforts should not preference some groups at the expense of others, or directly/indirectly exclude individuals or groups. Research projects with more narrow impact limited to subgroups of people based on protected class or characteristics do not effectuate NSF priorities” (National Science Foundation, 2025b). This change in priorities deviated from more than 40 years of broadening participation efforts for women and people of color, as designated by the National Science Foundation Authorization and Science and Technology Equal Opportunities Act (Kennedy, 1980).

The NSF change in priorities disproportionately limited women and people of color. Of the terminated grants, 58% were led by women principal investigators (PI) and 17% by Black PIs (Mervis, 2025). This is despite women and people of color serving as PI on disproportionately small percentages of NSF awards (34 and 4%, respectively). Trainees were also negatively impacted as many terminated awards, such as the Louis Stokes for Minority Participation, supported STEM training for students of color.

The Alliance for Minority Participation, later named after the late Congressman Louis Stokes, was mandated by the Congress in 1991 with a mission to “diversify the nation’s science, technology, engineering, and mathematics (STEM) workforce by increasing the number of STEM baccalaureate and graduate degrees awarded to persons from LSAMP populations. LSAMP populations are defined as persons from groups underrepresented in the STEM enterprise: Blacks and African Americans, Hispanic and Latino Americans, American Indians, Alaska Natives, Native Hawaiians, and Pacific Islanders” (National Science Foundation, 2024a).

The NSF LSAMP program promoted domestic STEM workforce development for more than 30 years. The program increased transfer rates, provided summer experiences for high school and college students, supported the development of STEM identity, provided funded research opportunities, and promoted psychological support and technical readiness (Gates et al., 2022; San Miguel and Gates, 2021). Recent data showed that at least 6% of earned doctorates by people of color (POC) between 1992 and 2022 were awarded to LSAMP alumni; 10% of mathematics and 12% of computer science earned doctorates by POC were earned by LSAMP alumni (Smart Graham et al., 2025). Despite these accomplishments, 75% of LSAMP awards were terminated on 2 May 2025, citing that “they no longer effectuate the program goals or agency priorities” (National Science Foundation, 2025d; Grant Watch, 2025).¹

In contrast, Executive Order 1,4278: Preparing Americans for High-Paying Skilled Trade Jobs of the Future (EO 1,4278: Preparing Americans), released on 23 April 2025, advocated for domestic workforce development in skilled trade (The White House, 2025b). As described, LSAMP was effectuating the goals outlined in EO 1,4278: Preparing Americans. Specifically, LSAMP was (a) integrating resources across higher education, national laboratories, and industry to prepare STEM students for the workforce (Louis Stokes Midwest Regional Center of Excellence, 2023); (b) was increasing retention and graduate degree earnings for STEM scholars (Gates et al., 2022; Smart Graham et al., 2025; San Miguel and Gates, 2021); and (c) generated data on skilled workforce development and best practices for student training (LSAMP National Coordination Hub, 2025). There is clear alignment with the Trump administration’s workforce development goals as defined in EO 1,4278: Preparing Americans (The White House, 2025b). There are incongruencies, however, between the demonstrated efficacy of LSAMP, self-imposed limitations on STEM workforce development through EO 1,4151: Ending DEI Spending, and the administration’s aims to expand workforce development with EO 1,4278: Preparing Americans. These incongruencies demonstrate a short-term strategy for strengthening America’s workforce that treads against the touted goals of the Trump administration. The terminations may have also violated statutes as defined by the Administrative Procedure Act.

The Administrative Procedure Act of 1946 (APA) was established to increase transparency of decisions made by federal agencies to the American people. Transparency occurs via publication of rules, opinions and orders, and public records (United States 79th Congress, 1946). Executive Orders can be unlawful if they do not follow this due course or are “(1) arbitrary or capricious, an abuse of discretion, or otherwise not in accordance with the law, (2) contrary to constitutional right, power, privilege, or immunity… (5) unsupported by substantial evidence”. Substantial evidence requires “the proponent of the rule of order shall have the burden of proof”. Here, we demonstrate that termination of the LSAMP program violated requirements of Judicial Review (i.e., arbitrary and capricious acts) and the required burden of proof. The authors use “arbitrary and capricious” in accordance with the terminologies used in the APA and analyze data sources to demonstrate the required burden of proof. LSAMP represents ~5% of terminated NSF grants and can be used as a model to understand federal decision-making for grant termination. We demonstrate that terminations do not comply with U. S. Code Title 5.1. §706 (Cornell Legal Information Institute, 2025) and advocate for the reinstatement of this pivotal program in accordance with the APA.

Our results demonstrate that the Trump administration did not consider the total cost of an award, the amount already spent or proportion remaining, the number of months remaining in an award, the type of award, the location of the award, inclusion in the Ted Cruz-led Senate investigation, or verbiage in the abstract to determine whether to terminate an award. Our analysis reveals an absence of consistent factors guiding award termination.

Review of publicly available data

Definitions and acronyms for each alliance type and detailed descriptions of the methods are available in the Supplementary materials.

What factors may have contributed to the selection of which LSAMP alliances/awards were terminated?

We evaluated eight factors to identify trends for which LSAMP awards were terminated. There was no observable or statistical trend (analysis type described below) for any of the following:

1. Allocated amount of the award

2. Amount of funding remaining in the allocation

3. Proportion of the award already spent

4. Months remaining to the expected closeout of the award

5. Type of award

6. Location of award (by state and state senators)

7. Inclusion in the Cruz-led investigation of DEI grants (U.S. Senate Committee on Commerce, Science, and Transportation, 2025)

8. Terminology used in the title or abstract of the award.

These eight metrics were selected because they capture both the main observable dimensions on which a rational termination policy could be expected to operate and could be assessed using publicly available data: financial exposure (total cost and funds spent/remaining), award timing, program type and location, and alignment with politically targeted themes. If decisions were non-arbitrary, we would expect systematic differences in at least one of these measures between terminated and continuing awards.

Allocated amount of award and remaining funds

Of the 82 LSAMP projects active prior to 2 May 2025,² 56 were terminated, 19 remained active, and 7 were already slated to end on that date (Grant Watch, 2025; National Science Foundation, 2025a). The 19 awards that remain active are in 13 U. S. states and average $2.07 m³ each as opposed to the terminated grant average of $2.42 m⁴ in 35 states.

Figure 1 shows the amount of allocated funds for each award as compared to the amount outlayed by termination status (USASpending.Gov, 2025). Outlayed expenditures have already been distributed to a university, whereas obligated expenditures are inclusive of monies that have not yet been disbursed. Of the awards with the largest obligated funds (~$4 m), approximately half were terminated. The total LSAMP budgets ranged from $187,874 to $4,076,341 (M ≈ $2,334,480, SD ≈ $1,130,559). Terminated awards had somewhat larger budgets on average (M ≈ $2,423,557, SD ≈ $1,028,421) than active awards (M ≈ $2,071,939, SD ≈ $1,387,634), but this difference was not statistically significant [Welch’s t(25.05) = 1.01, p = 0.32, 95% CI (−$362,439, $1,065,675)], indicating that larger awards were not systematically more likely to be terminated.

Figure 1

Figure 1. Appropriated expenditures in $USD for active and terminated awards.

The average amount spent on still active awards is 34.6% ($1.14 m⁵) and 44.3% ($968 k⁶) was spent on terminated awards. The amount remaining on active awards is higher on average than that of terminated awards. Based on these data, the selection process for LSAMP grant terminations was not based on individual award cost.

Remaining months of award

Expected end dates for still active grants range from 30 June 2025 to 30 September 2029, and 31 May 2025 to 30 November 2029, for terminated awards. Some former LSAMP leaders received the award termination notice less than 1 month before the expected end date of the funding (Personal Communication).

We calculated the time between the termination date and each project’s expected end date as an index of how much of the award period remained. On average, terminated awards had more time remaining (M = 22.50 months, SD = 17.79) than active awards (M = 14.79 months, SD = 18.12), a mean difference of 7.71 months. However, this difference did not reach conventional levels of statistical significance [t(73) = 1.63, p = 0.11, 95% CI (−1.75, 17.17)], and the effect size was modest (Cohen’s d = 0.43). Thus, we find no evidence that the time remaining on the award was a decisive factor in whether an award was terminated or remains active.

The average award period for terminated⁷ grants was ~8 months longer than for still active awards.⁸ The original lifespan of still active awards is on average lower than terminated awards; however, the range is wider. Still active awards⁹ would naturally conclude ~7 months sooner than terminated awards¹⁰ but neither the award period nor the conclusion date was statistically different [Welch’s t(24.59) = 1.43, p = 0.17, 95% CI (−3.40, 18.86)]. Thus, there is no evidence for the selection of award termination based on the award timeline.

Type of award

Termination may have partly been decided by the type of award, with an emphasis on continued support for students in graduate degree programs. Any potential trend may also be negated by later-terminated grants, but those data were not yet readily available at the time of writing. Still active grants after May 2 were SPIO, BD, or SPRA. Figure 2 shows the award type by active or terminated status. The fewest terminations were of BD alliances, with only one BD award terminated on May 2. In contrast, all CoE and B2B alliances were terminated. Some alliances, such as California State University and the State University of New York LSAMPs, had their SPRA awards terminated but not their BD, demonstrating inconsistencies even within which universities received termination letters. A chi-squared test suggested an association between award type and termination status, χ² (4, 75) = 21.30, p < 0.001, but 40% of cells had low expected counts, and later terminations are not captured. Any trend by award type is minimal and inconsistent, further demonstrating the arbitrary decision-making process.

Figure 2

Figure 2. Comparison of appropriation spent as of 3 June 2025 to award type and active or terminated status. Each award is represented by the proportion of obligated vs. originally allocated amount in U. S. dollars (USASpending.Gov, 2025). Obligated funds are those committed by the federal government (as of 3 June 2025), whereas allocated include funds that are intended for future years (FitzGerald et al., 2021).

Award geography

The NSF Established Program to Stimulate Competitive Research (EPSCoR) was developed in 1979 to distribute federal research and development funds more evenly. Like LSAMP, EPSCoR programs have a goal of “Broaden[ing] participation of diverse groups/institutions in STEM” (Committee on Equal Opportunities in Science and Engineering, 2022). If the federal administration was intentional when selecting which awards to terminate, we would expect some correlation to EPSCoR jurisdictions to limit the broadening participation efforts of both programs. Twenty LSAMP awards were in EPSCoR districts. Of the 20 awards, 13 were terminated. The NSF budget request to Congress proposed a > 41% reduction in EPSCoR funding between 2025 and 2026 (National Science Foundation, 2024b; National Science Foundation, 2025b). Despite the budget cuts and objectives of the program, LSAMP awards in EPSCoR jurisdictions were terminated at approximately the same rate as awards elsewhere, suggesting that EPSCoR status did not play a systematic role in termination decisions.

We also investigated the distribution of awards across the United States. Figure 3A shows the appropriated awards prior to 2 May 2025, and Figures 3B,C show obligated and outlayed, respectively, after May 2. The amounts in Figure 3B are inclusive of dollars spent prior to termination. Figure 3C represents the funds actually disbursed to the alliance as compared to the proposed or tentative funding. The color intensity variation in Figure 3 demonstrates how the terminations blocked congressionally and contractually obligated funds from reaching their intended sources.

Figure 3

Figure 3. Discrepancy between allocated, (A) obligated, (B) and outlayed (C) NSF funds for LSAMP programs prior to and after May 2nd terminations.

We found no visible associations when comparing the location of the award to the political environment. Figure 4 shows the senatorial composition of the United States as of April 2025 compared to the terminations of awards. Texas, for example, which has two republican senators, had three awards terminated and three remain active. There does not seem to be any bias by political affiliation for maintaining or terminating awards (Figure 4).

Figure 4

Figure 4. Map of United States delineated by senatorial composition as of 7 April 2025. Terminated and still active awards are marked by institutional zip code. Yellow/black circles are still active grants; green filled circles are terminated awards. Blue and red states represent Democrats and Republican senators, respectively. Hatched red and blue lines have mixed senators. Vermont has one independent and one Democratic senator and Maine is split between a Republican and independent senator. Created in ArgIS online using data from Esri, USGS, Province of Ontario, Esri, TomTom, Garmin, FAO, NOAA, USGS, EPA, USFWS, NRCan, Parks Canada, Esri, Office of the Clerk of the House of Representatives, and Grant Watch (2025).

Inclusion in Cruz investigation

The Cruz-led investigation into federal grants looked at themes of social justice, ethnicity, gender, and/or environmental justice (U.S. Senate Committee on Commerce, Science, and Transportation, 2025). Grants identified as having any of those focuses were categorized as “red status” and considered high risk for termination. We compared the termination status of LSAMP awards to their presence on the Cruz List and any listed themes. Of the LSAMP grants which were present on the list (n = 22), all were categorized under social justice with a subset also categorized under ethnicity (n = 8) and gender (n = 1). We found no correlation between termination status and inclusion on the Cruz List or listed emphasis.

Terminology in the abstract or title

An analysis of word frequencies in LSAMP project abstracts revealed important differences and overlaps between terminated and active projects. Among the most frequently occurring terms in both active and terminated projects were terms associated with research and the program title (e.g., STEM, LSAMP).¹¹ Abstracts from active¹² projects showed lower overall word frequencies but retained several overlapping keywords (Figure 5A). Term frequency was normalized by the number of terms in each group.

Figure 5

Figure 5. (A) Abstract word analysis: Frequency of words associated with active and terminated projects. (B) Words associations with terminated and active projects.

The presence of “diversity,” “equity,” and “inclusion” was examined across terminated and active projects to determine if this was a key factor in deciding whether to terminate an award. “Diversity” appeared 11 times in terminated projects and 8 times in active ones, while “inclusion” was mentioned 4 times in terminated and 3 times in active abstracts. In contrast, “equity” appeared seven times and only in the terminated projects. Inclusion of the word equity in the abstract may be the only consistent consideration in determining whether a grant was terminated but the subset sample size is too small to draw significant conclusion.

Comparisons of word use between active and terminated projects highlighted differences that are difficult to reconcile with the stated goals and termination rationale. Terminated projects were associated with terms such as “center,” “dissemination,” “regional,” “CSU¹³,” and “transfer.” These words reflect an emphasis on structural initiatives, regional collaborations, and transfer pathways, suggesting that projects focused on these areas were more vulnerable to termination.

Conversely, words more common in active projects included “doctorate,” “BD,” “doctoral,” “Ph. D.,” and “Indigenous.” These terms are associated with graduate-level education and national STEM priorities, indicating that projects emphasizing doctoral training and the inclusion of Indigenous groups were more likely to remain funded.

The prevalence of “Indigenous” in active awards may be a result of the unique structure of Native Education in the United States as a political designation as opposed to ethnicity (Morris and Curleyhair, 2025). The All Nations Alliance which hosts 35 Tribal-affiliated and Tribal-serving institutions remains active, and discussions are ongoing between the Trump administration and tribal leaders on how Native Education will change moving forward.

Recommendations

Based on our analysis, we recommend that institutions or alliances challenge the termination of LSAMP awards as arbitrary and capricious per the APA. We also recommend that the federal government follow the standard process of public notice, commentary period, and transparent rationale for all terminated awards and pending termination decisions. In California, an LSAMP award was reinstated because the APA was not appropriately followed for award termination demonstrating precedent that can be followed nationally (Mervis, 2025a).

Discussion

We analyzed eight metrics and found little consistency or substantial evidence as required by the APA. While there are some trends in the data, none of the differences between terminated and active projects are strong enough to point to a specific rationale for termination. One pattern finding is that the word “equity” appeared only in terminated project abstracts (n = 7), but this small subset is considered insufficient to establish a clear decision rule. Both active and terminated projects included references to “diversity” and “inclusion,” and there was no consistent alignment between terminations and inclusion on politically targeted “Cruz Lists.” Taken together with the absence of a clear, documented rationale, this pattern raises serious concerns about whether the termination decisions met the transparency expectations of the Administrative Procedure Act. Based on this, we urge that terminations are reconsidered or overturned (Cornell Legal Information Institute, 2025). The termination of a congressionally mandated program without any publicly articulated supporting evidence may set a dangerous precedent.

Strategic planning, clear action items for award close-out, and transparent rationale for terminations would allow institutions to make informed decisions in the future. This information could serve as a guide for the design of new proposals, the development of future programs, and improve resilience in times of political or financial uncertainty. LSAMP has had a positive impact on workforce development through graduate degree earnings, transfer success, and career readiness, which could be lost for current and future domestic STEM students because of the federal terminations (Gates et al., 2022). This will likely lead to a reduction in the U. S.-based STEM workforce in the near future.

The terminations directly oppose the aims of EO 1,4278: Preparing Americans by limiting access to research, STEM professional development, and graduate degree attainment. If the Trump administration aimed to restructure grant funding through terminations, they could have done so with strategic planning and evidence in accordance with the U. S. Code. In addition to the evidence of poorly planned grant terminations presented here, post-termination actions for LSAMP leadership were opaque. LSAMP leaders navigated a loss of funds and subsequently personnel while receiving conflicting information. For example, the Update on NSF Priorities stated that annual reports are not required for terminated programs; however, LSAMP leaders received multiple email notices about imminent due dates for annual reports (National Science Foundation, 2025c,d). This lack of direction put strain on staff who were no longer paid by the awards and further demonstrates a lack of planning and foresight in termination decisions.

Our analysis is limited to publicly available NSF award and expenditure data. We did not have access to internal review materials or decision-making documents and therefore cannot evaluate other criteria that may have been applied to specific awards. However, inaccessible rationale or access to decision-making rubrics are inherent transparency concerns, particularly for a congressionally mandated program such as LSAMP.

Expanding access to higher education to the most vulnerable groups in society is essential to building a truly equitable education system. Talent is equally distributed across the population, but opportunities are not (Meyer, 2021). If we want our country, state, or universities to reach the highest standards in research, innovation, and scientific development, we must ensure that all social groups, especially those that have been historically excluded, have the support and opportunities they need to thrive. In this context, the LSAMP project plays a critical role. We suggest that the National Science Foundation reinstate the awards because the cited rationale for termination is not supported by the publicly available award or expenditure data, demonstrating a lack of burden of proof.

Author contributions

SB-B: Data curation, Formal analysis, Investigation, Visualization, Writing – original draft, Writing – review & editing. AC-M: Conceptualization, Data curation, Supervision, Writing – original draft, Writing – review & editing.

Funding

The author(s) declared that financial support was not received for this work and/or its publication.

Conflict of interest

The author(s) declared that this work was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

Generative AI statement

The author(s) declared that Generative AI was not used in the creation of this manuscript.

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Supplementary material

The Supplementary material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/feduc.2026.1673464/full#supplementary-material

Footnotes

^Additional terminations occurred in late May 2025, particularly of Bridge to the Doctorate awards. However, the data for those terminations were not yet accessible at the time of writing.

^All data represent awards terminated on 2 May 2025. Later terminations are not included because the data were inaccessible at the time of writing.

^SD = $1.39 m; range: $700 k–$4.07 m.

^SD = $1.03 m; $187 k–$4 m.

^SD = $508 k; range: $336 k–2 m.

^SD = $645 k; range: $6,639–$2.86 m.

^X = 59.57 months; SD = 15.57; range: 9–83.

^X = 51.84 months; SD = 21.71; range: 23–83.

^X = 15.79 months; SD = 18.12; range: 1–52; from 2 May 2025 to expected end date.

^X = 22.5 months; SD = 17.79; range: 0–54; from 2 May 2025 to expected end date.

^“STEM” (578 occurrences), “students” (261), “LSAMP” (222), “alliance” (207), “research” (200), and “university” (199).

^“STEM” (177), “students” (94), “LSAMP” (74), and “research” (71).

^“CSU” may refer to multiple institutions, such as “California State University,” “Colorado State University,” “Chicago State University,” which could explain its frequent appearance in project abstracts.

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