Upcoming Federal Changes

Last Update: September 3, 2026

This page includes recent federal agency announcements and guidance, but is not comprehensive. Updates will be added as new information is made available.

More details can be found through the Federal Agency Updates Digest:

Proposed Changes to the Uniform Guidance

On May 29, 2026, the Office of Management and Budget (OMB) proposed significant revisions to the Uniform Guidance. Several of the most consequential proposed changes to research are summarized here.

WashU has submitted a formal letter expressing concerns and opposition to these changes.

The White House

July 21, 2026
Science: A New Golden Age, a report to the President 

  • White House OSTP Director Michael Kratsios wrote this report proposing an overhaul of U.S. federal research and development. The report organizes its recommendations to government, industry, academia, and philanthropy around four key pillars:
    • Revitalize America’s Science and Technology Enterprise 
    • Secure U.S. Dominance in Critical and Emerging Technologies 
    • Launch a New Golden Age Powered by AI for Science 
    • Ensure That Science and Technology Better the Lives of All Americans

Research Security Training

Many sponsors are implementing research security requirements for applicants and awarded researchers. These requirements are summarized on the Research Security Requirements page.

NASA – National Aeronautics and Space Administration
Research Security Training Requirement for Federal Financial Assistance Funding, effective August 5, 2026

NIH – National Institutes of Health

NOT-OD-26-017: Research Security Training Requirements for NIH, effective for applications submitted for due dates on or after May 25, 2026

NSF – National Science Foundation

Important Notice No. 149: Updates to NSF Research Security Policies, effective December 2, 2025

DOE – Department of Energy

FAL (Financial Assistance Letter) 2025-02: Financial Assistance Letter Research Security Training Requirements for all R&D Financial Assistance Awards

Additional resources:

NIH Funding Policy Updates and Considerations

  • NIH has recently published funding policies and considerations for each NIH Institute, Center, and Office (ICO). These policies are based on NIH’s unified funding strategy and identify key topics that ICOs may consider when making funding decisions. 
  • Investigators should review both NIH-wide policies and the funding policies and considerations specific to the relevant ICO when preparing applications. Because NIH continues to update its funding priorities, application requirements, and funding strategies, investigators are encouraged to monitor NIH policy notices, highlighted topics, and ICO-specific guidance regularly.
  • NIH is making several changes to its approach to research funding opportunities and application policies:
    • Greater reliance on broad funding opportunities: NIH is looking to move away from individual NOFOs and increase reliance on parent announcements and other broad funding opportunities. 
    • Six-application limit: Effective September 25, 2025, NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator, Program Director, or Multiple Principal Investigators across all council rounds in a calendar year. Only T activity codes and R13 Conference Grant applications are exempt. See NOT-OD-25-132 for additional information. 
    • End of Continuous Submission: The Continuous Submission Policy will end on August 10, 2026, for applications assigned to the January 2027 Council. 
    • Reclassification of Basic Experimental Studies with Humans (BESH): As of May 25, 2026, BESH are being reclassified and will no longer be considered clinical trials. Consequently, BESH studies will no longer be subject to NIH clinical trial requirements. See NOT-OD-26-032 and NOT-OD-26-067 for additional information. 
    • Letters of Collaboration: As part of the implementation of Form J, NIH will replace Letters of Support with Letters of Collaboration. The letter should document any collaborative relationship with individuals who are not identified in the application as senior/key personnel or other significant collaborators. The letters should not contain endorsements, additional information, or evaluations of the proposed project. Each individual Letter of Collaboration must not exceed 100 words. Examples are available in NOT-OD-26-094.

Additional resources:

NIH Policy on Foreign Subawards

PA-26-002: NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional)

  • On September 12, 2025, the NIH announced they will no longer accept new applications that request funds for foreign components using the traditional grant subaward/consortium structure. The Parent NOFO supporting this structure was released on January 20, 2026. Submissions will be accepted starting April 25, 2026.
  • NIH has released updated instructions for multi-project applications:
    • Collaborating Organization as the Lead of a Component
    • Collaborating Organization as a Consortium in a Component
      • When a collaborating organization does not have a leadership role for a component, then the applicant organization is the component lead, and any collaborating organizations are included using the subaward/consortium budget form.
    • Multi-project Application Component Forms

NOT-OD-25-155: New Application Structure for NIH-Funded International Collaborations

  • Effective for due dates on or after January 25, 2026, competing applications must be in response to a funding opportunity using a new grant type when requesting NIH funding for one or more foreign components.
  • As previously noted in NOT-OD-25-104, NIH must ensure it can transparently and reliably report on each dollar spent on foreign collaborations. The current subaward structure does not allow for consistent reporting and accurate tracking; therefore, NIH will not issue awards to domestic or foreign entities (new, renewal, or non-competing continuation) that include a subaward to a foreign entity.

Resources

Prior Approval Requests

NIH – National Institutes of Health

NOT-OD-26-062: Prior Approval Requirement for Changes to Domestic Subawards

  • Effective June 1, 2026, all prime recipients are required to obtain NIH prior approval when adding a new domestic subaward to a project post-award, when the arrangement was not originally a part of the peer-reviewed and approved application.
  • Requests must be submitted in the eRA Commons Prior Approval Module
    using the “Other Request” type.

NOT-OD-26-026: NIH Requires Use of the eRA Prior Approval Module for the Submission of ALL Prior Approval Requests

  • Effective February 20, 2026, NIH requires the use of the eRA Prior Approval Module for the submission of all prior approval requests.
  • All requests must be initiated and submitted by the Signing Official (SPA).

National Science Foundation Funding Policy Updates and Considerations

Dear Colleague Letter: Prohibition on Collaborations with Restricted Entities

  • This policy bans using NSF funds for research with groups on federal restricted lists, stops key researchers from taking money or jobs from those groups, and shifts policy from case reviews to a full ban. 
  • NSF plans to revise its current guidance to include the following:
    • NSF appropriated funds shall not be used for grants, contracts, other transactions or other assistance to an organization if the purpose is to conduct research in collaboration with restricted entities. This funding prohibition also extends to the employees of such restricted entities. 
    • Senior/key personnel are prohibited from holding an appointment or position with, or receiving research support from, a restricted entity. Further, senior/key personnel are prohibited from collaborating with a restricted entity, or employee thereof, on research funded by their NSF award.

Agency Information Collection Activities: Comment Request; National Science Foundation Proposal/Award Information-NSF Guidance on Financial Assistance

  • NSF is announcing plans to renew and revise its collection for its financial assistance policies and procedures. NSF is providing the opportunity for public comment on this action. After obtaining and considering public comment, NSF will prepare the submission requesting OMB clearance of this collection for no longer than three years. 
  • Read WashU’s response on Regulations.gov.