Last Update: April 16, 2025
This page will be updated as new information is made available.
For university-wide updates, visit WashU: Updates on Federal Impacts.
The current administration took office on January 20, 2025. Several Executive Orders have been issued, which may signal shifts in federal priorities. WashU is closely monitoring the situation and coordinating with peer stakeholders.
Updates and resources related to Federal Executive Orders and other federal actions impacting federally-funded research can be found below.
Proposals
Awards
Executive Actions
Federal Agency Guidance
Resources
WashU Announcements
Pending Lawsuits
Proposals
- Proposal should continue to be submitted as in accordance with the published Notice of Funding Opportunity (NOFO).
- NOFO may be revised without notification. Confirm updates from the sponsor have not been issued.
- We anticipate that there may be delays in proposal review timelines.
- NIH Proposals and RPPRs Guidance – 4/3/2025
- Detailed guidance for Research Administrators
Awards
- The terms and conditions of an executed award remain enforceable so long as an award is active. This includes the ability to invoice and receive reimbursement. Please continue with business as usual.
- OMB memorandum M-25-13 has been rescinded. Federal agencies are not currently ordered to “temporarily pause all activities related to obligations or disbursement of all federal financial assistance.” – 1/29/2025
- Changes are expected in requirements for research compliance and award reporting. These changes may come directly from the federal agency, or on a project-by-project basis. You may receive instructions from your Program Officer, and they should be promptly and strictly followed to ensure compliance and avoid jeopardizing funding. Any information the university receives regarding changes will be communicated broadly.
- Exercise caution when considering project activation requests as they are at the risk of the department. See: Proposal Submission & Management During Ongoing Federal Litigation.
Executive Actions
Executive Action Types
- An Executive Order (EO) directs government operations and has the force of law.
- A Proclamation is a formal statement often ceremonial or symbolic.
- A Memorandum provides policy guidance or instructions, typically less formal than an EO.
Overview of All Executive Actions
- Presidential Actions – The White House
- COGR’s Summary of Executive Orders – Includes details about EOs that impact research and/or grants and contracts.
- APLU Overview of President Trump’s Executive Orders – Association of Public and Land-grant Universities – 1/23/2025
Executive Directives Most Impacting Research
- Ensuring Commercial, Cost-Effective Solutions in Federal Contracts – 4/16/2025
- Restoring Common Sense to Federal Procurement – 4/15/2025
- A Letter to Michael Kratsios, Director of the White House Office of Science and Technology Policy – 3/26/2025
- Protecting America’s Bank Account Against Fraud, Waste, and Abuse – 3/25/2025
- Improving Education Outcomes by Empowering Parents, States, and Communities – 3/20/2025
- Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement – 3/20/2025
- Restoring Public Service Loan Forgiveness – 3/7/2025
- Memorandum Fact Sheet: President Donald J. Trump Ensures the Enforcement of Federal Rule of Civil Procedure 65(c) – 3/6/2025
- Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative – 2/26/2025
- Ensuring Accountability for All Agencies – 2/18/2025
- Radical Transparency About Wasteful Spending – 2/18/2025
- Keeping Education Accessible and Ending COVID-19 Vaccine Mandates in Schools – 2/15/2025
- Establishing the President’s Make America Healthy Again Commission – 2/13/2025
- Ending Illegal Discrimination and Restoring Merit-based Opportunity – 1/21/2025
- Ending Radical And Wasteful Government DEI Programs And Preferencing – 1/20/2025
- Reevaluating and Realigning United States Foreign Aid – 1/20/2025
Federal Agency Guidance
CDC – Centers for Disease Control & Prevention
- DEI Restrictions (Domestic) – 1/29/2025 – Rescinded
CHCO – Chief Human Capital Officers Council
- Initial Guidance Regarding DEIA Executive Orders – 1/21/2025
DOD – Department of Defense
DOE – Department of Energy
- Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE) – 4/11/2025
- Suspension of DEI, CBP, PIER, and Justice40 – 1/31/2025
- Agency-wide Review of Program and Administrative Activities – 1/20/2025
DHHS – Department of Health and Human Services
- Payment Management System (PMS) Payment Delays Due to Executive Orders – 1/27/2025
- Effective immediately, PMS is only available during the hours of 9 a.m. to 4 p.m. EST, Monday – Friday. The limited hours are in effect until a further notice.
- PAYMENT DELAYS: Due to Executive Orders regarding potentially unallowable grant payments, PMS is taking additional measures to process payments. Reviews of applicable programs and payments will result in delays and/or rejections of payments.
HRSA – Health Resources and Services Administration
- Dear Colleague Letter from HRSA Administrator Thomas J. Engels – 4/8/2025
- Letter to Hospital Administrators, Colleagues, and Grant Recipients from HRSA Administrator – 3/6/2025
NASA – National Aeronautics and Space Administration
- NASA Payment Request Monthly Cut-off Update – 4/1/2025
- [NASA Watch] Janet Petro NASA Update – 2/21/2025
- Amendment 109: Removing DEIA Requirements from ROSES-2024
NIH – National Institutes of Health
- Implementation Update: Enhancing Security Measures for NIH Controlled-Access Data [NOT-OD-25-083] – 4/2/2025
- Protecting Human Genomic Data when Developing Generative Artificial Intelligence Tools and Applications [NOT-OD-25-081] – 3/28/2025
- NIH Implementation of New Initiatives and Policies
- NIH Grants and Funding Information Status
- RESCINDED: NOT-OD-20-178 – Requirement for Trainee Diversity Report to be Submitted Electronically for Institutional Research Training, Career Development, and Research Education Awards Beginning in Early FY 2021 – Rescinded 3/17/2025
- NOT-OD-25-068, “Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates” – 2/7/2025
- PA-23-189, “Research Supplements to Promote Diversity in Health-Related Research” – Expired
NIJ – National Institute of Justice
- NIJ has cancelled all previously posted Notices of Funding Opportunity and associated webinars – 1/27/2025
NSF – National Science Foundation
- Temporary Restraining Order (directed to Federal grant-making agencies) – 1/31/2025
- Executive Order Implementation webpage – 1/28/2025
OPM – Office of Personnel Management
Resources
AAMC – Association of American Medical Colleges
COGR – Council on Government Relations
- 2025 Administration Transition Information & Resources
- COGR’s Summary of Executive Orders
- Unnecessary Disruptions to Federally Supported Research – 2/18/2025
- COGR Letters to Trump Administration on Reducing Red Tape Affecting Research (email) – 1/29/2025
WashU Announcements
- NIH Guidance on Genomic Data and Artificial Intelligence – 4/3/2025
- Update on impact of federal actions – Chancellor Martin – 3/31/2025
- Agency Communications – 3/6/2025
- Principles for the Research University of Our Time – Chancellor Martin – 2/18/2025
- Indirect Cost Guidance – 2/11/2025
- Update on research funding – 2/8/2025
- Conducting research while temporary restraining orders are litigated – 2/6/2025
- Federal Grant Funding Process – 2/3/2025
- Update on Federal Directives – 1/28/2025
- Response to Pause by Federal Agencies – 1/23/2025
Pending Lawsuits
Lawsuits have been filed to challenge the legality of some of the new Executive Orders and Memoranda. However, recipients of federal funds are required to comply with guidance as it is issued until a determination is made by a judge. Below are some pending lawsuits that may result in temporary restraining orders or recent federal regulations being overturned or upheld.
- Association of American Universities v. Department of Energy – 4/14/2025
- American Association of University Professors – Harvard Faculty Chapter v. United States Department Of Justice – 4/11/2025
- AG Campbell Sues Trump Administration Over Illegal Funding Cuts and Delays for Medical and Public Health Research – 4/4/2025
- American Public Health Association et al. v. NIH et al. – 4/2/2025
- Colorado et al. v. DHHS et al. – 4/1/2025
- State of Washington v. Trump – 2/7/2025
- Notice of Court Order – 3/5/2025
- PFLAG (Parents, Families, and Friends of Lesbians and Gays) v. Trump – 2/14/2025
- Association of American Medical Colleges Files Temporary Restraining Order Against the Change of Rate Notice NOTOD-25-068 – 2/10/2025
- ACE, AAU, APLU, Others File Legal Challenge to Trump Administration’s Cut to Life-saving NIH Research – 2/10/2025
- AG Campbell Sues Trump Administration For Defunding Medical And Public Health Innovation Research – 2/10/2025
- Doctors for America v. Office of Personnel Management, CDC, FDA and DHHS – 2/4/2025
- Association of Diversity Officers in Higher Education v. Trump – 2/3/2025
- National Council of Nonprofits v. Office of Management and Budget – 1/28/2025
- State of New York v. Trump – 1/28/2025