May 20, 2025
NIH ESI Extension 
On May 20,2025 the  National Institutes of Health (NIH) announced automatic extension of Early-Stage Investigator (ESI) eligibility. This extension addresses delays impacting grant application submissions, peer review, or award processing timelines between January 1, 2025, and May 31, 2025, and seeks to mitigate their effects on the biomedical research community. 

Who Is Impacted

This Notice provides information about an extension of ESI eligibility for the following investigators:

• Investigators whose last submission date for a new/resubmission application, based on ESI eligibility, was October/November 2024 will be granted a three-receipt cycle extension (roughly twelve additional months). The last submission as an ESI will be October 2025

• Individuals whose last submission date for a new/resubmission application, based on ESI eligibility, was February/March 2025 will be granted a two-receipt cycle extension (roughly eight additional months). The last submission as an ESI will be October 2025

• Individuals whose last submission date for a new/resubmission application, based on ESI eligibility, will be June/July 2025 will be granted a one-receipt cycle extension (roughly four additional months). The last submission as an ESI will be October 2025

No action is required from investigators to receive this extension; thus, no ESI extension request submission is necessary. To aid potential applicants in determining whether they are eligible for the extension, the following examples are provided: 

Example 1: For individuals whose eligibility ended with the October/November 2024 due dates, the extension would allow them to apply for the R01 in June/July 2025 or October/November 2025.

Example 2: For individuals whose eligibility ended with February/March 2025 due dates, the extension would allow them to apply in June/July 2025 or October/November 2025.

Example 3: For individuals whose eligibility would normally end with the June/July 2025 due dates, the extension would allow them to apply in October/November 2025.

This extension does not preclude investigators from requesting additional time for qualifying life events (e.g., medical leave, caregiving) under existing policies.

May 20, 2025
Deferred Implementation of Indirect Cost Policy for Institutes of Higher Education (IHEs) 
Issuance Date: May 20, 2025 
Effective Date:  May 20, 2025 
Applies to: All new awards and associated subawards to IHEs. 

This notice is being issued to all NSF proposers and recipient organizations, Principal Investigators, and Authorized Officials for awareness.  The National Science Foundation (NSF) is temporarily pausing implementation of NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034) through June 13, when a hearing is scheduled to occur in the United States District Court for the District of Massachusettsin Association of American Universities, et al. v. National Science Foundation, et al., No. 25-cv-11231.  This policy applies to all new awards and associated subawards to IHEs. New NSF awards and associated subawards issued during this pause will not implement NSF 25-034 but will include a term applying NSF 25-034 for the entirety of the award if there is a court decision permitting application of the policy.   

NSF reserves the right to modify, rescind, or fully implement NSF 25-034 to the entirety of awards and subawards issued to IHEs on or after May 5, 2025 in accordance with applicable legal rulings and administrative procedures.

May 19, 2025
The NSF posted updated FAQs HERE. 
Topics  of note

• 15% F&A pause for Higher Ed institutions until the 6/13 court hearing. Current rates apply but NSF will include language now, instating the 15% in case they win.
• Waiving of required final outcomes reports for terminated grants.
• Clarification that appeals for terminated awards will not be reviewed or considered.
• details about terminated awards accounting

May 16, 2025
HHS  Preliminary Injunction (PI). 
Please note, this action only applies to the 23 Plaintiff States listed in the PI and the District of Columbia.
 A federal court in Rhode Island granted a preliminary injunction blocking the U.S. Department of Health and Human Services (HHS) from ending $11 billion in public health grants. The funds, allocated during the COVID-19 pandemic, supported programs like disease response, immunizations, and mental health services. HHS argued the funds were no longer needed post-pandemic, but 23 states and D.C. sued, claiming the termination was unlawful. The court sided with the states, finding they were likely to win the case and would face serious harm without the funding.  

May 15, 2025
AAU v DOE (D Mass May 15, 2025) Opinion and Order Granting Preliminary Injunction on DOE Indirect Cost Policy
Plaintiffs Association of American Universities (“AAU”), Association of Public and Land-Grant Universities (“APLU”), American Council on Education (“ACE,” and, with AAU and APLU, the “Organizational Plaintiffs”), and several public and private universities (together with the Organizational Plaintiffs, “Plaintiffs”) seek a preliminary injunction halting implementation of a Department of Energy (“DOE” or “the Department”) “Policy Flash,” which sets a universal cap on indirect funding costs for Institutes of Higher Education (“IHEs”) (the “Rate Cap Policy” or the “Policy Flash”). Plaintiffs allege that the Rate Cap Policy is arbitrary and capricious, impermissibly retroactive, and contrary to governing law.
For the foregoing reasons, the Plaintiffs’ motion for a preliminary injunction is GRANTED.

May 15, 2025
NSF Priorities Updates
The National Science Foundation (NSF) provides specific guidance for awardees whose grants have been terminated, detailing the requirements for submitting an itemized accounting of allowable costs.

• Allowable Costs: Only costs incurred prior to the termination date are considered allowable.
• Submission Format: There is no prescribed template; however, the cost ledger should be submitted in a non-PDF electronic format, such as Microsoft Excel or CSV.
• Content of Cost Ledger: The ledger should include detailed information for each expense, such as cost category, description, and date expended.
• General Ledger Export: Institutions using financial systems may submit a general ledger export, provided it offers detailed transaction information rather than summary totals.
• Submission Process: The final documentation should be sent to dgafinalcosts@nsf.gov by the organization’s Authorized Organizational Representative (AOR)
• Review and Payment: Upon submission, NSF will review the cost ledger. Once approved, the award threshold will be updated in ACM$ to permit a final payment request.
• Finality of Payment: After the final payment is processed, no further adjustments will be permitted, and traditional final financial reporting and adjustment periods do not apply to terminated awards.

May 14, 2025
On May 14 NSF posted updated guidance regarding terminated grants. Please see the NSF website for updates on NSF priorities and FAQs HERE. 

May 7, 2025
Updated NIH Processes for No-Cost Extensions 
This notice alerts the extramural community that NIH has temporarily disabled the No-Cost Extension functionality in eRA Commons. The Director of NIH has directed NIH staff to review all existing grants and cooperative agreements to ensure that NIH awards do not fund off-mission activities or projects. Therefore, temporarily disabling the NCE functionality in eRA Commons will allow NIH staff to review and assess all NCE requests to confirm that the activities proposed during the extension align with the NIH mission and agency priorities.

At this time, all requests for NCEs must be submitted as a prior approval request in eRA Commons, for NIH review and approval. Requests for activities that do not align with the NIH mission and agency priorities will not be approved.

May 5, 2025
Perkins Coie LLP v U.S. Department of Justice, et al  Motion to Dismiss
Upon consideration of plaintiff Perkins Coie LLP’s Motion for Summary Judgment and Declaratory and Permanent Injunctive Relief, ECF No. 182; the government’s Renewed Motion to Dismiss and for Expedited Judgment, ECF No. 183; the memoranda, declarations, and exhibits submitted in support and opposition; the arguments in support and opposition presented at the motions hearing held on April 23, 2025, and the entire record herein, it is hereby:
(1) ORDERED that plaintiff’s Motion for Summary Judgment and Declaratory and Permanent Injunctive Relief, ECF No. 182, is GRANTED; it is further
(2) ORDERED that the government’s Renewed Motion to Dismiss and for Expedited Judgment, ECF No. 183, is DENIED; it is further
(3) DECLARED that Executive Order 14230, 90 Fed. Reg. 11781 (Mar. 11, 2025), issued by the President on March 6, 2025, entitled “Addressing Risks from Perkins Coie LLP,” is unlawful because it violates the First, Fifth, and Sixth Amendments to the U.S. Constitution and is therefore null and void;…

May 5, 2025
Memorandum Opinion Granting Summary Judgment and Declaratory and Permanent Injunctive Relief
Part I reviews the relevant factual and procedural background of this case. Part II provides the legal standards governing consideration of plaintiff’s motion for summary judgment, under Federal Rule of Civil Procedure 56, and the government’s motion to dismiss and cross-motion for summary judgment, under Rules 8, 12(b)(1), 12(b)(6), and 56.
Part III then turns to the substantive issues in dispute, which are discussed in three sections.
Part IV provides a brief conclusion summarizing the disposition of the pending motions.

May 2, 2025
NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate
Effective May 5, 2025. All new NSF financial assistance awards and subawards. The U.S. National Science Foundation (NSF) is updating its policy regarding the reimbursement of indirect costs in federally funded financial assistance. 

Implementation

• NSF funding opportunities issued after May 5, 2025, will include notice of this indirect cost rate policy to ensure public awareness.
• The 15% rate maximum applies only to new awards made to IHEs on or after May 5, 2025.
• Recipients must use a rate no greater than 15% of modified total direct costs (MTDC), as defined in 2 CFR 200.1.
• This policy does not apply retroactively to existing awards.
• Institutions are not required to amend budgets for awards issued before this effective date, nor will they be required to return previously reimbursed indirect costs.
• Award supplements that are effectuated via amendments to awards in existence prior to May 5, 2025, are not subject to this policy.
• Continuing grant increments are awarded under the original award terms and conditions; continuing grant awards in existence prior to May 5, 2025, are not subject to this policy.

May 1, 2025
New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight, and National Security of NIH Funded Research
Effective with the next NIH award cycle, all NIH-funded research involving foreign subawards must be structured as subprojects directly linked to the prime award. Foreign subawards are prohibited from being nested under the parent grant. Guide Notice NOT-OD-25-104 prospectively updates NIH policies and practices for utilizing foreign subawards. 

Effective May 1, 2025, NIH will:

• Not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity.
• No longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.
• Renegotiate new, renewal or non-competing awards to remove subawards to foreign entities, and allow the funds to be rebudgeted for use by the prime recipient when the work can be performed domestically
• Work with the recipient to negotiate a bilateral termination if a project is no longer viable without the foreign subaward, taking into consideration any need to support participant safety and/or animal welfare.

This is a temporary pause for foreign subawards, while NIH finalizes the implementation of the new award structure (expected no later than September 30, 2025). The clearer structures and safeguards seek to enhance transparency, trackability, and protect national security in the areas of both monetary and non-monetary foreign collaborations.

April 21, 2025
Notice of Civil Rights Term and Condition of Award. NOT-OD-25-090

The NIH has issued Notice NOT-OD-25-090, introducing a new Civil Rights term and condition for all NIH grants, cooperative agreements, and other transaction (OT) awards issued on or after April 21, 2025. This term supersedes Section 4.1.2 “Civil Rights Protections” of the NIH Grants Policy Statement and applies to domestic recipients of new, renewal, supplement, or continuation awards. Grants.gov

Key Provisions:

• Compliance with Federal Anti-Discrimination Laws: Recipients must adhere to all applicable federal civil rights laws that prohibit discrimination based on race, color, sex, religion, and national origin.
• Prohibitions on Certain Activities:
  • Recipients must not operate programs that promote Diversity, Equity, and Inclusion (DEI), Diversity, Equity, Inclusion, and Accessibility (DEIA), or “discriminatory equity ideology” in violation of federal anti-discrimination laws.
  • Recipients must not engage in “discriminatory prohibited boycotts,” defined as actions that refuse or limit commercial relations specifically with Israeli companies or entities doing business with or in Israel.
• Certification Requirement: By accepting the award, recipients certify compliance with the above provisions.
• Enforcement: NIH reserves the right to terminate awards and recover funds if recipients violate these terms.

This policy does not apply to foreign and international organizations. For further details, please refer to the full notice: NOT-OD-25-090.

April 16, 2025
Temporary Restraining Order on DOE Rate Cap Policy
Defendants and their officers, employees, servants, agents, appointees, and successors are hereby enjoined from implementing, instituting, maintaining, or giving effect to the DOE Policy Flash: Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE) (the “Rate Cap Policy”) in any form; from otherwise modifying negotiated indirect cost rates except as permitted by statute and by the regulations of the Office of Management and the Budget; and from terminating any grants pursuant to the Rate Cap Policy or based on a grantee’s refusal to accept an indirect cost rate less than their negotiated rate.

April 14, 2025
APLU, AAU, & ACE Legal Challenge to Cuts to Critical Energy Research
The Association of Public and Land-grant Universities (APLU) today joined with the Association of American Universities (AAU) and the American Council on Education (ACE) as plaintiffs in a lawsuit challenging the Department of Energy’s action limiting Facilities and Administrative (F&A) reimbursements (indirect cost rate) to 15% for research grants to colleges and universities. This action would have an immediate and dire impact on critical energy, physical sciences and engineering research nationwide. “It also sets a very dangerous precedent that could be used to undermine federal investments in research at many other federal agencies. A similar attempt to unilaterally cap the indirect cost rate for NIH grants to colleges and universities was enjoined nationwide.

“F&A costs are the real and necessary costs of conducting the groundbreaking research that has led to so many advances, that has positioned the United States as a global scientific leader and has improved the lives of our nation’s citizens. With funding from DOE, our nation’s researchers are driving innovations in fusion and advanced nuclear energy, nuclear security, microelectronics, materials research, advanced computing, fossil and alternative energy research, grid technologies, quantum science, and AI in furtherance of American science and a secure energy future.”

March 25, 2025
NASA has updated the NASA Grant and Cooperative Agreement Manual (GCAM) and NASA Grant and Cooperative Agreement Terms and Conditions (GCAT) to comply with recently-issued Executive Orders. Both documents are now available on the NASA Grants Policy and Compliance website under the “Regulations, Guidance, and Forms” section. 

March 20, 2025
Washington v. Trump – notice of court order – PI clarification – 03-20-25
258 – Order on Motion for Contempt
The Court has clarified the preliminary injunction in Washington v. Trump, restricting enforcement of certain provisions in Executive Orders 14,168 and 14,187 within Washington, Oregon, Minnesota, and Colorado. These provisions aimed to limit federal funding for “gender ideology” and prohibit funding for medical institutions supporting gender-affirming care for minors. The injunction prevents the federal government from enforcing these restrictions in the plaintiff states, requiring agencies to administer grants as they did before the orders. Agencies, employees, contractors, and grantees must comply and refer to the Court’s order for guidance.

March 14, 2025, Instructions for Payment Management System User
In order to implement Executive Order 14222 — Implementing the President’s “Department of Government Efficiency” Cost Efficiency— PMS is introducing a new mandatory field in the payment request screen at the subaccount level on March 17, 2025. This field, limited to 1,000 characters, will capture a justification from the Grant Recipient explaining the purpose of the payment. Justifications can be brief or more detailed, such as:

• • “Purchase of anti-retroviral drugs for HIV/AIDS clinics in Uganda.”
  • “Reimbursement of payroll and supply expenses for a Head Start preschool program.”

March 12, 2025
Message from Dr. Sethuraman Panchanathan, Director, U.S. National Science Foundation.
“…NSF staff continue to work around the clock, even under great stress and uncertainty, to do the hard work that is necessary. They do so because they understand that NSF’s mission is incredibly important to our economic and national security. However, it is equally important that everyone who plays a role in the research enterprise also does their part to communicate broadly the value and impact of America’s scientific enterprise and what it makes possible for individuals, communities, our states, and the nation.”

March 10, 2025 
Special Notice to All Foreign Assistance Recipients
On March 10, 2025, the U.S. District Court for the District of Columbia, in cases titled AIDS Vaccine Coalition v. U.S. Department of State and Global Health Council v. Trump, granted in part a preliminary injunction against the U.S. Department of State, the U.S. Agency for International Development, and the Office of Management and Budget.

March 10, 2025 
Notice of Court Order, PFLAG v. Trump, 8:25-cv-337-BAH (D.Md.) To Agencies, Employees, Contractors, and Grantees, U.S. Department of Health & Human Services, National Science Foundation
Preliminary Injunction Order
A preliminary injunction has been issued in PFLAG v. Trump, blocking enforcement of provisions in Executive Orders 14,168 and 14,187 that restricted federal funding for entities providing gender-affirming care to minors. The injunction prohibits the government from conditioning, withholding, or terminating funding based on the provision of such care. Agencies and their personnel must immediately comply, including reinstating any paused funds. Written notice of the ruling must be provided to all relevant employees, contractors, and grantees. For details, refer to the attached Court Order.

March 5, 2025
2025.03.05 – Washington v. Trump – Notice of Court Order
Summation of 2025.03.05 – Washington v. Trump – Notice of Court Order
Here is a summary of the key terms:
1. Defendants and all their respective officers, agents, servants, employees, and attorneys, and any person in active concert or participation with them who receives actual notice of this Order, are hereby fully enjoined from enforcing or implementing Section 4 of EO 14,187 within Washington, Oregon, Minnesota, and Colorado.
2. Defendants and all their respective officers, agents, servants, employees, and attorneys, and any person in active concert or participation with them who receives actual notice of this Order, are hereby fully enjoined from enforcing Sections 3(e) or 3(g) of EO 14,168 to condition or withhold federal funding based on the fact that a health care entity or health professional provides gender-affirming care within Washington, Oregon, Minnesota, and Colorado.

March 5, 2025
NASA’s Science Mission Directorate (SMD) is working to comply with new Executive Orders, policies, and court rulings affecting grants, cooperative agreements, and contracts. Due to the complexity of implementing these changes, processing times are longer than usual.
Key updates:

February 28, 2025 
Message to Grant Recipients on Manual Review Process  
Effective immediately, FEMA and DHS are conducting additional reviews of allocations before releasing funds for all grants. These actions will ensure that funding is obligated and disbursed in line with the Secretary’s direction so that we can continue to support and prioritize communities and disaster survivors who rely on FEMA for assistance. Upon completion of reviews, approved funding will be processed through the respective grant systems.

February 19, 2025
Washington v. Trump – notice of court order – 2-19-25
A temporary restraining order has been entered in the case of Washington v. Trump.
This case challenges two sections in Executive Order (EO) 14,187, Protecting Children from Chemical and Surgical Mutilation (Jan. 28, 2025). Plaintiffs challenged Section 4, which directs the heads of departments and agencies “that provide[] research or educational grants to medical institutions” to, “consistent with applicable law and in coordination with the Director of the Office of Management and Budget, immediately take appropriate steps to ensure that institutions receiving Federal research or education grants end the chemical and surgical mutilation of children.” EO 14,187 § 4. Plaintiffs also challenged Section 8, which instructs the Attorney General to “review Department of Justice enforcement of section 116 of title 18, United States Code, and prioritize enforcement of protections against female genital mutilation.”

In response to Plaintiffs’ motion, the Court has entered a temporary restraining order prohibiting certain actions by the Defendants in the case within the Plaintiff states of Washington, Oregon, and Minnesota, which is effective immediately. All Defendants—including their employees, contractors, and grantees—must immediately comply with the Court’s Order.

February 17, 2025
New FAQs answered from NSF

February 10, 2025
NIH rate change blocked by federal judge
A Federal Judge issued a restraining order that placed a temporary pause nationwide on plans by the NIH to cap indirect cost rates.

February 10, 2025
Federal Court Filing regarding NIH Grants Policy Statement: Indirect Cost Rates
Twenty-two states file to block indirect cost rate cap. 

February 7, 2025
NSF Guidance Updated 
The National Science Foundation has posted updated guidance regarding activities mentioned in the rescinded Memorandum M-25-13, including diversity, equity, and inclusion. The NSF guidance states, “Consistent with the district court’s order, NSF awardees may continue activities consistent with the current terms and conditions of their NSF awards at this time.”