Federal Funding Updates Under the New Administration
OMB Memo Guidance
On February 3, 2025, the Trump administration issued new guidance to federal agencies clarifying how it intends to comply with a temporary restraining order (TRO) imposed by the U.S. District Court for the District of Rhode Island on January 31. The guidance clarifies that federal agencies cannot 鈥減ause, freeze, impede, block, cancel or terminate鈥 any federal grants on the basis of the now-rescinded OMB memo from January 27 or any recent Executive Orders. This includes stop work orders issued to institutions as well as individual PIs on specific grants.听
Based on this ruling and the accompanying guidance, we ask that all researchers, faculty, and staff continue working on their grants as normal.听
The administration鈥檚 guidance says federal agencies must release funds for all grants, not just grants in the 22 states, including Colorado, who filed the lawsuit. As stated in the Notice of Court Order:
1. Federal agencies cannot pause, freeze, impede, block, cancel, or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President鈥檚 recently issued Executive Orders.
2. This prohibition 鈥 also applies to future assistance (not just current or existing awards or obligations).
3. Agencies may exercise their own authority to pause awards or obligations, provided agencies do so purely based on their own discretion鈥攏ot as a result of the OMB Memo or the President鈥檚 Executive Orders鈥攁nd provided the pause complies with all notice and procedural requirements in the award, agreement, or other instrument relating to such a pause鈥. (e.g.) agencies remain free to exercise their own discretion under their 鈥渁uthorizing statutes, regulations, and terms,鈥 including any exercise of听discretion to pause certain funding. Additionally, agencies remain free to take action pursuant to the terms of the relevant award or obligation, such as in cases of grantee noncompliance.
NIH Guidance听
as of 2/12/2025
NIH issued the afternoon of Friday, February 7, 2025. This notice reduces the facilities and administration (鈥淔&A鈥 or indirect cost) rate that NIH will fund to 15%, as of Monday, February 10, 2025. There are three related court cases and temporary restraining orders halting implementation of this notice.
91福利社 is doing the following:
- Proposal submissions. All proposals must be submitted in accordance with 91福利社鈥檚 negotiated (full) F&A rate. Proposals may NOT be submitted at 15%. (Non-standard proposals such as fellowship grants can continue to be submitted in accordance with program notices of funding opportunities.)
- New awards.听We anticipate new awards to be issued with 91福利社鈥檚 negotiated rate agreement. 听If we receive new awards that reference the 15% F&A rate, such awards will be placed on hold until such time as this issue is resolved. The same is true of any NIH flow-through awards we receive from other institutions that reference the 15% rate.
- No-cost extensions. The automatic NCE link in eRA Commons has been deactivated. We have not yet received any official explanation from NIH regarding why this is the case. There is a real possibility that NIH will no longer allow us to take a one-time automatic no-cost extension at the end of our period of performance. PIs should not assume that no-cost extension requests will be approved for NIH funded projects. 听
- Reimbursement. We anticipate current awards to continue using 91福利社鈥檚 negotiated rate agreement. Research Financial Service will draw down funds from NIH at the negotiated rate.
This guidance may change frequently in the comin