Federal Funding Updates Under the New Administration

听听Last updated March 5, 2025.

Several Executive Orders have been issued since the current administration took office on January 20, 2025, which may signal shifts in federal priorities. These changes could potentially impact both awarded projects and those awaiting funding from federal agencies or sponsors. As federal agencies and sponsors adapt to the ongoing developments related to the transition, the Research & Innovation Office and the Office of Contracts and Grants (OCG) is closely monitoring how federal agencies and sponsors are adapting to these developments.

Research faculty should continue to follow grant, proposal, or funding deadlines and instructions as they are currently posted until further information is updated.

Updates and additional agency specific information will be posted here as it becomes available. If you have questions, please reach out to your OCG Proposal Analyst, Contract or Grant Officer.

What principal investigators (PIs) can do in preparation for a potential federal government shutdown

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If a federal fiscal year 2025 budget or a new continuing resolution are not passed by March 14, we will be faced with a federal government shutdown. While we don鈥檛 know if a shutdown will occur next week, or the length of a shutdown should one occur, we are making preparations.听
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For federally funded projects, directly funded by a federal agency or through a subaward to 91福利社, we recommend PIs take the following actions as soon as possible:
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  • No Cost Extensions (NCE): No-cost extensions (NCEs) that are anticipated within 30 days after March 14 should be submitted promptly. is available on the OCG website and your can help answer questions. Please note that during a shutdown, federal agencies are not able to process NCEs or any other contract modifications.
  • Pre-Approvals: Pre-approvals for key personnel changes, equipment purchases and international travel should be submitted through your .
  • Incremental Funding: PIs should reach out to their sponsor鈥檚 technical contact to request incremental funding on projects for which the incremental funding date is approaching.
  • Plans for Federal Partners on Awards: For awards that include federal partners on the project, PIs should promptly make plans with the federal partner in case they cannot work on the project during the shutdown period.
  • Limit At-Risk Accounts: At-risk accounts will be set up on a very limited, case-by-case basis, until resolution on the federal budget.
  • Post Award: PIs or department administrators should notify their of funds that are due or have not been invoiced for milestones or deliverables completed prior to the shutdown.

Current Guidance

On February 3, 2025, the Trump administration issued new guidance to federal agencies clarifying how it intends to comply with a temporary restraining order (TRO) imposed by the U.S. District Court for the District of Rhode Island on January 31. The guidance clarifies that federal agencies cannot 鈥減ause, freeze, impede, block, cancel or terminate鈥 any federal grants on the basis of the now-rescinded OMB memo from January 27 or any recent Executive Orders. This includes stop work orders issued to institutions as well as individual PIs on specific grants.听

Based on this ruling and the accompanying guidance, we ask that all researchers, faculty, and staff continue working on their grants as normal.听

The administration鈥檚 guidance says federal agencies must release funds for all grants, not just grants in the 22 states, including Colorado, who filed the lawsuit. As stated in the Notice of Court Order:

1. Federal agencies cannot pause, freeze, impede, block, cancel, or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President鈥檚 recently issued Executive Orders.

2. This prohibition 鈥 also applies to future assistance (not just current or existing awards or obligations).

3. Agencies may exercise their own authority to pause awards or obligations, provided agencies do so purely based on their own discretion鈥攏ot as a result of the OMB Memo or the President鈥檚 Executive Orders鈥攁nd provided the pause complies with all notice and procedural requirements in the award, agreement, or other instrument relating to such a pause鈥. (e.g.) agencies remain free to exercise their own discretion under their 鈥渁uthorizing statutes, regulations, and terms,鈥 including any exercise of听discretion to pause certain funding. Additionally, agencies remain free to take action pursuant to the terms of the relevant award or obligation, such as in cases of grantee noncompliance.

CU leadership continues to monitor these matters, assessing impacts and planning next steps as expeditiously as possible. For the latest information and resources, please monitor the university鈥檚:

  • : For campuswide resources
  • : For research and innovation-specific information
  • : For CU System resources, information and updates

For inquiries about specific contracts or grants, please contact your OCG grant or contract officer. 听

NIH Guidance听

as of 2/12/2025

NIH issued the afternoon of Friday, February 7, 2025. This notice reduces the facilities and administration (鈥淔&A鈥 or indirect cost) rate that NIH will fund to 15%, as of Monday, February 10, 2025. There are three related court cases and temporary restraining orders halting implementation of this notice.

91福利社 is doing the following:

  • Proposal submissions. All proposals must be submitted in accordance with 91福利社鈥檚 negotiated (full) F&A rate. Proposals may NOT be submitted at 15%. (Non-standard proposals such as fellowship grants can continue to be submitted in accordance with program notices of funding opportunities.)
  • New awards.听We anticipate new awards to be issued with 91福利社鈥檚 negotiated rate agreement. 听If we receive new awards that reference the 15% F&A rate, such awards will be placed on hold until such time as this issue is resolved. The same is true of any NIH flow-through awards we receive from other institutions that reference the 15% rate.
  • No-cost extensions. The automatic NCE link in eRA Commons has been deactivated. We have not yet received any official explanation from NIH regarding why this is the case. There is a real possibility that NIH will no longer allow us to take a one-time automatic no-cost extension at the end of our period of performance. PIs should not assume that no-cost extension requests will be approved for NIH funded projects. 听
  • Reimbursement. We anticipate current awards to continue using 91福利社鈥檚 negotiated rate agreement. Research Financial Service will draw down funds from NIH at the negotiated rate.

This guidance may change frequently in the coming days and weeks as we learn more. We will keep the research community updated as soon as possible.

Proposals

  • Federal agency submission portals are operational and OCG will continue to facilitate proposal submissions as usual.
  • Sponsor proposal review timelines may be paused or extended during the transition period.

What to Do

  • Proposal deadlines may change. It is highly recommended to reconfirm deadlines for proposals currently under development.
  • Reconfirm that the funding announcements have not been revised or postponed. Consider signing up for alerts from the sponsoring agency, if available.

Awards

  • The terms and conditions of executed, active awards remain enforceable, including the ability to invoice and receive reimbursement. Work should proceed as usual under executed awards. If there are changes to awards, OCG will receive an amendment from the agency for review and execution.
  • Changes to research compliance requirements for current awards are anticipated. These may be implemented at the sponsor level or through an amendment on a project-by-project basis. Swift compliance with any new requirements is important, and failure to do so could jeopardize funding.
  • Changes to award reporting requirements are also anticipated. As with compliance changes, these may be implemented at the sponsor level or through an amendment on a project-by-project basis. Timely compliance with any new requirements is important, and failure to do so could jeopardize funding.
  • If specific programs are terminated or restructured, there could be delays or pauses in payments for existing grants under those programs. While this is rare, it may occur if funding for a program is rescinded or redirected. Federal agencies managing these programs will typically issue guidance on how to proceed. OCG will pass this along promptly if/when received.
  • If a program or initiative is reduced or de-funded, there could be delays or pauses in payments for existing grants under those programs. While this is rare, it may occur if funding for a program is rescinded or redirected.
  • It is not recommended to extend an At-Risk status unless the project is at significant risk of being negatively impacted. If an At-Risk status has already been initiated for your project due to indications from the federal agency regarding an award, ongoing negotiations, or awaiting the next funding increment, it is encouraged to keep your department informed about the potential risks associated with any future funding decision.

What to Do

  • Review your grant or contract agreement: Ensure you understand the terms, especially clauses related to funding availability and reimbursement.
  • Closely monitor budget obligations: Avoid overspending award accounts while waiting for anticipated future funding. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed.
  • Reports and deliverables: Continue to submit required reports and deliverables to your sponsoring agency on time. Prioritize the submission reports or deliverables that may be past due.
  • Monitor policy updates: Keep an eye on announcements from the agency overseeing your grant or contract for funding or compliance updates.

DEIA (Diversity, Equity, Inclusion, and Accessibility) Activities

  • Federal agencies have issued notices to immediately cease all DEIA activities tied to awarded federally funded projects.
  • Affected activities include, but are not limited to:
    • DEI/DEIA plan requirements (eg, DOE鈥檚 Promoting Inclusive and Equitable Research (PIER))
    • Training and reporting
    • Staffing considerations
    • Other direct or indirect award activities
  • Until we have a formal definition of the meaning of 鈥淒EI鈥 and 鈥淒EIA鈥 as referenced in the presidential executive order(s), it is recommended that DEI and DEIA be interpreted broadly. Proposals may have included DEI/DEIA related plans and awarded statements of work may include specific DEI/DEIA work. Both of these may be referenced to identify DEI/DEIA-related work.
  • From agency memorandums and notices:
    • NASA: 鈥淒EIA plan requirement, training, reporting, considerations for staffing, or any other direct or indirect contract or grant activity鈥 are specifically called out by NASA.
    • DOE: 鈥淒iversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; and Community Benefits Plans (CBP) or Promoting Inclusive and Equitable Research (PIER) Plans; and Justice40 requirements, conditions, or principles.鈥
    • "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 diversity, equity, inclusion and accessibility (DEIA) principles and frameworks or violates federal anti-discrimination laws."

What to Do:

  • If you have received a cease-and-desist, stop work order, or communication from the agency (e.g., agency memorandums, notices, etc.), stop all DEIA-related activities on your project immediately.
    • If any subrecipients are performing DEIA-related activities, see Subrecipients section below.
  • Do not apply any further charges to the award for DEIA purposes.
    • Costs and salaries for DEIA activities may be mapped to non-sponsored accounts at the unit鈥檚 discretion.
    • The effective date of DEIA activity charges not being allowed may vary by federal agency. Unless otherwise notified, assume an effective date of January 20, 2025.
  • Ensure that funds previously allocated for DEIA activities remain unspent and are not reallocated to other budget categories.
  • Document actions taken to comply with the new requirements, including communications with subrecipients.
  • Sponsors may issue changes to individual projects. In the case of a sponsor providing a revised statement of work, removing DEIA related activities, work with OCG in communicating with the sponsor about the changes.

Subrecipients

  • In reviewing DEIA related activities of a project, if subrecipient portions of the project include DEIA related activities, PIs should notify the subrecipient PI that those activities must cease immediately and costs for the activities may be unallowable as of January 20, 2025.
  • If a stop work order or termination of a CU award is received, OCG will work with subrecipients on the contractual change.

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the sponsored research at CU听91福利社.

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covering a broad range of topics.

A carefully integrated cyberinfrastructure supports CU听91福利社 research.

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