Federal Research Funding Updates: April 16, 2025 

Proposals and Post-Proposal Considerations 

• Submission: Federal agency submission systems are operational, and UVA will continue to submit proposals according to our normal process.
• While federal agency proposal submission portals are currently operational, we caution researchers about unannounced updates to Notices of Funding Opportunities (NOFOs) that may impact submission.  Additionally, solicitation information in ResearchUVA may be out-of-date. Please refer directly to the NOFO on the agency website for the latest information.
• Indirect Costs: Unless there is a valid exception on a specific award, all federal proposals will be submitted with UVA’s negotiated indirect cost rate agreement.  Offices with delegated authority to submit proposals have been provided with language to include in the application package to accommodate a future change in applicable indirect cost rate due to a change in applicable law.
• At-Risk (Advance) Accounts: Under OSP’s Advance Account Procedure, PIs can request a grant worktag prior to the acceptance of the award in ResearchUVA and Workday.
• Requesting at-risk accounts remains at the discretion of the individual school/department requesting the account.  Many units within UVA are monitoring these costs closely given the current environment since ultimately the unit is financially responsible if UVA does not receive the award that the at-risk account supports. Consult with your unit’s research administrator or central office to evaluate whether an advance account is appropriate given the status of your award. 

Award Considerations 

• While the situation remains fluid, research activities should continue as usual, unless you have received specific guidance otherwise.  

• Award Adjustments: You may receive instructions directly from your Program Officer or sponsor of changes to your grant, including requests for scope of work changes, funding decreases or anticipated future modifications. Do not respond, complete or sign any certifications, acknowledgements, questionnaires or surveys sent to your attention from federal sponsoring agencies.  Please immediately forward any direct communication from a federal agency or sponsor to ospnoa@virginia.edu. 

• Research Expenditures: PIs and research administrators should closely monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed. Be conservative about large expenditures but continue activities necessary to meet contractual obligations. 

• We are receiving notices with retroactive effective dates. Since our practice is not to retract Workday award line end dates prior to today's date, the end dates of the award lines in the financial system may be a few days off from the actual termination effective date. Please make sure that no new transactions are processed after the actual termination effective date.   

• Ensure that all project costs are charged directly to the sponsored research worktags in a timely manner to reduce after-the-fact transfers.  

• Terms and Conditions: The terms and conditions of your executed award remain enforceable so long as your award is active. This includes the ability to invoice and receive reimbursement. Please continue with business as usual. If there is a change to your award, we will receive an amendment for review and execution. 
• Review Your Grant Agreement to ensure you understand the terms, especially clauses related to funding availability and reimbursement. 
• Research Compliance: We anticipate updates to award Research Compliance requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis.  
• Reporting Requirements: We anticipate updates to award reporting requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis. 

• Prioritize the submission of any technical reports or deliverables that may have been past due. 

No Cost Extensions (NCEs)  

• OSP is closely tracking NCE activity, and we have seen NCE approvals from a variety of agencies consistent with their normal guidelines and applicable regulations.  OSP recommends that PIs coordinate closely with any award Program Officer if they can and also consult with their unit research administrators for guidance before requesting a NCE.  PIs should ensure that NCE requests are submitted with sufficient time for processing keeping in mind that changes in federal agencies may experience backlogs and delays in granting approvals. 

Stop-Work Orders and Early Terminations 

• Federal sponsors have issued stop-work orders, suspension notices, or termination notices for certain awards or activities. It is important to understand the distinctions between these notices and their implications for ongoing projects. Please immediately forward any direct communication from a federal agency or sponsor to ospnoa@virginia.edu as OSP must take immediate action. OSP will act as your primary point of contact during the termination process. 
  • Stop-Work Order: a written notice issued by the sponsor (or flowed-down from the pass-through entity) to immediately suspend all, or any part, of the work under an award without terminating the award. In some cases, a stop-work order may precede an early termination. 

  • Termination Notice: An official, legal notice from the federal government or a pass-through entity ending the agreement. These differ from non-award specific agency-specific notices, memos or award modifications issued in response to executive orders. All work must cease as of the effective date. If subrecipients are involved, termination notices must be issued to them as well.  

• Stop-work orders, terminations and other agency-specific notices require careful review. OSP will determine whether the notice is compliant with regulations applicable to the specific award, and whether the notice is a full termination or allows for partial continuation or re-scoping. OSP will work with the PI, department, Dean’s office, OVPR and other stakeholders to assess the impact on each project and evaluate next steps.  

• In the case of termination notices from federal agencies, an appeals process may be available. These appeals are time sensitive. Please let OSP know as soon as possible if you wish to pursue an appeal. Appeals are a University decision, but the input from the PI will help inform the decision-making process. 

• Research Expenditures: After the date of termination, expenses incurred for project activities or deliverables funded by the terminated award are not allowable and will not be reimbursed under most award regulations unless specific pre-approval has been provided by the Sponsor’s or Pass-through Entity’s authorized Contract or Grant Officer. Approvals from Technical Representatives and other program officers are not binding. 

• Some expenses, considered closeout costs, can still be charged to a grant after it ends or is terminated. Allowable expenses include financial obligations that cannot be canceled and costs that wouldn’t have been incurred had the grant not been terminated early. 2 CFR §200.343 and 2 CFR §200.472 define closeout costs for federal grants. Work with OSP Post Award if you have questions on allowability of costs. 

• Research Terms and Conditions: Some stop-work orders or termination notices are not following sponsored award terms and conditions. OSP Post Award may need to submit final financial reports or invoices earlier than the typical 90-120 day window, and therefore you may not be able to move legitimate expenses on to the sponsored award.  

• The PI and research administrator should coordinate with OSP Post Award to ensure all project costs charged up to the termination or stop-work order effective date are included in the final financial report or invoice. 

• Review and follow the applicable regulations in your award agreement pertaining to close out and settlement under a termination, which may include a termination plan, asset disposition procedures, Institutional Review Board (IRB) and/or Institutional Animal Care and Use Committee (IACUC) requirements, and Intellectual Property and Data ownership requirements. 

• Normally, when a grant-funded research program ends as expected, investigators can plan to make sure they finish up animal experiments and human subjects’ research. Contact the IRB and IACUC immediately following the receipt of a termination or stop-work order.  

Responsibilities Related to Award Stop-Work or Termination 

• All: Immediately forward any direct communication from a federal agency or sponsor to ospnoa@virginia.edu.  

• OSP: OSP will ensure the PI, study team, and impacted school(s)/department(s) are notified following the receipt of a stop-work order or early termination.  

• PI and Study Team: Work with your research administration team to assess project implications, especially for progress-to-completion, payroll implications, including graduate students, and compliance and safety requirements. Immediately stop work on all activities and deliverables funded by the referenced award. 

• OSP Pre-Award: OSP will create a modification in Research UVA and Workday Financials to change the end date of the award line to ensure that charges that postdate the stop-work order or termination date are not allowable. 

• OSP Outgoing Subaward Team: Any potential subawards must be notified immediately. OSP will send notice to the administrative contact at the subrecipient and the subrecipient PI.  

• OSP Post Award: Post Award portfolio accountants will work with the departments to review and reconcile expenditures and submit final financial reports or invoices in a timely manner. Post Award Cash Management will track cash statuses in sponsors’ payment systems and resolve anomalies directly with the sponsors. Post Award Financial Compliance team will review and enter subaward invoices for PI review & certification.  

• Please email ospnoa@virginia.edu with any questions. 

On March 14, 2025 the Senate passed a spending measure to fund the government though September 30, 2025. The Full-Year Continuing Appropriations and Extensions Act, 2025 reduces non-defense spending to the levels in the 2024 budget year and increases defense spending by $6 billion. It also contains a 57% reduction in appropriations to Congressionally Directed Medical Research Programs (CDMRP). The landscape continues to change rapidly given the impacts of recent Executive Orders (EOs) and actions by the Department of Government Efficiency (DOGE). We are actively monitoring the situation and will provide additional information as it becomes available.  

To ensure the sustainability of our research programs, we ask you to continue to be mindful of your spending against federal grants. For example, please be cautious about incurring unneeded non-personnel costs and assess the necessity of making new research hires and/or purchasing new equipment as we continue to monitor the changing environment. As you are aware, federal funding works on a reimbursement model, which means the University does not receive federal funds until after expenses are incurred. We believe that prudent spending now will help protect UVA research in the long term and safeguard the best interests of your research and the institution. 

Should you receive stop work instructions from a sponsor, or other grant-related communications, please immediately share with research administration staff in your units and OSP (ospnoa@virginia.edu). If the VPR office becomes aware that a stop work order is issued, staff will follow up with additional information for affected investigators and units.  

You can find research-specific FAQs online at research.virginia.edu/resources/federal-updates and institutional updates at federalinfo.virginia.edu. 

As you may be aware, today a federal judge extended the temporary restraining order blocking the implementation of the proposed 15% cap on indirect research funds provided by the National Institutes of Health (NIH). The decision follows arguments from 22 states and several academic organizations, which emphasized the potential harm that these funding restrictions could pose to research progress and infrastructure. While it's unclear from the current reporting what the duration of the extension is, Judge Kelley has indicated that she hopes to make a ruling "quickly."

In another update, Nature is reporting that grant reviews continue to be delayed as new requirements on posting advance notices in the Federal Register have caused both a backlog of applications and the awarding of new grants to be stalled. The NIH workforce has also undergone severe cuts, further undermining their response time.

The OVPR will continue to monitor federal updates and share any information that may affect research at UVA. Please reach out with any questions or concerns.

There has been an important update regarding the recent NIH supplemental guidance. Late last night (February 10), a nationwide temporary restraining order (TRO) was issued on behalf of several organizations, including the Association of American Medical Colleges (AAMC), the American Association of Colleges of Pharmacy, the Association for Schools and Programs of Public Health, the Conference of Boston Teaching Hospitals, and the Greater New York Hospital Association. The court has prohibited the NIH, HHS, and their officials from implementing or enforcing the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (NOTOD-25-068), issued on February 7, 2025, across all institutions nationwide until further notice. The court's decision provides immediate relief to research institutions, preventing the NIH from enforcing the funding cuts until further notice. A hearing to evaluate next steps has been set for Feb. 21. 

This action was in addition to a federal judge in the U.S. District Court for Massachusetts granting a TRO blocking the implementation of the NIH supplemental guidance. This TRO was issued in response to a lawsuit filed by a coalition of 22 states. The Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and American Council on Education (ACE) also filed a separate lawsuit against the NIH on February 10, 2025, seeking both a TRO and an injunction against the supplemental guidance. 

This ruling is important news for our research community, ensuring that ongoing projects will not be disrupted by these proposed funding reductions at this time. 

We will continue to monitor the situation closely and provide updates as more information becomes available. As shared in previous messages, please continue to do your research, be cautious about spending, and share any communications you receive from program officers or agencies with OSP.  

Visit our federal updates page to find resources and all research-related updates. 

On Friday evening, the National Institutes of Health (NIH) issued supplemental guidance to the 2024 NIH Grants Policy Statement stating that facilities & administrative (F&A) costs (also known as indirect costs) will now be set at a standard rate of 15% for all NIH grantee institutions. According to the guidance, this 15% rate would replace any individually negotiated rates for an institution beginning Monday, February 10, 2025. 

Association of American Universities states, F&A costs are the essential costs of conducting research. While the “direct costs” portion of a grant supports researcher salaries, graduate students, equipment, and supplies, “indirect costs” cover necessary research infrastructure and operating expenses that the university provides to support the research. These research expenses include: state-of-the art research laboratories; high-speed data processing; national security protections (e.g., export controls); patient safety (e.g., human subjects protections); radiation safety and hazardous waste disposal; personnel required to support essential administrative and regulatory compliance work, maintenance staff, and other personnel, infrastructure, and activities necessary for supporting research. A helpful fact sheet on F&A costs can be found here 

This news is concerning, and we are actively assessing the implications for research at UVA. We are aware that the AAU, APLU, AAMC and COGR are working on responses to this action. While we wait for more clarity about the next steps, we ask that all researchers, regardless of funding agency, continue to do your research (unless you are in receipt of a stop order), train your PhD students, work with your postdocs, and be mindful of your spending against federal grants. 

We recognize the critical importance of your work and the potential challenges introduced by this new guidance. Please be assured that we will keep you informed of any further developments. All federal research updates can be found at research.virginia.edu/resources/federal-updates 

The past two weeks have been challenging as we have navigated multiple developments related to federally-funded research and worked to understand their implications for our institution and our community members. We continue to monitor the situation closely and are committed to providing you with the most up-to-date information. 

As part of this information sharing, we thought it would be helpful to explain how federal funds flow to the University. Federal funding for sponsored research is not typically provided to universities in advance of incurred costs, but rather is received as a reimbursement. This means that UVA covers research expenditures upfront, then invoices the federal government and “draws down” those funds via federal payment sites. Given this process, it is essential that we carefully monitor and manage our federal research expenditures to account for any potential slowdowns in the reimbursement process or future changes in payment processing. 

At present, the School Deans and our offices are committed to bridging salary coverage for grant-funded personnel (faculty, graduate student, postdoctoral fellows, and research staff) if needed in the near-term. We will continue to assess matters as we receive new information and will update you if the situation changes. To ensure the sustainability of our research programs, we are asking you to be mindful of your spending against federal grants. For example, please be cautious about incurring unneeded non-personnel costs and assess the necessity of making new research hires and/or purchasing new equipment over the next few weeks as we continue to monitor the current environment. We believe that prudent spending now will help protect UVA Research in the long term and safeguard the best interests of your research and the institution. 

Thank you in advance for your understanding. If you have any questions or concerns, please feel free to reach out via askresearch@virginia.edu. We are here to support you during this time.

Yesterday, the White House rescinded OMB memo M–25-13, which froze federal grant and loan dollars from being distributed. Action related to the memo had also been blocked by a federal judge until Monday, February 3, 2025. The underlying Executive Orders issued by the new Administration remain in place.

As previously advised, please continue with your research activity, unless you have received a project-specific stop work order that is related to the Executive Orders remaining in place. If you have received a stop work order, or have questions or concerns about your current award, please email askresearch@virginia.edu. We are here to support the UVA Research community and help you navigate these changes.

We will continue to monitor the situation and will share new information with you as soon as it becomes available. 

Thank you for your continued dedication to our research mission.

We understand the feeling of uncertainty surrounding the recent White House Office of Management & Budget (OMB) memo M-25-13 released late last night on January 27, 2025. This memo issued a temporary pause on (i) issuance of new awards; (ii) disbursement of Federal funds under all open awards; and (iii) other relevant agency actions that may be implicated by the executive orders, to the extent permissible by law, until OMB has reviewed and provided guidance to the agency. As of this afternoon, a judge has temporarily blocked the freeze related to funding for “open awards” already granted by the federal government until Monday, February 3, 2025.

This situation is changing rapidly and we are actively monitoring to ensure we are up-to-date on the latest information. We will continue to share new information with you as soon as it becomes available. Importantly, we are here to support you as we all traverse these changes together.

To help the research community navigate until more information is available and our understanding becomes clearer, please see the guidance below. Note that this guidance will be updated as we learn more.
 

Research Activity

• Please continue your research activity as planned through the review period noted in the OMB M-25-13 memo (until February 10, 2025), unless you have received a stop-work order. This guidance may be updated as more information becomes available.
• Travel arrangements using obligated and approved funds may proceed. 

Proposals

• Please continue to submit previously planned grant proposals. We have no information to indicate that federal agencies' submission systems are closed.
• Pay close attention to possible changes in submission due dates and in requirements in new funding announcements.
• Note: Due to unannounced updates to Notices of Funding Opportunities (NOFOs), solicitation information in ResearchUVA may be outdated. Please refer directly to the NOFO on the agency website for the latest information. Currently, we do not know if there will be an impact on ResearchUVA system-to-system submissions.
• We have no information as to whether previously scheduled NIH study section review panels will be held as planned over the next several weeks; however, NSF has announced a pause on study section panels until February 1, 2025.

Awards

• We have no information as to when new funds might be received for recently issued Notice of Award statements.
• We anticipate updates to award Research Compliance requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis.
• We anticipate updates to award reporting requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis.
• Agencies are issuing stop-work orders that are being implemented on a direct project basis as well as general directives to suspend work related to broad types of programs and activities, such as diversity, equity and inclusion (DEI) programs and Community Benefit Plans (CBP). Notify OSP of any stop-work communication immediately.

Recommended Actions

• You may receive instructions directly from your Program Officer or sponsor. It is crucial to act swiftly to ensure compliance with any new requirements, as failure to do so could jeopardize funding. Please immediately forward any direct communication from a federal agency or sponsor related to your award or research compliance to ospnoa@virginia.edu
• Review your grant agreement to ensure you understand the terms, especially clauses related to funding availability and reimbursement.
• Closely monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed.
• Prioritize the submission of any technical reports or deliverables that may have been past due.
• Keep an eye on announcements from the federal agency overseeing your grant for any updates on funding or compliance requirements.
• Diligently monitor proposal deadlines as they may change.
• Check if the funding announcement has been revised or postponed. If available, sign up for alerts from the federal agency or sponsor.

The National Institutes of Health (NIH) has issued supplemental guidance to the 2024 NIH Grants Policy Statement, setting a standard facilities & administrative (F&A) cost rate of 15% for all NIH grantee institutions. This new rate will replace any previously negotiated institutional rates and will take effect on Monday, February 10, 2025.

However, on February 11, a federal court issued a temporary restraining order (TRO) suspending the change in response to a lawsuit challenging the NIH guidance. The TRO was then extended on February 21.

Faculty and PIs are encouraged to:

• Continue conducting research
• Be mindful of spending against federal grants

• Follow any specific directives from funding agencies (e.g., stop orders)
   

All federal research updates will be posted at research.virginia.edu/resources/federal-updates. Faculty should check this site regularly for new information.

Agencies are issuing stop-work orders that are being implemented on a direct project basis as well as general directives to suspend work related to broad types of programs and activities, such as diversity, equity and inclusion (DEI) programs and Community Benefit Plans (CBP). Notify OSP of any stop-work communication immediately.

Please continue with your research activity, unless you have received a project-specific stop work order. 

If you have received a stop work order, or have questions or concerns about your current award, please email askresearch@virginia.edu.

To ensure the sustainability of our research programs, we are asking you to be mindful of your spending against federal grants. For example, please be cautious about incurring unneeded non-personnel costs and assess the necessity of making new research hires and/or purchasing new equipment over the next few weeks as we continue to monitor the current environment.

Travel arrangements using obligated and approved funds may proceed. 

Please continue to submit previously planned grant proposals. We have no information to indicate that federal agencies' submission systems are closed.

Pay close attention to possible changes in submission due dates and in requirements in new funding announcements.

Please immediately forward any direct communication from a federal agency or sponsor related to your award or research compliance to ospnoa@virginia.edu

If you have any questions or concerns, please feel free to reach out via askresearch@virginia.edu.