Published February 3, 2025, via Research News
In the current climate of quickly changing Executive Orders and federal guidance regarding grant funding, it is important to understand the administrative process involved in covering grant expenditures and how new federal updates may impact your research.
The federal government directs how money can be spent. If the federal government changes spending regulations, agencies must comply with the new rules and advise researchers of the changes.
Steps to receive federal funding:
- As part of the application for funding, the PI submits a budget to the sponsoring agency. The budget includes a projection of expenses and their purposes.
- If the grant proposal is awarded, the agency approves the budget and issues a Notice of Award (NOA).
- Most commonly, the agency promises to reimburse WashU for costs that align with the approved budget, in line with the NOA. Funds are not deposited into a WashU account before expenses are incurred.
- As the research progresses, costs are incurred and tracked in Workday.
- WashU’s Sponsored Projects Accounting (SPA) requests reimbursement from the agency for costs incurred.
- The agency approves the reimbursement if it aligns with current federal guidance and then remits the funds to WashU.
Potential impact of Executive Orders on WashU research activities
While we are still working to determine how the new Executive Orders impact WashU, federal agencies are adapting their own guidelines to comply with these Executive Orders. Federally funded research at WashU then must follow the updated agency guidelines. The updated guidance also could be applied retroactively. NSF, DOD, DOE, CDC, and NASA have issued memos to pause all diversity, equity, inclusion and accessibility (DEIA) activities. Some agencies have sent stop work orders to WashU investigators ordering them to pause all DEIA and gender identity activities and expenditures. Even if you have not been directly notified by your federal sponsor, you may want to consider temporarily halting DEIA and gender identity activities paused by the Executive Orders. Any costs incurred related to these activities after January 20, 2025, are at risk of not being reimbursed by federal agencies. All other research activities supported by federal funding should continue unless you receive a direct stop work order.
We understand it is not always clear whether your research activities are directly affected by the new executive orders and related agency guidelines. If you are uncertain about whether your research includes activities affected by the stop work orders, please reach out to your program officer or agency contact.
We have also seen lawsuits being filed to challenge the legality of the new Executive Orders and Memoranda. For now, we expect to continue operating in a scenario where new guidance may come quickly and be rescinded. Ultimately, however, recipients of federal funds are required to comply with guidance as it is issued. We continue to monitor new developments in federal guidance that may affect our research activities and are committed to keeping you updated. Thank you for working together with us during this time, which I know is challenging for many of you.
See grant funding process flowchart in Box.
Sincerely,
Mark E. Lowe, MD, PhD
Vice Chancellor for Research
Associate Dean for Research, School of Medicine
Harvey R. Colten Professor of Pediatric Science