Federal updates impacting research
Since the start of the new presidential administration on Jan. 20, 2025, the White House has issued multiple executive orders and taken federal actions that have implications for federally funded grants, agreements and contracts. The Office of the Vice President for Research, in collaboration with the Office of the Provost and Executive Vice President and other CSU leadership, is reviewing and monitoring federal policy changes to evaluate impact and provide guidance for the CSU community.
OVPR will communicate directly with principal investigators and project leads as we receive notifications from funding agencies about the need to modify or stop certain activities related to specific grants and contracts.
Questions?
OFFICE OF THE VICE PRESIDENT FOR RESEARCH MESSAGES
- March 11: Sharing some good news and actions for possible federal shutdown
- March 3: Updated guidance regarding federal changes and activities
- February 25: Update on federal sponsored projects
- February 14: Update on federal sponsored projects
- February 8: New guidance from NIH capping F&A
- See archived messages
FEDERAL FUNDING UPDATES
The content on this webpage refers only to federally funded activities.
March 6: Possible government shutdown guidance
A government shutdown is possible at midnight on March 14.
A potential shutdown may affect federal agencies in different ways. Please take the following steps to prepare:
- For federally funded grants that expire between March 15 and May 15, please work with the Office of Sponsored Programs to request extensions now, if needed.
- Consider submitting proposals due on or around March 14 early. Some federal agencies may suspend the acceptance of new grant proposals and the issuance of new awards.
- Please continue to work on your projects as planned, unless you are notified otherwise by your federal, federal pass-through sponsors, or the OVPR.
March 5: Preliminary injunction puts cuts to indirect costs on hold
- On March 5, a federal judge issued a preliminary injunction on the NIH plan to change the rate of indirect costs, issued on Feb. 7. The preliminary injunction further pauses the cuts while the legal process plays out.
- The injunction is nationwide.
- Existing NIH awards and new NIH proposals should continue to utilize CSU’s federally negotiated facilities and administration rates
- Please continue to comply with original terms and conditions of awards.
- Further changes may occur as the courts continue to review the administration’s actions and directives, with the potential for the court order to be reversed.
Feb. 10: Temporary restraining order regarding cap on facilities and administration costs
- On Feb. 10, Attorney Generals from 22 states, including Colorado, sued the federal government to halt the implementation of the 15% cap on facilities and administration costs at the National Institutes of Health. The court has granted a temporary restraining order.
- Colorado is one of 22 states involved in the legal action against the NIH to block an indirect cost rate cap at 15% for new and existing grants.
- A federal judge issued a temporary restraining order on Monday, Feb. 10. It applies to all 50 states.
- An additional, similar lawsuit was filed by the Association of Public Land Grant Universities and Association of American Universities. A temporary restraining order was also issued in that case.
- Existing NIH awards and new NIH proposals should continue to utilize CSU’s federally negotiated facilities and administration rates
- Please continue to comply with original terms and conditions of awards.
- Further changes may occur as the courts continue to review the administration’s actions and directives, with the potential for the court order to be reversed.
Jan. 31: Temporary restraining order on pause in federal funding
On Jan. 31, 2025, a temporary restraining order was issued by a United States District Court. The temporary restraining order impacts the implementation of the federal Office of Management and Budget directive related to federal funding.
- The court ordered that the federal government cannot pause, block or terminate federal awards and obligations, except on the basis of current law and regulation.
- This means that federal agencies are not permitted to block or terminate funding for grants, contracts, or cooperative agreements based on the federal Office of Management and Budget directive or recently issued executive orders.
- The temporary restraining order applies to all federal financial assistance, including sponsored research.
- Work on federally funded awards may resume if activities had been stopped due to the executive orders and related stop-work orders.
- For the time being, this includes work involving DEIA (diversity, equity, inclusion, access) activities.
- Please continue to comply with the original terms and conditions of the awards.
KEY INFORMATION
- If you receive a stop-work order, termination or other notice please email that communication to [email protected] immediately.
- View the latest agency-specific updates and guidance, and federal executive orders.
- With the temporary restraining order in place, activities on federal awards may continue unless you have received additional direction from a federal sponsor or from the Office of the Vice President for Research (OVPR).
- This is a rapidly shifting landscape and is subject to change, please continue to monitor the impacts to your work and communicate changes to [email protected].
SPONSORED PROJECT GUIDE
Review timelines for sponsored project proposals may be extended while federal agencies navigate pauses on federal assistance funding in specific areas.
- Continue to submit proposals as submission systems at federal agencies remain operational.
- Reconfirm proposal deadlines, as they may change.
- Verify that funding announcements have not been revised or postponed.
- It is likely that DEIA-related aspects will be removed from solicitations going forward.
- Sign up for agency or sponsor alerts, if available.
- OVPR will not approve new pre-award spending accounts for federal awards at this time.
- Pre-award spending accounts already approved for federal awards with department guarantees should be assessed by college or other home unit.
- Please follow any other agency-specific guidance.
The terms and conditions of your active awards remain enforceable. Please continue with activities as usual unless notified otherwise by OVPR of a federal agency. OVPR will promptly review and share with PIs any awards, amendments or notices to awards.
- If you receive any notification about your award from your federal sponsor, please send it promptly to [email protected].
- You can anticipate that grant reviews, new awards, modifications, and amendments will be delayed.
- Closely monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed.
- If you receive a stop-work order or termination notice, immediately halt project activities as specified in the notice and notify [email protected].
- Review the terms of the stop-work order or termination notice carefully.
- Retain all award records using the normal records retention processes and procedures.
- Submit any required final reports and deliverables promptly.
- Do not incur additional expenses on federal sponsored program accounts related to the order or notice unless explicitly authorized.
- If a stop work order or termination of an award is received, the Office of Sponsored Programs will work with any subrecipients on the award to issue required notices and/or changes to the subrecipient agreement.
With the temporary restraining order issued on Jan. 31, 2025, in place, DEIA activities on federal awards may resume. Please see the Feb. 3, update (above) for further details.
Following the issuance of executive orders on Jan. 20 and Jan. 21, many federal agencies have issued notices to immediately cease all diversity, equity, inclusion and accessibility (DEIA) activities using federally funded awards.
At this time, based on the temporary restraining order issued Jan. 31, DEIA activities on federal awards may resume. As noted, this is a fluid situation and subject to change. We will continue to provide updates as quickly as possible.
The federal government has provided limited definition of the terms “DEI” and “DEIA” and interpretation varies across agencies.
RELEVANT UPDATES & EXECUTIVE ORDERS
- APLU (Association of Public Land Grant Universities) tracks updates: Research Facilities and Administrative Costs.
- COGR, the national authority on federal policies and regulations affecting U.S. research institutions, tracks and shares news, executive orders, and resources as they become available.
NOTIFICATIONS FROM AGENCIES
Office of Management and Budget (OMB) Memorandum M-25-13, issued on January 27, 2025, directs all Federal agencies to conduct a comprehensive review of their financial assistance programs to determine programs, projects, and activities that may be implicated by the recent Executive Orders. Therefore, all review panels, new awards, and all payments of funds under open awards will be paused as the agency conducts the required reviews and analysis. NSF has created an executive order implementation webpage to ensure the widest dissemination of information and updates. We will continue to communicate with you as we receive additional guidance.
All NSF grantees must comply with these Executive Orders, and any other relevant Executive Orders issued, by ceasing all non-compliant grant and award activities. Executive Orders are posted at whitehouse.gov/presidential-actions. In particular, this may include, but is not limited to conferences, trainings, workshops, considerations for staffing and participant selection, and any other grant activity that uses or promotes the use of DEIA principles and frameworks or violates Federal anti-discrimination laws. Please work with your institutional research office to assist you in complying with the Executive Orders. You can also direct your questions through this webform.
Thank you for your work advancing science, engineering, technology and innovation for our nation.
MEMORANDUM FOR ALL DOE FUNDING AGREEMENTS OR AWARDS
FROM: SARA WILSON
ACQUISITION DIRECTOR
ACTING HEAD OF CONTRACTING ACTIVITY
ENERGY EFFICIENCY & RENEWABLE ENERGY
SUBJECT: Cease all activities associated with DEI and CBP
The President has issued 43 Executive Orders, Presidential Memoranda, and Proclamations, including an Executive Order entitled Ending Radical and Wasteful Government DEI Programs and Preferencing. DOE is moving aggressively to implement this Executive Order by directing the suspension of the following activities in any loans, loan guarantees, grants, cost sharing agreements, contracts, contract awards, or any other source of DOE funding:
● diversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; and
● Community Benefits Plans (CBP); and
● Justice40 requirements, conditions, or principles.
Recipients and subrecipients must cease any activities, including contracted activities, and stop incurring costs associated with DEI and CBP activities effective as of the date of this letter for all DOE grants, cooperative agreements, loans, loan guarantees, cost sharing agreements, or other DOE funding of any kind.
Recipients are responsible for communicating and enforcing this direction with all subrecipients and contractors. Costs incurred after the date of this letter will not be reimbursed.
This letter will be incorporated into your award with the next modification.
Additional guidance will be forthcoming. Recipients who have DEI and CBP activities in their awards will be contacted by their Grants Officer to initiate award modifications. consistent with this Order.
MEMORANDUM FOR NASA CONTRACTOR AND GRANTEE COMMUNITY
SUBJECT: Initial Guidance Regarding Diversity, Equity, Inclusion,
Accessibility (DEIA) Executive Orders
On January 20, 2025, the President of the United States of America signed an Executive Order (E.O.) titled, “Initial Rescissions of Harmful Executive Orders and Actions”, which repeals Executive Order 14035, Diversity, Equity, Inclusion and Accessibility in the Federal Workforce”.
The U.S. Office of Personnel Management (OPM) issued a memorandum, dated January 21, 2025, titled, “Initial Guidance Regarding DEIA Executive Orders” to federal agencies.
To implement the E.O. requirements, OPM directed federal agencies to take immediate action to identify and terminate DEIA initiatives and programs and remove final or pending documents, directives, orders, materials, and equity plans issued in response to the now-repealed Executive Order 14035, Diversity, Equity, Inclusion and Accessibility (DEIA) in the Federal Workforce (June 25, 2021). To date, the following directions are provided:
Contracts and Grants. NASA Contractors and Grantees immediately shall cease and desist all DEIA activities required of their contracts or grants. In accordance with FAR 52.242-15, Stop Work clause, a stop work order may have been issued to stop all or any part of the DEIA related activity.
Additionally, FAR 52.249, Terminations clause modifications may also be issued to implement this change. This work may include but is not limited to: DEIA plan requirement, training, reporting, considerations for staffing, or any other direct or indirect contract or grant activity. All Contractors and Grantees shall notify their Contracting Officer or Grant Officer if they identify requirements within their contracts or grants that are in violation this guidance.
Guidance. Consistent with the DEIA E.O. and the Regulatory Freeze Pending Review E.O, additional guidance will be issued to further implement the executive order requirements, such as updating and removing DEIA related policy guidance in the NASA FAR Supplement, Grant and Cooperative Agreement Manual, Grant and Cooperative Agreement Procedures, and the Grant and Cooperative Agreement Terms and Conditions.
Websites, social media, accounts, etc. NASA Office of Procurement has removed external and internal facing contract and grant websites that include DEIA related policies and documents, and these website were taken offline as of 5pm January 22, per OPM guidance.
National Aeronautics and Space Administration
Mary W. Jackson NASA Headquarters
Washington, DC 20546-0001
We endeavor to keep our NASA contractor and grantee community informed. As additional guidance becomes available, NASA Contracting Officers or Grant Officers will be contacting your organization to discuss necessary contract or grant modifications required to comply with the Executive Orders. To ensure efficient lines of communication are available we ask companies to actively engage with their cognizant Contracting officer or Grant Officer regarding the removal of DEIA activities as it pertains to their contract or grant award.1
Please contact your cognizant Contracting Officer or Grant Officer if you have any questions regarding this memorandum.
I appreciate your cooperation and continued commitment to supporting NASA’s mission.NASA President Executive Order Guidance
Dear Recipient:
This Centers for Disease Control and Prevention (CDC) award is funded in whole or in part with United
States Government foreign assistance funds.
To implement Executive Orders entitled Ending Radical and Wasteful Government DEI Programs and Preferencing and Initial Rescissions of Harmful Executive Orders and Action, you must immediately terminate, to the maximum extent, all programs, personnel, activities, or contracts promoting “diversity,
equity, and inclusion” (DEI) at every level and activity, regardless of your location or the citizenship of employees or contractors, that are supported with funds from this award. Any vestige, remnant, or renamed piece of any DEI programs funded by the U.S. government under this award are immediately,
completely, and permanently terminated.
No additional costs must be incurred that would be used to support any DEI programs, personnel, or
activities.
If you are a global recipient and have previously received this notification regarding DEI activities, please follow those instructions accordingly.
January 27, 2025
SUSPENSION OF AWARD IMPLEMENTATION
Reference: President Trump’s Executive Orders Reevaluating and Realigning United States Foreign Aid; Reevaluating and Realigning United States Foreign Aid and DEIA Activities Under Existing USAID Awards
This notice applies to all assistance awards (e.g., cooperative agreements and grants) issued by USAID/M/OAA/REFS in support of USAID’s Bureau for Resilience, Environment, and Food
Security.
Suspend Performance. The Agreement Officer hereby issues this order for award recipients to immediately suspend performance (See 2 CFR 700.14) under the agreement between your organization and USAID.
You must not resume implementation until you have been notified in writing by the cognizant Agreement Officer to resume implementation. In the meantime, the award recipient will take all reasonable steps to minimize the incurrence of costs allocable to the agreement during this pause. For additional guidance, please refer to “Notice on Implementation of Executive Order: Reevaluating and Realigning United States Foreign Aid.” Please confirm via e-mail to the cognizant Agreement Officer of your receipt of this notice and your intent to comply with this Stop-Work Order.
Certification. Previously via email dated January 24, 2025 you were asked to send written certification that you are not implementing DEIA-related activities under the award. This certification request is in accordance with the “Notice on Implementation of Executive Order: DEIA Activities Under Existing USAID Awards” issued by the USAID Senior Procurement Executive on January 24, 2025. Please send the written certification via Email with the Subject Line: “DEIA Partner Certification” to the cognizant Agreement Officer and to [email protected]. The certification should include the name of the activity, the award number, and a clear statement that DEIA-related activities have completely ceased.
Additional details will be forthcoming as soon as possible. In the meantime, please direct any questions to my attention at [email protected].
In accordance with FAR 42.1303, the Government hereby directs your firm to stop work on any DEIA related work in accordance with the President’s Executive Orders titled Ending Radical and Wasteful Government DEI Programs and Preferencing and Initial Rescissions of Harmful Executive Orders and Actions, which repeals Executive Order 14035, Diversity, Equity, Inclusion and Accessibility in the Federal Workforce. Therefore, your firm shall cease all services and the ordering of supplies in support of any DEIA related work. If applicable, any work not related to DEIA activities may continue.
All subcontractors shall be notified immediately that a stop-work order has been issued to the prime contractor for DEIA related work. The stop-work order shall remain in place until you are notified otherwise by the Contracting Officer. As soon as feasible and prior to the lifting of the stop-work order, appropriate action shall be taken to either cancel the contract or extend the period of performance, if necessary. The stop work order is being implemented due to causes outside of your control and should not be misconstrued as an indication of poor performance by your firm.
Please do not hesitate to contact Michael McGuire with any questions or concerns at [email protected].