Guidance for Federally Funded Research Activities

Page last updated: June 18, 2025

Since January 20, 2025, numerous Executive Orders (EOs) have been issued, signaling shifts in federal priorities. While federal agencies navigate these EOs – and corresponding legal actions – the Iowa State research community has responded with patience, perseverance, and resilience in the face of questions and uncertainty about both active research grants and upcoming proposals.

On January 30, 2025, the Office of the Vice President for Research (OVPR), launched an effort to provide tailored guidance to principal investigators (PIs) with questions regarding grants and proposals that were or could be impacted by changes in federal priorities and funding. To date, the team has triaged and responded to more than 400 PI inquiries. Our team will continue to work with investigators as agencies provide more concrete guidance. If you have any concerns about a grant or contract, please email fedfunds2025@iastate.edu and include the following information in your message: your name; agency; project number; and information in question.

Modify Proposals to Meet Changing Requirements

As a principal investigator (PI), lean on guidance from the professional organizations that represent your discipline and scholarly interests. Most important, carefully review the most current RFPs from your funding agencies and be sure your project proposals adhere to their requirements, language, and standards.

General Guidance

Proposals

• We will continue to submit proposals as the federal agencies submission systems are operational.
• Sponsor proposal review timelines may be extended while federal agencies navigate pauses on federal assistance funding in specific areas.
• Sponsor RFPs may also change during this timeframe. Please check the RFP for revisions before submitting your proposal. OSPA will do all we can to review/assess changes.
• There may be changes to proposal deadlines. Reconfirm that the RFP (proposal funding opportunity announcement) has not been revised or postponed. Monitor sponsor portals, grants.gov, and emails for updates.
• To date, three federal agencies have attempted to decrease the negotiated F&A rate for grants: the National Institutes of Health (NIH), the National Science Foundation (NSF), and the U.S. Department of Energy (DOE). You can find specific details for each agency in the agency communications section below. To date, the attempts to lower these rates have been halted through court actions. Guidance: Continue to use the ISU-posted negotiated F&A rates when preparing proposals. (5/2/25)

Awards

• The terms and conditions of your executed award remain enforceable so long as your award is active. If there is a change to your award, OSPA or OIPTT will receive notice or an amendment for review and execution.
• We anticipate updates to award Research Compliance and/or 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. We will share any information we receive with you, though you may also receive instructions directly from your Program Officer. Please forward any notifications you receive to fedfunds2025@iastate.edu.  It is crucial to act swiftly to ensure compliance with any new requirements, as failure to do so could jeopardize funding.
• If specific programs are terminated or restructured, you may encounter difficulties accessing funds or meeting new criteria. Federal agencies managing these programs will typically issue guidance on how to proceed. OSPA or OIPTT will pass this along promptly if/when received.
• Issuance of subawards by OSPA/OIPTT from federal funding sources will be paused until the federal agency has completed their analysis of their federal financial assistance programs.
• If a program or initiative is reduced or defunded, there could be delays or pauses in payments for existing projects under those programs. While this is rare, it may occur if funding for a program is rescinded or redirected.
• Should a stop work order be issued for an existing project, the PI will be notified promptly. If the PI receives a stop work order directly, please forward it to fedfunds2025@iastate.edu for review and coordination.

Awards – What to do

• Review your sponsored project agreement. Ensure you understand the terms, especially clauses related to funding availability and termination.
• Closely monitor obligated and unspent balances to avoid deficits while awaiting future funding. Anticipated future funding remains subject to availability of funds and is not guaranteed.

• Review your grant proposal and contract. If you have any DEI activities in your grant/contract, contact fedfunds2025@iastate.edu for assistance.

• Communicate with the Program Officer. Stay in touch with your Program Officer to confirm there are no changes affecting your award.
• Reports and deliverables: prioritize submission of any technical reports or deliverables that are due or past due.

Agency Communications

Section last updated: June 18, 2025

All agencies that have provided guidance have indicated that grantees shall cease and desist all DEI activities required of their contracts or grants. This work may include but is not limited to a DEI plan requirement, training, reporting, considerations for staffing, or any other direct or indirect contract or grant activity. This requirement does flow down to subrecipients. The memos ask affected PIs to connect with their cognizant program officer, or similarly titled agency representative, immediately.

Until such time as you receive specific guidance from the funding agency, if a project includes DEI components, outreach, or related activities (i.e., your project contains explicitly outlined DEI goals), you must pause these immediately and contact us at fedfunds2025@iastate.edu.  The funding agency will not be able to distribute funds for such work beyond January 20, even if you attempt to invoice against the previously approved grant budget.

Funds previously allocated for DEI activities on your grant must remain unspent and cannot be reallocated to other budget categories. As with all changes to scope of work, such a change will need to be approved by the cognizant Program Officer. Federal agencies are currently not approving fund reallocation, and there is potential for agencies to request the return of these funds to comply with the Executive Order.

Agency communications are being monitored, and will be updated and dated, below.  If you receive any additional communications from an agency that does not appear below, please contact dank@iastate.edu.

OMB/White House

• President Releases FY2026 Discretionary Budget Request (5/2/25)
• President Trump’s letter to Michael Kratsios, Director of the White House Office of Science and Technology Policy (3/26/25)
• OMB/OPM memorandum (PDF): Guidance on Agency RIF and Reorganization Plans Requested by Implementing the President’s “Department of Government Efficiency” Workforce Optimization Initiative. (2/27/25)
• Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative (2/26/25)
• OMB Memo M-25-14 Recission of M-25-13 (1/29/25)  This memorandum rescinds the original M-25-13, below.
• Memo M-25-13 Memorandum For Heads of Executive Departments and Agencies: Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs.  This memorandum calls for a temporary pause on “all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders” and also directs Federal agencies “to pause all activities associated with open NOFOs, such as conducting merit review panels.” (1/27/25)

Department of Defense (DOD)

• U.S. District Court Judge issues nationwide TRO in AAU-ACE-APLU case contesting cuts to Defense research (6/18/25)
• Department of Defense issues memo announcing 15% cap on indirect cost rates. (6/17/25)
• APLU, AAU, and ACE file joint lawsuit seeking to halt proposed indirect cost rate cap. (6/17/25)
• Department of Defense Press Release:  Department of Defense Statement Clarifying Defense Contracting (1/28/25)

Department of Education

• Department of Education Press Release:  U.S. Department of Education Takes Action to Eliminate DEI (1/23/25)

Department of Energy (DOE)

• Nationwide Preliminary Injunction Granted in DOE F&A Rate Cap Lawsuit (5/16/25)
• DOE Announces Standard 15% Indirect Cost Rate (4/11/25)
  • APLU, AAU, & ACE Legal Challenge Cuts to Critical Energy Research (4/14/25) Temporary Restraining Order Granted (4/16/25)
• Executive Order Update to PIER Plan Requirement (1/27/25)
• DOE Recission of DEI, CBP, and Justice40 Policy Flashes, Acquisition Letters, and Financial Assistance Letters
• Memorandum for Heads of Departmental Elements: Agency-wide Review of Program and Administrative Activities (dated 1/20/25)

Health and Human Services/National Institutes of Health

• NIH Director, Jay Bhattacharya, recently announced the 2024 NIH Public Access Policy (Notice Number: NOT-OD-25-047) will be pushed up from its original December 31, 2025 implementation date to July 31, 2025. (5/12/25)
• NIH updated policy on foreign subawards (5/12/25)
• Updated NIH Processes for No-Cost Extensions (5/7/25)
• On March 5, 2025, Judge Angel Kelley of the United States District Court for the District of Massachusetts issued a preliminary injunction halting the implementation, application, or enforcement of the National Institutes of Health’s February 7 supplemental guidance imposing a cap of 15% on facilities and administration (F&A) costs reimbursement to universities who receive NIH research grants. The injunction applies to all institutions nationwide. This preliminary injunction replaces the temporary restraining order that had been in place since February 11, which also halted the implementation of the supplemental guidance. (3/6/25)
• NIH Policy Change: Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (2/10/25)
  Contact your grant support specialists with questions about F&A/indirect cost rates regarding your specific projects.
  
• HHS/NIH Immediate Pause on Issuing Documents and Public Communications (1/21/25)

National Aeronautics and Space Administration (NASA)

• Memorandum for NASA Contractor and Grantee Community: Initial Guidance Regarding Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders (1/23/25)
• Amendment 109: Removing DEIA Requirements from ROSES-2024 – NASA Science

National Institute of Justice (NIJ)

• As of 1/29/25, NIJ has cancelled all previously posted Notices of Funding Opportunity and associated webinars.  Please check the NIJ Current Funding Opportunities webpage for any updates.

National Science Foundation (NSF)

• NSF is temporarily pausing implementation of the 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 Massachusetts. New NSF awards 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 upon a court decision permitting application of the policy. (5/21/25)
• NSF recently published updates to the Broader Impacts section of grants for PIs. Please refer to this page for guidance in addressing Broader Impacts in NSF research proposals. (5/12/25)
• APLU, AAU, ACE and 13 Research Universities File Joint Lawsuit Contesting NSF Indirect Cost Rate (5/6/25)
• NSF announces Standard 15% Indirect Cost Rate (5/2/25)
• NSF Announces Termination of Awards Not Aligned with Current Agency Priorities (Statement and FAQ) (4/18/25)
• Message from Dr. Sethuraman Panchanathan, Director, U.S. National Science Foundation (PDF)  (3/11/25)
• NSF Implementation of Recent Executive Orders: FAQ  (2/13/25)
• On Friday, January 31, 2025, a Federal Court issued a Temporary Restraining Order (TRO) directing Federal grant-making agencies, including the National Science Foundation (NSF), to “…not pause, freeze, impede, block, cancel, or terminate… awards and obligations to provide federal financial assistance to the States, and… not impede the States’ access to such awards and obligations, except on the basis of the applicable authorizing statutes, regulations, and terms.” Although the language of the TRO is directed at State institutions, the Department of Justice has determined that it applies to all NSF award recipients. You can review the TRO here (PDF). To comply with the TRO, the NSF Award Cash Management Service (ACM$) system is available for awardees to request payments as of 12:00pm EST, February 2, 2025. (2/3/25)
• Please check the NSF Executive Order Implementation page regularly as the agency adds frequently asked questions based on community feedback. (2/3/25)
• NSF Implementation of Recent Executive Orders | NSF – National Science Foundation (1/28/25)
• UCAR, NSF NCAR Close DEI Offices Update (1/24/25)

United States Agency for International Development (USAID)

• Notice on Implementation of Executive Order: Reevaluating and Realigning United States Foreign Aid (1/24/25)

United States Department of Agriculture (USDA)

• No official USDA communications as of 1/29/25.
• All NIFA Requests for Applications are currently under review and have been removed from the upcoming deadlines calendar. Packages have also been removed from grants.gov.

Please note that this is not a comprehensive list of notifications.  Project-specific notifications may be sent directly to Principal Investigators.