Last Update: May 14, 2025
This page will be updated as new information is made available.

At this time, please adhere to the guidance listed below.

Ongoing litigation and further communications from the federal government may result in changes to these instructions. Updates with any new information will be disseminated as soon as it becomes available.

Please use the RA Teams Network to ask additional questions or seek further clarification.

Proposal Submissions

• We encourage faculty to continue to submit proposals 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.
• Guidance for Avoiding Misrepresentation in Grant Applications and RPPRs – 4/29/2025
• NIH Proposals and RPPR Guidance – 4/3/2025
• Summary of Updated NIH Policy on Foreign Subawards – Updated on 5/14/2025
• Proposal submission practices have not changed. We will continue to submit proposals at the negotiated indirect cost rate. Do not submit proposals using the 15% rate.

Indirect Cost Reimbursement Cap Policies and Litigation

Guidance from the federal government is complex and rapidly changing.

The National Institutes of Health (NIH), Department of Energy (DOE), and the National Science Foundation (NSF) have implemented policies to cap indirect cost reimbursements for research grants to 15%:

• NOT-OD-25-068: Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates
• Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE)
• NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate – 5/2/2025

These policies have prompted multiple lawsuits:

• As of April 4^th, a nationwide permanent restraining order (PRO) was issued against the NIH.
• As of April 16^th, a temporary restraining order (TRO) was issued against the DOE.
• A lawsuit against the NSF has also been filed (5/5/2025).

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  • OMB memorandum M-25-13 has been rescinded.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.
• Guidance for Avoiding Misrepresentation in Grant Applications and RPPRs – 4/29/2025

No-Cost Extensions (NCEs)

• Updated NIH Processes for No-Cost Extensions [NOT-OD-25-110] – 5/7/2025
  • NIH has temporarily disabled the No-Cost Extension functionality in eRA Commons.
  • At this time, all requests for NCEs must be submitted as a prior approval request in eRA Commons, for NIH review and approval. Requests for activities that do not align with the NIH mission and agency priorities will not be approved.
  • See WashU’s NCE webpage for more guidance.

New Awards

• If we receive new awards or flow-through awards with the 15% rate:
  • They will be placed on hold until the indirect cost rate is resolved.
  • PIs must not charge existing awards for costs associated with a project that is on hold pending resolution of the indirect costs (IDC) rate.
• Project activations for new NIH awards will not be processed by Sponsored Projects Accounting (SPA) until the notice of award (NoA) is received at the negotiated IDC rate. This does not apply to NIH funding mechanisms with IDC rates normally below our negotiated rate such as training grants.
• For existing NIH awards, spending on continuations will not be allowed on awards with foreign subawards until the NoA is received for the next increment of funding.

Stop-Work Orders and Terminations

• Procedure on Grant and Contract Suspensions, Pauses, Stop Work Orders, Cancellations, Terminations, and Non-Cancellable Commitments – 4/29/2025
• Non Cancellable Commitments Template (Excel file) – 4/29/2025

Reimbursement

• Sponsored Projects Accounting will draw down funds from the NIH at the negotiated IDC rate.
• SPA will not draw down funds from the NIH at the 15% rate. 

Rebudgeting Existing Awards

• Do not re-budget costs from indirect to direct categories.

Invoicing

• We have seen an increase in requests from departments to send invoices on agreements that are not fully executed. SPA can NOT send invoices for awards that are not fully negotiated and signed.