Executive Order Impact Guidance

The recent Executive Orders issued by the new administration may bring changes to federal priorities that could impact awarded projects and pending applications. While the full effects are not yet clear, the Office of Research is actively monitoring developments and will provide updates as they become available.

This page was last updated May 14, 2025

Potential Impacts

  • Submission systems (e.g., Grants.gov) will remain operational. Deadlines must still be met, but review funding announcements for any revisions prior to submission.
  • Delays in award notices and modifications may occur, but ongoing projects with current funding should not be affected.
  • It is possible some programs may experience restructuring, funding delays, or temporary restrictions on certain expenses (e.g., travel).
  • We may see changes to compliance requirements as agencies adjust to meet the new requirements.  
  • We may encounter potential delays in payments from some federal sponsors or requests for additional information to support payments.

 

Recommended Actions

  • Researchers should continue their projects and adhere to deadlines as usual. Unless specifically directed otherwise, projects will not need to stop work.
  • Submit all required reports (technical, financial, and compliance) on or before deadlines. Prioritize past-due deliverables.
  • Avoid spending funds for projects without award documents or fully executed agreements.
  • The Office of Research is closely monitoring guidance from federal agencies. We will promptly communicate updates to the research community.

While it is difficult to predict the extent of the impacts or how agencies may respond, our experience has shown that short-term disruptions typically have minimal impact on federally funded projects. The Office of Research is committed to providing clear and timely information to support our researchers and their important work.

Thank you for your collaboration and support as we navigate this situation together. We are maintaining a running list of guidance relating to recent executive orders that could impact federal funding. This page will be updated.

Indirect Rate Reduction Cases

  • NIH F&A Reduction to 15% 
    • Case No. 1:25-cv-10338, 1:25-cv-10346, and 1:25-cv-10340
    • Granted a permanent injunction on 4/4
    • Case has been appealed to the First Circuit Court and is awaiting hearing
      • Appellate Case (First Cir.) 

  • Dept of Energy F&A Reduction to 15% 
    • Case No. 1:25-cv-10912
    • Temporary Restraining Order in place 4/16 
    • TRO will continue until the request for preliminary injunction is resolved. 

  • NSF F&A Reduction to 15% 
    • Lawsuit filed on 5/5, Case 1:25-cv-11231 

  • , Effective 3/25/2025
    • Detailed description of expenses now required for any draw of funds, known as the DOGE form
    • All requests are elevated up to a couple of individuals at each agency that report to DOGE
    • Requiring reduction of payment systems outside of the Treasury and the Treasury is charged with reviewing payments for fraud, waste, and abuse 

NIH Policy 

  • No Cost Extensions (NCE),
    • Grantee initiated automatic 12-month NCEs are no longer permitted
    • All NCE must be submitted via Prior Approval Module in Commons 

  • Foreign Subawards,  
    • NIH will not issue new awards that include a subaward to a foreign entity  
    • Institutes may opt to renegotiate awards to remove subawards to foreign entities. If a project is no longer viable without the foreign subaward, NIH will work with the recipient to negotiate a termination of the project
    • NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. Unknown structure expected to be implemented by 9/30/2025 to manage foreign subrecipients  
    • New structure may extend to domestic subawards as well 

Select Executive Orders

 

February 26, 2025 — Calls for a 30 days pause on payments to evaluate of grants and contracts for fraud, waste, and abuse.

 

February 3, 2025 — Temporary Restraining Order (TRO) challenging the pause of certain Federal financial assistance. 

learn more

 

January 29, 2025 — The Office of Management and Budget has rescinded its memo freezing spending on federal grants.

OMB Rescission Memo

 

January 28, 2025 — With the new administration taking office on January 20, 2025, several Executive Orders (EOs) have been issued. These EOs could signal shifts in federal priorities, which may impact awarded projects and pending applications from federal sponsors.

 

January 27, 2025 — In implementing President Trump’s executive orders, the Office of Management and Budget issued guidance requesting that agencies temporarily pause, to the extent permitted by law, grant, loan or federal financial assistance programs that are implicated by the president’s executive orders.

 

Guidance

 

Agency-Specific Information

  • February 2, 2025 — NSF has reopened the payment portal and is working to reschedule cancelled review panels.

    January 28, 2025 — NSF has restricted the ability to draw down funds at this time and has paused review panels in the short term.

  • February 10, 2025 — Attorney Generals Case 1:25-cv-10338 was filed for injunctive relief.

    February 7, 2025 — NIH released a Notice limiting indirect costs on future projects to 15% and expenses incurred on existing grants as of 2/10/2025 forward.

  • January 27, 2025 — All funding opportunities from the Department of Energy are currently under review, pausing grant-making from this agency. Unclear when grant-making will resume.

    January 20, 2025 — See below for previous Department of Energy guidance.

  • January 28, 2025 — Additional Information on USAID’s Implementation of the Executive Order on Reevaluating and Realigning United States Foreign Aid

    learn more

    January 24, 2025 — All funding opportunities from U.S. AID are paused and a stop work orders are being issued on foreign assistance.

  • January 23, 2025 — Guidance from NASA.

  • January 23, 2025 — Guidance from the Department of Education.

  • January 22, 2025 — Guidance from the Department of Labor.

  • January 21, 2025 — Guidance from the Department of Health and Human Services.

  • All funding opportunities from U.S. Dept of Agriculture National Institute of Food and Agriculture are currently under review, pausing grant-making from this agency. Unclear when grant-making will resume.