Office of the Vice President forResearch and Innovation

Following the VCU research enterprise town hall and listening session in mid June and in concert with reviews and discussions with university leadership across the commonwealth and the country, the OVPRI has submitted the following VCU institutional response to the OMB as part of the public comment process.

July 13, 2026

Docket ID: OMB-2026-0034-0001

Agency: Office of Management and Budget (OMB)

Subject: Public Comment on Proposed Guidance/Rules Regarding Federal Research Management and Awards

To Whom It May Concern,

Thank you for the opportunity to submit public comments regarding the proposed revisions and guidance outlined in Docket OMB-2026-0034-0001. We appreciate the Office of Management and Budget’s (OMB) engagement with the scientific and academic communities to refine the framework governing federal research awards.

Virginia Commonwealth University (VCU) is a premier public, urban doctoral university located in Richmond, Virginia. Classified as an R1 Doctoral University with "Very High Research Activity" by the Carnegie Classification of Institutions of Higher Education—a distinction held by fewer than 5% of universities nationwide—VCU serves as a vital anchor institution for the Commonwealth of Virginia and a major engine for national scientific innovation. 

As a top-50 public research institution ranked by the National Science Foundation (NSF), VCU's research enterprise manages a robust portfolio supported by more than $500 million in research expenditures and sponsored funding, with more than $200 million coming from federal sources. Enrolling nearly 30,000 students across more than 200 academic programs—including a comprehensive academic medical center and health sciences campus—VCU is deeply committed to translating federal investment into transformative innovation, public health advancements, and economic development. 

Accordingly, VCU has a significant institutional stake in the clarity, stability, and administrative burden of government-wide federal financial assistance policies.

We share the foundational goals of OMB and the federal funding agencies: to maximize the returns on public investment by supporting high-impact, transformative science that directly advances the health, security, and overall betterment of the United States. To ensure these shared objectives are met effectively without creating unintended disruption to the research ecosystem, we offer the following constructive feedback on specific elements of the proposal.

[200.202, 200.205] Support for a Robust, Merit-Based Scientific Evaluation Process

We strongly support a merit review process that remains rooted in robust scientific evaluation. Ensuring that funding decisions are driven by rigorous peer review and scientific merit allows the highest-quality research to be prioritized. This standard is essential for maintaining the global leadership of U.S. science and ensuring public funds are directed toward the most promising and impactful discoveries. Final decisions on grant awards should be made by qualified individuals with relevant disciplinary expertise.

Additionally, we are concerned by the inclusion of terms that do not have clear and transparent definitions, such as “compromise public safety.” This language would introduce variation in agency review and reduce transparency and consistency across agencies.

[200.340] Stability, Predictability, and Harmonization with FAR Standards

Scientific research and its subsequent discovery is an inherently long-term endeavor that requires financial predictability to function. We strongly urge OMB to harmonize any grant termination framework with the established principles of the Federal Acquisition Regulation (FAR). 

Scientific research requires long-term institutional planning and financial predictability. Expanding termination mechanisms for ongoing grants and contracts introduces volatility that makes it difficult for institutions to commit to multi-year obligations. We are concerned that expanded termination authority will inherently destabilize the research enterprise.  

Most critically, this unpredictability will shrink the future scientific workforce. With less certainty regarding funding for trainees—such as undergraduate, graduate students and postdoctoral fellows— institutions may be unable to sustain current levels of support for them. 

This will ultimately weaken the pipeline of future U.S. scientific talent and the critically needed workforce to maintain global scientific leadership. Additionally, this could also create challenges for recruiting and retaining top talent.  The risk of a mid-project termination will severely damage the ability of U.S. institutions to compete globally for premier scientific minds. 

Top researchers seek environments that offer funding predictability to execute complex, multi-year projects. If federal grant awards can be dissolved due to shifting priorities mid-project, the risk profile of accepting a federally funded position becomes untenable. Highly qualified scientists will increasingly favor international research institutions that offer greater structural and financial stability. 

Additionally, the proposed expansion of agency termination authority—particularly the ability to terminate awards if they no longer align with "agency priorities"—will introduce significant instability into the research enterprise.

FAR termination for convenience includes well-defined mechanisms for notice, winding down operations, and equitable settlement of incurred costs. Aligning grant management with these established FAR standards would provide researchers with the predictability necessary to sustain project staffing and institutional planning. Without such protections, the resulting volatility will discourage participation in federal research and force institutions to support fewer trainees, directly harming the pipeline of the future U.S. scientific workforce.

[200.220] Leveraging Existing Research Security Frameworks

We agree that research security is of utmost importance and we appreciate the extensive work that federal agencies have already undertaken to ensure that malign foreign talent and countries of concern cannot access the critical innovations and intellectual property produced in the United States. We are concerned that the proposals in this section would create unnecessary hurdles for the open exchange of information that has long fueled American scientific breakthroughs. 

Complex scientific and technical challenges, ranging from public health monitoring and epidemiological modeling to deep space exploration, are inherently global in scale. They require access to geographic data, physical environments, and specialized datasets that exist outside the borders of the United States. 

International collaborations allow U.S. institutions to leverage global infrastructure and specialized expertise, maximizing the return on federal taxpayer investments by sharing the immense capital costs of large-scale scientific discovery. A broad prohibition on foreign collaborations risks isolating U.S. researchers from critical global networks, potentially slowing advancements that directly benefit American health, security, and economic competitiveness. 

It is critical to recognize that a robust legal and regulatory framework, specifically the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), is already in place to govern and protect research where national or economic security is at stake.  In addition, grantees are already subject to extensive research security requirements as a result of the National Security Presidential Memorandum-33, the CHIPS and Science Act, and the agency implementations of these requirements.

These existing regulations effectively manage security risks while simultaneously allowing U.S. universities to thrive as leaders and centers of global innovation. Rather than layering on new, potentially incongruent requirements, we encourage OMB to utilize the existing national security frameworks. This will allow the government to apply a targeted, risk-based approach to specific projects or data types, protecting U.S. interests without systematically stifling the collaborative environment that is vital to high-impact science.

[200.112] Redundancy in Conflict-of-Interest Disclosures 

With regard to the new disclosure requirements under section 200.112 pertaining to former federal employees, we note that the federal government already maintains a comprehensive statutory framework to address post-employment conflicts of interest under 18 U.S.C. § 207.

Introducing additional, overlapping disclosure requirements creates administrative redundancy that serves only to increase the burden on research institutions and former public servants without providing meaningful improvements to transparency or security. 

We ask OMB to rely on the existing, well-understood statutory framework of 18 U.S.C. § 207 to ensure federal policy remains streamlined and focused on objective oversight.

Conclusion

We reiterate our gratitude to OMB for its leadership and for considering the perspectives of the scientific community.  Incorporating our recommendations will strengthen the final guidance, ensuring it effectively protects federal investments while fostering a stable, collaborative, and cutting-edge research environment in the United States.

Sincerely,

P. Srirama Rao
Vice President for Research and Innovation

The following message was sent to VCU/VCU Health research faculty and staff:

Dear members of the VCU research community,

You may be aware that, at the federal level, the Office of Management and Budget recently announced updates to the federal Uniform Grants Regulation. We recognize that these proposed changes could significantly impact how federal awards will be managed and administered across higher education.

Please be assured that our leadership team is partnering with professional organizations, including the Association of Public and Land Grant Universities (APLU), Council on Government Relations, Association of American Medical Colleges, and others, to assess the impact that these changes would have on our research enterprise. APLU has summarized some major issues that could impact member institutions. As we navigate this transition, understanding your perspectives, questions and concerns is crucial in shaping VCU’s next steps.

We invite our research community to share your feedback on this proposal. There are two ways to provide your insights:

1. OVPRI will host a virtual town hall/listening session on June 18 at 12 p.m. Register here to participate.
2. Complete this feedback form by no later than June 23.

VCU strongly supports academic freedom and your right to voice your opinions as a private citizen and expert in your field. At the same time, we must remind all employees to remain compliant with university policy. Under VCU’s "Communicating with Governmental Officials" administrative policy, specific rules apply to how we engage with federal and state officials:

• Personal Capacity Communications: If you choose to submit personal opinions or comments on these regulations, you may do so freely on your own time and using your own personal resources. However, you must ensure your personal opinions are not represented as VCU positions, and you cannot use VCU letterhead, VCU phone lines, or your official vcu.edu email account to submit them.
• Official VCU Positions & Comments: The President and the Office of Government Relations are solely responsible for developing and coordinating official university positions or formal comments on proposed federal and state regulations and policy.
• Professional Society Representation: If you are asked to submit comments or engage in advocacy regarding these grant regulations on behalf of a professional society or external organization, you must notify and coordinate with the VCU Office of Government Relations in advance.
• Note on Routine Grant Actions: As a reminder, this policy does not restrict routine, everyday technical interactions with your federal program officers regarding active, standard grant proposals or awarded projects.

We appreciate your patience and dedication to maintaining the highest standards of research integrity and compliance at VCU. We will keep you updated as more information becomes available.

If you have immediate questions regarding the “Communicating with Governmental Officials” policy, please contact the VCU Office of Government Relations.

Sincerely,

P. Srirama Rao, Ph.D.
Vice president for research and innovation

Register for town hall

Complete feedback form

The following message was sent to VCU/VCU Health research faculty and staff:

Dear colleagues,

As you may be aware, the federal government may enter a shutdown period tomorrow. As we continue to evaluate the impact that this may pose to the VCU research enterprise, please be aware of the following guidance to assist you during this time:

• Existing work on projects should continue, unless communication is received from the agency to the contrary. Please pay very close attention to all communication received for the time being as VCU's response to these notices will need to be swift. Any such communication should also be sent promptly to the Division of Sponsored Programs and Grants and Contracts Accounting. Drawdowns will resume once federal systems are online and available again.
• Particularly for those with federal contracts, communication regarding specific contingency plans could be expected.
• Proposal submissions should continue as planned where possible, particularly submissions for the October 6 deadline. While there could be a deadline extension issued retroactively once the government reopens, this is not a certainty and should not be expected.
• Administrative actions/prior approval requests should continue to be requested in a timely fashion (although agency response from various staff and program officers will likely not occur until reopen).
• Responses to our proposal submissions and prior approval requests will be limited as very few of our agency programmatic or administrative contacts will be available for guidance and communication during the shutdown.

Guidance on individual agency plans during shutdown are hosted solely on each agency’s website. Should you need any assistance in finding any agency-specific guidance or should you encounter any challenges as a result of this potential shutdown, please do not hesitate to contact dirospa@vcu.edu.

As we receive guidance on individual projects, we will communicate that promptly to the affected individuals. 

Please feel free to contact DSP with any questions that you may have regarding your specific projects.

My best,

P. Srirama Rao, Ph.D.
Vice president for research and innovation

NIH director, Jay Bhattacharya, M.D., Ph.D., has announced a unified strategy that aims to align federal priorities and funding approaches. Researchers are advised to review this new strategy during award application processes. The statement can be found here. 

The university is now certifying and accepting all federal awards. Faculty who have received new federal awards will no longer need to submit an Advanced Index Request Form to establish a new index. DSP/G&C are now completing all federal full award setups. Contact your school or unit research administrator with any questions regarding this process.

On July 18, 2025, a federal judge issued a nationwide preliminary injunction blocking the implementation of the proposed 15% cap on Department of Defense 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 university is closely monitoring the implementation of the new policy announced by the NIH: “Supporting Fairness and Originality in NIH Research Applications.” This policy states that: 

• NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year
• NIH will not consider applications that are either substantially developed by AI, or contain sections substantially developed by AI, to be original ideas of applicants.

This policy applies to all activity codes except T activity codes and R13 Conference Grant Applications.

PIs should monitor and track their progress towards these submission limits. All proposals should continue to adhere to existing institutional submission guidelines.

As we learn more about this new NIH policy and other federal guidelines, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.

On June 17, 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 Defense 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 NSF has further delayed Implementation of Standard 15% Indirect Cost Rate until 6/20/2025. 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.

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.

Click here to view updated information and resources.

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:

• APLU Overview of President Trump's Executive Orders
• Facilities & Administrative (F&A) Costs of Research
• Costs of Federally Sponsored Research infographic
• Frequently Asked Questions about Facilities and Administrative (F&A) Costs
  of Federally Sponsored University Research