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.