As the article says, legal action up to this point has been based on the fact that the government created policies that didn't follow its own rules under, for example, the Administrative Procedures Act.

So now the administration is attempting to follow those rules to create these new procedures, which they believe will then be lawful.

If they are successful, challenges would have to be made judicially based on non-procedural grounds, or through Congress.

Yes, but even following APA, the order doesn't have the strength of statute.

They can follow APA to come up with all kinds of illegal rules. And the actual rules are so broad they could be used from anything sane to something that might be just political revenge.

The actual language:

> “As part of the merit review process, Federal agencies must perform pre-issuance reviews to ensure that Federal award proposals selected for funding are consistent with applicable law, Federal agency priorities, and the national interest.”