Key federal updates, including guidance from specific agencies

by | Jan 29, 2025 | Federal Changes | 0 comments

(UPDATED Jan. 29 at 12:42 p.m.)

The University of Michigan is closely monitoring updates from federal agency partners regarding policy changes and evaluating their potential impact on the management of federally sponsored projects during this period of transition. Any important updates for the research community will be shared here as they become available.

Proposals

Federal sponsor proposal review timelines may be extended due to pauses on federal funding. It is recommended to reconfirm deadlines and check for any changes to the proposal requirements or guidelines. The Office of Research and Sponsored Projects (ORSP) will continue to submit to federal agency submission systems as they are available.

Awards

Many agencies have indicated that work on existing awards may continue as long as obligated funds are available. However, delays in additional funding are anticipated. Continued compliance with research requirements is expected.

Guidance from specific agencies
Department of Agriculture
  • USDA has communicated a temporary suspension of actions on grants in a Jan. 21 memo.
  • According to clarifications offered by the department, the moratorium does not apply to no-cost extensions or no-cost modifications on existing awards. This may include budget revisions that do not obligate additional funds, no-cost extensions of time, changes in key staff and other changes that do not result in any additional expenditure of funds (regardless of their source).
  • Existing work can continue under active awards until such time that you receive future guidance that specific transactions must be modified or terminated.
  • Payments or claims may continue to be processed under existing awards, provided that they are not funded using IRA and IIJA funding sources. Additional guidance related to IIJA and IRA funds will be provided by OCFO and/or OBPA, when available.
  • USDA states that this guidance is subject to change pending future updates from the current administration.
Department of Energy
  • DOE released a memo on Jan. 20 regarding an agency-wide review of program and administrative activities.
  • Awards will be postponed for pending proposals.
  • Work may continue if funds are available on existing awards.
  • A principal investigator or research administrator who receives a stop-work order directly should contact their award management officer in ORSP.
  • DOE issued a subsequent memo on Jan. 27 directing the suspension of the following activities in any source of DOE funding, including grants and contract awards:
    • Diversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; and
    • Justice40 requirements, conditions, or principles.
    • Community Benefits Plans (CBP); and
  • According to the Jan. 27 memo, DOE will initiate award modifications consistent with this order, and costs associated with these activities incurred after Jan. 27 will not be reimbursed.
Department of Health and Human Services
  • There will be a delay in communications due to an immediate pause on issuing documents and public communications.
  • This pause is expected to be temporary to allow the president’s appointees to have the opportunity to review and approve any regulations, guidance documents and other public documents
  • This mandate was issued directly through the HHS in a Jan. 21 memo, and thus impacts the National Institutes of Health, the Centers for Disease Control and Prevention, the Food and Drug Administration and all other HHS divisions.
NASA
  • NASA issued a memo on Jan. 23 stating the following as it relates to grants and contracts:
    • 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.
  • The NASA memo also offered the following 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.
National Institute of Justice
  • The National Institute of Justice – the research, evaluation, and technology agency of the Department of Justice – has cancelled all previously posted Notices of Funding Opportunity and associated webinars, according to a notice on its website.
National Science Foundation
  • NSF posted a message on its website on Jan. 28 referring to the Office of Management and Budget’s Jan. 27 memo directing 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.
  • The NSF message advised that “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.”
  • The agency is advising PIs to direct questions to this webform.
Office of Science
  • The Department of Energy’s Office of Science is immediately ending the requirement for Promoting Inclusive and Equitable Research (PIER) Plans in proposals submitted to the office.
  • All open solicitations have been or will be amended to remove the PIER Plan requirement and associated review criteria.
  • For proposals already submitted, no action is required from applicants. However, applicants may choose to resubmit their application without a PIER Plan. Reviewers will not be asked to read or comment on PIER Plans, and selection decisions will not consider their content or any related reviewer comments.
Additional resources
Questions or concerns?

Please reach out to [email protected].