Page last updated: January 7, 2026
Guidance for Federally Funded Research Activities
The Office of the Vice President for Research established this page to provide the Iowa State Research community with timely updates and guidance on executive priorities and their impact on federally funded research.
Here, you will find:
- The most current federal agency communications;
- Guidance from the OVPR team; and
- Information from key external resources including the Council on Government Relations (COGR), the Association of Public and Land-Grant Universities (APLU), and the American Council on Education (ACE).
If you are a principal investigator (PI) needing tailored guidance on a specific matter – such as a project termination, stop-work order, or agency request for details about your budget – please email fedfunds2025@iastate.edu. Please include the following information in your message: your name; sponsoring agency; project number; and situation in question.
FY26 Project Stop-Gap Support
As resources permit in FY26, the University may provide stop-gap funding in support of a research project that is terminated, except for cause of non-performance. Priority will be given to support students and staff, as well as associated limited supplies.
Agency Communications
Agencies have provided periodic updates on changing federal priorities and research funding since late January 2025. The communications Iowa State has received are sorted below by agency. The OVPR will add to this collection as new updates are received. If you have received an agency communication that you believe is relevant to the broader campus research community, that is not included here, please email it to dank@iastate.edu.
- 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)
- Federal judge blocks Department of Defense’s attempt to cap indirect research cost reimbursements. (10/14/25)
- U.S. Judge Brian E. Murphy of the District Court for Massachusetts granted a preliminary injunction in the lawsuit challenging DOD’s F&A policy. The injunctive relief is granted to all plaintiffs and their members. (7/22/25)
- 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 Press Release: U.S. Department of Education Takes Action to Eliminate DEI (1/23/25)
- 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)
- On January 5, 2026, the 1st U.S. Circuit Court of Appeals issued a decision affirming the order by the district court permanently blocking the implementation, application, or enforcement of the National Institutes of Health’s (NIH) February 7, 2025, supplemental guidance imposing a 15% cap on F&A reimbursements for institutions of higher education that receive NIH research grants. The decision found the NIH guidance to be unlawful, violating both the Department of Health and Human Services’ regulations and an appropriations rider enacted by Congress in 2018 and reenacted in every subsequent appropriations cycle. Importantly, citing recent Supreme Court decisions, the 1st Circuit held that jurisdiction over the challenge to the NIH supplemental guidance was proper in the district court. (1/7/26)
- NIH Director Releases Statement Outlining Agency Priorities Moving Forward (8/15/25)
- 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)
- 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.
- 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)
- 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.
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.
Key Resources
- Council on Government Relations (COGR)
- COGR 2025 Administration Transition Information and Resources
- COGR Summary of Executive Orders
- COGR: Costing Points to Consider for Terminations and Suspensions (PDF)
- COGR: Points to Consider for Reimbursement of Expenses Under Active Grants (PDF)
- Association of Public and Land-Grant Universities
Contact Us for Support
The OVPR has established a team to help you navigate the challenges of today’s evolving federal funding landscape. Please contact us if you’ve received a stop work order, a project pause, or a concerning or confusing communication from the program officer of your sponsoring agency. We’re here to help you find a solution to whatever funding situation arises.