July 29, 2026
This email is being sent to PIs with open federal awards, deans, research associate deans, and unit heads whose units have federal sponsored projects.
Dear Colleagues,
Over the summer, we have seen a rise in agency rulemaking that would impact the CSU research enterprise. Beyond the Office of Management and Budget’s proposed overhaul of the Uniform Guidance, I want to highlight a few others today.
New final rules
The Department of Energy recently announced a final rule on conflict of interest and conflict of commitment that goes into effect on Aug 17. The rule codifies the National Security Presidential memorandum-33 and the Chips and Science Act of 2022. It places additional, broad requirements on institutions that receive DOE funding including new training, reporting, and oversight requirements. This new rule will require CSU to modify our Conflict of Interest and Conflict of Commitment policies and procedures. While CSU continues to support employees’ engagement in outside activities that enhance our mission, there will be added oversight to both the nature and time spent on this work. More information will be communicated as the policies and procedures are finalized.
The White House issued a new policy, “United States Government Policy for Stopping High-Risk Life Sciences Research.” It will require research institutions such as CSU that are receiving federal funds come into compliance by Jan. 16, 2027. This policy imposes new obligations on research universities and principal investigators including new review, certification, and training requirements. It also prohibits certain kinds of federally funded research, including dangerous gain of function research and all life science research conducted with a country, entity, or individual of concern. We anticipate additional guidance over the next 120 days from science and national security agencies.
Rule-making and public comment
The National Science Foundation is proposing considerable changes to its Proposal and Award Policies and Procedures Guide (PAPPG). CSU will be submitting public comment before the Aug. 24 deadline. To provide input for consideration in CSU’s response, please submit feedback via this survey by end of the day on Aug. 17. If you would like to comment as a private citizen, you may submit comments directly to the NSF.
The National Institutes of Health also has a proposed policy open for public input, with the comment period closing on Aug 3. This proposed policy would cap the number of Research Project Grants an individual can simultaneously serve on as principal investigator or multi-principal investigator. CSU is working with national higher education associations to develop comments. If you have feedback that you would like us to consider, please email it to Lori Schultz. If you would like to comment as a private citizen, you may submit comments directly to the NIH.
Court ruling
On July 17, the U.S. District Court for the District of Massachusetts ruled in favor of a coalition of 20 states, including Colorado, holding that federal agencies may not terminate previously awarded grants simply because a new administration adopts different program goals or policy priorities after an award has been made. This decision remains subject to appeal and may be affected by the changes proposed by the Office of Management and Budget to the Code of Federal Regulations. In the meantime, the Office of Sponsored Programs is reviewing termination notices received over the past year to identify awards that may have been terminated on this basis to determine next steps.
Finally, I hope you all take advantage of the last weeks of summer and spend quality time doing things you love. Thanks to everyone who has participated in previous requests for comments and collaboration as we respond to proposed federal changes. As always, I’m grateful for all you do.
Best,
Cass
Cassandra Moseley, Ph.D. (she/hers)
Vice President for Research
Professor, Department of Forest and Rangeland Stewardship
Office of the Vice President for Research