Federal funding updates
This webpage serves as the centralized location for updates regarding federal research funding. Updates and resources for all other federal actions can be found here.
Page last updated: May 20, 2025, 12:20 p.m.
Updates
On May 16, 2025, the NSF delayed Implementation of Standard 15% Indirect Cost Rate until 6/13/2025. The original NSF policy notice to implement a standard 15% indirect cost rate (released 5/2/2025) stated, “The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.” This delay in implementation is in response to a deferment request until after 5/23 hearing.
On May 14, 2025, the Department of Defense issued a statement outlining the pursuit of implementing a 15% Indirect Cost Cap on Assistance Awards to Institutions of Higher Education. The policy states the DoD “will pursue a lower cap on indirect cost rates for all new financial assistance awards to institutions of higher education, consistent with federal regulation.” This F&A rate will apply to new financial assistance awards, in accordance with the policy guidance that is forthcoming from the DOD (expected June 4, 2025). In addition, DOD Components are directed to renegotiate existing awards to incorporate the 15% rate within 6 months.
As with other instances of policy changes during the past several months, we are examining this potential impact on the VCU research enterprise.
Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. If PIs received a request from DoD to renegotiate the F&A rate on an existing award, you should reach out to your sponsored program team in the OVPRI (find your team here) for guidance. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement.
As we learn more about this new DOD F&A rate and other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.
Thank you,
Tina Cunningham, J.D.
Associate vice president for research administration
The following message was sent to VCU/VCU Health research faculty and staff:
Dear colleagues,
Earlier today, the NIH issued an Updated NIH Processes for No-Cost Extensions. The notice states that the agency has temporarily disabled the No-Cost Extension functionality in eRA Commons. NIH staff have been directed to “review all existing grants and cooperative agreements to ensure that NIH awards do not fund off-mission activities or projects.” Disabling the NCE functionality allows for a more in-depth review of each extension request.
NCE’s must now be submitted as a prior approval request in eRA Commons.
Researchers will need to create an administrative action (AA) in the RAMS-SPOT award record for all NCE requests. Please review our Admin Action Get Started Guide for what should be included in a prior approval NCE.
Researchers who are planning on submitting an NCE for their NIH award are advised to do so well in advance of their anniversary date.
Please direct any questions to the sponsored program team in the OVPRI (find your team here).
You can find more information about federal research issues here. Information about other federal issues can be found here.
Thank you,
Tina Cunningham, J.D.
Associate vice president for research administration
The NIH has released an Updated NIH Policy on Foreign Subawards. The updated policy states, in part, that the NIH "will not issue awards to domestic or foreign entities that include a subaward to a foreign entity.” This applies to new, renewal and non-competing continuation awards, effective immediately. VCU investigators with affected awards should discuss options like renegotiation or deferral with their program officers as upcoming NOAs are expected to reflect defunding of foreign subawards.
The following message was sent to VCU/VCU Health research faculty and staff:
Dear colleagues,
Over the past few weeks, the federal government and its research-funding agencies have issued several new and updated directives. While we continue to provide timely updates on our federal funding page, I would like to share more in-depth information for several of them.
NSF 15% F&A rate limit implementation
On Friday, May 2, the NSF announced the Implementation of Standard 15% Indirect Cost Rate policy. The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.”
The implementation of this policy is effective for all new grants beginning today, May 5, 2025. Current grants are not impacted by this new policy.
Principal investigators do not need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement. Should you receive direct communication from the NSF regarding updating award budgets, please immediately forward them to your sponsored program team in the OVPRI (find your team here).
The federal government’s long standing recognition and payment of F&A costs has helped U.S. colleges and universities like VCU build, support and maintain the required research infrastructure that has made the American research enterprise the best in the world. At a national level, 10 organizations (including the APLU, COGR and AAMC) are convening a Joint Associations Group on Indirect Costs taskforce to examine the F&A system. VCU will remain engaged in this process - both at the federal and state level.
NIH Notice of Civil Rights Term and Condition of Award
On April 22, the NIH issued a Notice of Civil Rights Term and Condition of Award. The notice requires that institutions certify that they:
- do not, and will not…operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of federal anti-discrimination laws; and
- do not engage in and will not…engage in, a discriminatory prohibited boycott.
These terms and conditions are accepted when we draw down funds from the federal financial system. The university is currently reviewing its policies to ensure that we are in compliance with all federal and statewide DEI guidelines and policies. Thus, until this due diligence is completed, the university is implementing a temporary hold on the drawing down of funds on new, renewal, supplement and continuation awards from NIH/DHHS.
Although we are unable to immediately be reimbursed for these research activities, it is crucial that faculty are able to continue to conduct their important and impactful research. For current awards, faculty can continue to charge expenses to their existing award indexes. For new awards, full award setup will not be completed until the university can certify this notice requirement. However, faculty can begin work on their new awards by submitting an Advanced Index Request Form to establish their new index. Contact your school or unit research administrator with any questions regarding this process.
Resolving this is a high priority for the university and we will inform you as soon as this is finalized. It is our hope that this process will be expedient and resolved in a timely manner.
While these past four months have been filled with uncertainty and concern, it is important that we do not let it stop us from conducting the groundbreaking research that has made VCU a national research powerhouse. My team in the OVPRI and research administrators across the university have been working as hard as possible to ensure that researchers have every level of support we can provide.
As we continue through these challenging times, please do not hesitate to reach out should there be anything we can help with. Researchers who are immediately impacted by either of these temporary holds can reach out to rescomply@vcu.edu for additional information and support.
Thank you for your continued dedication to VCU's research mission,
P. Srirama Rao, Ph.D.
Vice president for research and innovation
The university is closely monitoring the implementation of the new policy announced by the U.S. National Science Foundation: Implementation of Standard 15% Indirect Cost Rate. The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.”
This F&A rate maximum applies only to new awards beginning on May 5, 2025 and does not apply retroactively to existing awards.
As with other instances of policy changes during the past several months, we are examining this potential impact on the VCU research enterprise.
Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement.
As we learn more about this new NSF F&A rate and other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.
The OVPRI is aware of yesterday’s notice (NOT-OD-25-090) from the NIH, which, in part, requires recipients of NIH funds to certify that they:
- do not, and will not…operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws; and
- do not engage in and will not…engage in, a discriminatory prohibited boycott.
As are research universities around the country, VCU is examining any immediate implications of this notice.
Currently, there are no changes to the operations of existing grants and funding - please continue to work and charge expenses to your projects in a prudent manner and according to sponsor-approved budgets.
As soon as possible, we will provide additional guidance.
On April 18, 2025, the National Science Foundation published an updated guidance on its priorities, including a statement from Director Panchanathan and a frequently asked questions section. If you receive a stop work or termination notification concerning existing grants or general information about an operational change from the NSF, please immediately forward them to your sponsored program team in the OVPRI (find your team here).
As soon as possible, we will provide additional guidance. In the meantime, should there be any material changes, you will receive additional communication.
On April 16, 2025, a judge for the District Court of Massachusetts issued a nationwide temporary restraining order blocking the implementation of the proposed 15% cap on Department of Energy indirect research funds. This nationwide temporary restraining order is significant but is not permanent. The OVPRI will continue to monitor any future filings for this case.
The following message was sent to VCU/VCU Health faculty and staff:
Dear colleagues,
We are continuing to monitor the impact that federal changes are having on the research enterprise, and more importantly, our faculty, staff and students.
Every grant we earn is a direct result of the years of tireless efforts of our investigators, co-investigators, and the subsequent study teams and administrative support required to ensure that discovery and innovation can be incubated at VCU. Each grant plays a pivotal role in driving the VCU research enterprise to new heights.
In short, we are a top 50 public research university because of the groundbreaking work conducted by each of you every single day.
What’s next
At the direction of President Rao, the university is implementing a formal appeals process to support our faculty in examining when a federal appeal may be possible. More information regarding the appeals process can be found here.
University leadership is also diligently exploring options to support faculty, staff and students who are most impacted by terminated grants. We will provide additional updates as soon as they are available.
You can find more information about federal research issues here. Information about other federal issues can be found here.
We are committed to finding ways to continue to support the researchers and teams who are conducting impactful research across the enterprise.
Thank you for your continued dedication, professionalism and innovative spirit.
Sincerely,
Fotis Sotiropoulos, Ph.D.
Provost and senior vice president for academic affairs
Marlon F. Levy, M.D.
Senior vice president for VCU Health Sciences and CEO of VCU Health System
Meredith Weiss, Ph.D.
Senior vice president for finance and administration and CFO
Srirama Rao, Ph.D.
Vice president for research and innovation
The OVPRI is closely monitoring the implementation of the new policy announced on Friday: Department of Energy Overhauls Policy for College and University Research, Saving $405 Million Annually for American Taxpayers. The policy statement shares, in part, that “it will limit financial support of ‘indirect costs’ of DOE research funding to 15%.”
As with other instances of policy changes during the past several months, we are examining this potential impact on the VCU research enterprise.
Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement.
As we learn more about this new Department of Energy F&A rate and other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.
Information about other federal issues can be found here.
On March 5, 2025, a federal judge issued a nationwide preliminary injunction blocking the implementation of the proposed 15% cap on NIH indirect research funds. This nationwide preliminary injunction is significant but is not permanent. The OVPRI will continue to monitor any future filings for this case.
The following message was sent to VCU research faculty and staff:
Dear colleagues,
As many of you will have read last week, in response to the Feb. 14 “Dear Colleague” letter from the U.S. Department of Education’s Office for Civil Rights, the university will undertake a review of the Research strategic plan in light of new federal guidance. We will continue to provide updates as this process continues.
From a federal research funding perspective, we have seen several NIH study sections now posted on the Federal Register. While this is welcome news, it does not yet account for the currently cancelled or postponed sections, or provide any clarity on council meetings which provide the final approval for funded grant proposals.
As we await additional updates to court cases and executive orders, please continue to check the federal research updates website for the most current advice and recommendations. At this time, no other institutional changes are being implemented and I request you to continue to continue to submit your grants as planned and consult with your unit level leadership to discuss your individual research studies and plans.
Finally, as we approach next month’s Research Weeks, I encourage you to join us in celebrating your colleagues and the groundbreaking research that we continue to conduct here at VCU. I hope you will consider joining me for the State of the Research on April 15 and I am looking forward to seeing many of you at department, school and college events throughout the month.
While the current federal research landscape is challenging and uncertain, we must remember to take time to celebrate the progress that we have already made and remind ourselves that the research that we do at VCU not only advances the frontiers of science, discovery and innovation, but also impacts the communities and the patients we serve, as well as leads to significant economic development in the region and the commonwealth. This is not the time to slow down - the research you do matters. I look forward to learning about your continued research impact in the weeks and months to come.
Thank you for all that you do and with my best wishes,
Sriram
The OVPRI continues to monitor the impacts to federal funding during the current administrative transition period. As of today, there are no changes to university research operations.
- NIH indirect cost cap
- On Feb. 21, 2025, a federal judge extended the temporary restraining order blocking the implementation of the proposed 15% cap on NIH indirect research funds. 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 what the duration of the extension is, Judge Kelley has indicated that she hopes to make a ruling "quickly."
- Detailed information on this case can be found here.
- Pause on updates to the Federal Register
- Nature has reported that NIH grant reviews continue to be delayed, causing both a backlog of applications and the awarding of new grants to be stalled.
- Executive order: “Implementing the President’s ‘Department of Government Efficiency’ cost efficiency initiative”
- On February 26, 2025, President Trump signed an executive order directing agencies to review existing contracts and grants within 30 days. The guidance prioritizes the review of grants and contracts to educational institutions. Additionally, the EO instructs agencies to develop technological systems and guidance to record contract and grant payments as well as written justifications for those payments. Any impact of this executive order is not immediately clear or actionable for VCU.
On Wednesday, Feb. 12, university leaders hosted a virtual meeting regarding federal research. This update session included remarks from:
- Michael Rao, Ph.D., VCU president
- Fotis Sotiropoulos, Ph.D., provost and senior vice president for academic affairs
- Matthew Conrad, J.D., vice president for government and external relations
- P. Srirama Rao, Ph.D., vice president for research and innovation
- Arturo P. Saavedra, M.D., Ph.D., dean of the VCU School of Medicine
- Marlon F. Levy, M.D., senior vice president for VCU Health Sciences and CEO of VCU Health System
- Meredith Weiss, Ph.D., senior vice president for finance and administration and CFO
During the session, university leaders reemphasized their commitment to the VCU research enterprise. This included the following updates:
- VCU is involved in bipartisan conversations at the state and federal level about how White House executive orders, federal agency directives and court decisions may impact VCU.
- VCU has more than 850 active federal grants for this fiscal year. As of Feb. 14, the university has received stop-work or termination guidance for very few of them.
- If a proposed 15-percent cap on indirect costs were to go into effect for current and future NIH grants, the financial impact to VCU would be approximately $26 million.
- Researchers should continue to work on existing grants and submit proposals for new ones.
Participants were able to submit questions during the session. Below are answers to questions that can be answered at this time:
How is VCU working with legislators, government officials and other stakeholders on these matters?
VCU is working closely with our partner institutions both in Virginia and across the country. We are also engaging with our national associations to share the impacts of these proposed directives. Additionally, our government relations team is engaging in bipartisan conversations at all levels of government.
What would be the impact of the proposed federal cap on indirect costs?
Indirect (F&A) costs are expenses incurred by the institution in support of sponsored projects. Currently, VCU’s indirect cost rate is 55.25 percent. If a proposed 15-percent cap on indirect costs were to go into effect for current and future NIH grants, the financial impact to VCU would be approximately $26 million. While VCU is committed to monitoring potential changes, speculation and chasing down hypothetical outcomes will not help us serve our students or communities.
If we are aware of any impacts to research operations or patient care directly in relation to any White House executive orders, federal agency directives and court decisions, what should we do?
Please share any impacts with your research representatives.
How can we stay up-to-date with what is happening at the federal level?
The OVPRI will continue to update its federal updates webpage with material impacts to the VCU research enterprise. For a full listing of executive orders, agency directives and court decisions, the Council on Government Relations is maintaining a 2025 Administration Transition Information & Resources webpage.
What is the current status of VCU’s grants and what should researchers do with their planned proposal submissions?
As of Feb. 14, 2025, very few of VCU’s 850+ federal grants have been impacted by the executive orders and agency directives. We have also been able to process “drawdowns” from all federal agencies as scheduled.
Unless explicitly directed otherwise by a funding agency, researchers should continue to conduct their research as planned, including submitting proposals by their posted deadlines and charging their accounts in a prudent manner.
What can I do to help?
VCU’s researchers conduct important, life-saving research every day. The most important thing is that we continue to conduct research and inform university administrators of any stop-work orders or other communications from federal agencies requesting that they stop their research.
What should I do if I receive outreach from members of the media?
VCU Enterprise Marketing and Communications, Public Relations leads campus-wide VCU media relations and is also available to support inquiries from the media and to lead public information efforts for VCU and VCU Health. Should you receive any outreach from members of the media, please contact Michael Porter, Associate Vice President for Public Relations, at mrporter@vcu.edu.
- On, Feb. 7, 2025, the National Institutes of Health released Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (NOT-OD-25-068), implementing a new cap on facilities and administrative (F&A) rate of 15%. Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our negotiated rate agreement.
- On February 10, 2025 a number of temporary restraining orders regarding NIH NOT-OD-25-068 were issued. Thus, VCU will not be immediately affected by this change. We will continue to monitor this situation and provide updates as we have them.
- We also draw your attention to FAQ #12 on the NSF website (https://www.nsf.gov/executive-orders). We reiterate that researchers should continue to conduct research and to charge expenses to projects in a prudent manner and according to sponsor-approved budgets.
We are continuing to closely follow the implementation of the recent federal executive orders and agency guidances pertaining to research in higher education, including yesterday's Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (NOT-OD-25-068).
The policy statement shares, in part, that:
- There will be a standard indirect rate of 15% across all NIH grants for indirect costs in lieu of a separately negotiated rate for indirect costs in every grant.
- This applies to all current grants for go forward expenses from February 10, 2025 forward, as well as for all new grants issued.
As with the other instances over the past several weeks, we are examining this guidance and its potential impact on the research enterprise.
As we learn more about the NIH F&A rates or other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.
Earlier this afternoon, the Office of Management and Budget’s memo (M-25-13), that called for a blanket temporary pause of federal agency grants, was rescinded. This does not rescind any other memo or executive order, so agencies will still be reviewing existing grants for compliance with other EOs.
Additionally, any previously announced agency communication pauses are still in place.
As has been the case for the past week, please continue to conduct your research and to charge expenses to your projects in a prudent manner and according to sponsor-approved budgets. Additionally, do not postpone your plans to submit your grant proposals on time; continue to submit them as planned and by the posted due dates.
We will continue to utilize and update the federal funding updates website as additional information becomes available.
The OVPRI is aware of yesterday’s memo from the Office of Management and Budget (M-25-13), which will impact federal agencies today, Jan. 28, at 5 p.m. As are research universities around the country, VCU is examining the implications of this pause.
Currently, there are no changes to the operations of existing grants and funding - please continue to work and charge expenses to your projects in a prudent manner and according to sponsor-approved budgets. Additionally, do not postpone your plans to submit your grant proposals on time; continue to submit them as planned and by the posted due dates. All federal grant submission systems are currently operational and are expected to remain that way.
If you receive a stop work or termination notification concerning existing grants or general information about an operational change from a federal agency, please immediately forward them to your sponsored program team in the OVPRI (find your team here). As soon as possible, we will provide additional guidance. In the meantime, should there be any material changes, you will receive additional communication. Additional updates and resources will continue to be posted on our federal funding updates webpage.
It is anticipated that the pause at federal agencies is temporary with additional guidance expected by Feb. 1. However, it is important that we are able to continue to gather the most important and up-to-date information as possible.
With that in mind, please consider the following two points:
- Unless you are otherwise notified by federal agencies or the OVPRI, do not postpone your plans to submit your grant proposals on time - i.e., continue to submit them as planned and by the posted due dates. All federal systems are currently operational and are expected to remain that way.
- If you receive any stop work order or termination notifications concerning existing grants or general information about a change in operational status from a federal agency, please immediately forward them to your sponsored program team in the OVPRI (find your team here). This will allow us to better understand any individual situations and/or the current operations of each federal agency.
We are staying in close and frequent touch with our senior research officers and federal government relations representatives both with Virginia’s research universities and across the country, and with associations such as the Association of Public and Land-grant Universities, in order to track changes as they develop.
Should there be any material changes, you will receive additional communication from the OVPRI. Additional updates and resources will continue to be posted on our federal funding updates webpage.
VCU is a nationally prominent public research university with a significant number of federally funded projects. Yesterday, several federal research agencies announced that all or partial operations are under review by the new administration. While reviews are consistent with a change in administration, we are closely monitoring the evolving situation around federal research projects to understand what impact these changes may have on our researchers, students and the communities we serve. The university will continue to adhere to the laws, policies and processes outlined by federal agencies.
Along with other research universities around the country, VCU is also seeking clarity about what comes next. We will communicate new information when we have it and update the OVPRI website with the latest information when available.
In the meantime, should you have any questions or require any assistance in speaking with or responding to communications from program officers, please do not hesitate to contact your representatives within the OVPRI.
Thank you for all that you do to make VCU a special place.
Proposals
What to do:
- Unless you are otherwise notified by federal agencies or the OVPRI, do not postpone your plans to submit your grant proposals on time - i.e., continue to submit them as planned and by the posted due dates. All federal systems are currently operational and are expected to remain that way.
- Reconfirm that the funding announcement has not been revised or postponed. If available, consider signing up for alerts from the federal agency or sponsor.
- As of May 1, 2025, the NIH will no longer issue awards to domestic or foreign entities that include a subaward to a foreign entity (Updated NIH Policy on Foreign Subawards). This applies to new, renewal or non-competing continuation awards. VCU cannot submit any NIH proposal that includes a subaward to a foreign entity. (Updated May 6, 2025)
Awards
What to do:
- Maintain a close eye on communication from your sponsoring agency.
- Stay in touch with your program officer from your sponsoring agency, as necessary.
- Continue to submit reports and other prior approval requests on schedule.
- The Division of Sponsored Programs (DSP) and Office of the Vice President for Research and Innovation (OVPRI) have issued new guidance on the appeal process for award terminations. This guidance outlines the process for how Principal Investigators (PI) may appeal termination decisions when that option is offered by the federal agency. To learn more or submit an appeal, click here.
- While the university works towards the ability to certify the DHHS’ Notice of Civil Rights Term and Condition of Award, faculty who have received a new NIH/DHHS award will need to submit an Advanced Index Request Form to establish their new index as DSP/G&C will not complete the full award setup until VCU is able to certify. Contact your school or unit research administrator with any questions regarding this process. (Updated May 5, 2025)
- As of May 1, 2025, the NIH will no longer issue awards to domestic or foreign entities that include a subaward to a foreign entity (Updated NIH Policy on Foreign Subawards). This applies to new, renewal or non-competing continuation awards. VCU investigators with affected awards should discuss options like renegotiation or deferral with their program officers as upcoming NOAs are expected to reflect defunding of foreign subawards. (Updated May 6, 2025)
- NIH no cost extensions must now be submitted as a prior approval request in eRA Commons, in accordance with Updated NIH Processes for No-Cost Extensions. Researchers will need to create an administrative action (AA) in the RAMS-SPOT award record for all NCE requests. Please review our Admin Action Get Started Guide for what should be included in a prior approval NCE. Researchers who are planning on submitting an NCE for their NIH award are advised to do so well in advance of their anniversary date. (Updated May 7, 2025)
Resources
COGR is the national authority on federal policies and regulations affecting U.S. research institutions. The organization's mission is to empower an unparalleled U.S. academic research ecosystem by advancing sound federal policies and regulations that are vital to U.S. science and innovation leadership and our nation’s health, security, and prosperity.
COGR has compiled an extensive listing of resources relating to the current administration transition.
The APLU has created several resources to help provide additional information regarding current White House executive orders, federal agency guidances and facilities and administrative costs: