National Science Foundation (NSF) – Executive Orders

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 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 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 2, 2025
The NIH has updated its policy on foreign subawards, as detailed in Notice NOT-OD-25-104, released on May 1, 2025. This change aims to enhance transparency and national security in NIH-funded research involving foreign collaborations.Key Points:

  • New Award Structure: NIH will implement a structure where foreign subawards are issued as independent awards linked to the primary grant. This allows NIH to track funds individually while the primary institution reports scientific progress collectively.
  • Implementation Timeline: The new structure is expected to be in place by September 30, 2025, before Fiscal Year 2026.
  • Applicability: The policy applies prospectively to all NIH grants and cooperative agreements (new, renewal, and non-competing continuation) to domestic and foreign entities. Existing awards will not be retroactively revised.(Grants.gov)
  • Restrictions: Effective immediately, NIH will not issue awards that include subawards to foreign entities. Prior approval requests to add new foreign components or subawards to ongoing projects will also not be accepted.
  • Exceptions: The policy does not apply to funds provided to support foreign consultants or the purchase of unique equipment or supplies from foreign vendors.
  • Future Plans: NIH intends to expand this policy to domestic subawards for consistency.(Grants.gov)

For more details, refer to the full notice: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html

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.”

February 17, 2025
New FAQs answered from NSF

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.”

February 2, 2025 
Access to the Award Cash Management Service (ACM$) 
Access to the Award Cash Management Service (ACM$) has been restored and the system is available to accept payment requests as of 12:00 PM ET on February 2, 2025. See the FAQs for more information. You can direct your questions through this webform. We are receiving a large volume of submissions, and we will not be able to respond individually. As we collect your questions, we will compile and post frequently asked questions (FAQs) on this page. Please check back regularly to access these FAQs. Thank you for your work advancing science, engineering, technology and innovation for our nation.

January 28, 2025
The NSF has paused all review panels  
The NSF has paused all review panels, new awards, and payments under open awards to comply with OMB Memorandum M-25-13, which mandates a review of financial assistance programs in light of recent executive orders. NSF grantees must cease all non-compliant activities, particularly those involving DEIA principles. Updates and further guidance will be provided through an executive order implementation webpage. Grantees should work with their institutional research offices to ensure compliance and direct questions through the provided webform.

NSF Implementation of Recent Executive Orders – official website