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.

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.

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 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.”

April 11, 2025
The Department of Energy (DOE) today announced a new policy action aimed at halting inefficient spending by colleges and universities while continuing to expand American innovation and scientific research. In a new policy memorandum shared with grant recipients at colleges and universities, DOE announced that it will limit financial support of “indirect costs” of DOE research funding to 15%. 

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 websiteunder 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.”