Federal Research Updates

While the university monitors the potential impact of federal actions on our research enterprise, we will post updates to this webpage and provide guidance and resources via email. Sign up to receive updates from the Office of the Vice Provost for Research.

Recent Updates

The Office of Management and Budget (OMB) has released the anticipated proposed updates to the Uniform Guidance at 2 CFR Part 200. Please take the time to review information pertaining to these changes below. A 45-day public comment period is open until July 13, 2026.
The National Institutes of Health (NIH) have issues a proposed rule limiting the number of Research Project Grants (RPGs) an individual can simultaneously serve on as Principal Investigator (PI) or Multi-Principal Investigator (MPI). Comments on the proposed rule should be submitted no later than August 3, 2026. Please see the 2026 Federal Updates section below for more information.
The National Aeronautics and Space Administration (NASA) has announced that starting August 5, 2026, “covered individuals” on federal financial assistance awards (grants and cooperative agreements applicants/recipients), must certify to NASA they have taken research security training prior to submission of proposals. Please see the 2026 Federal Updates section below for more information.

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OMB's Proposed Rule on Federal Grantmaking

Background

The Office of Management and Budget (OMB) recently published a proposed rule, Regulation for Federal Financial Assistance, that would fundamentally alter the way federal grants are awarded, administered, and overseen across federal agencies. The rule proposes revisions to several parts of Title 2 of the Code of Federal Regulations (2 CFR 200), also known as the Uniform Guidance (UG), which is the primary federal framework governing uniform administrative requirements, cost principles, and audit requirements for federal grants and cooperative agreements. If implemented as proposed, the rule would represent one of the most significant shifts in federal research administration in decades, with substantial implications for how investigators and institutions apply for, manage, and sustain federally funded research projects.

The university is working in close coordination with our peers and our national higher education partners, including the Association of American Universities (AAU), the Association of American Medical Colleges (AAMC), the Council on Governmental Relations (COGR), and the American Council on Education (ACE), among others. We are deeply engaged in assessing the potential impacts on our research community and preparing a coordinated institutional response. In addition, individual comments from the academic research community can be especially valuable when they include concrete examples of how the proposed changes would affect ongoing or planned research activities. We have provided information below as a resource for GW community members who wish to submit comments on their own behalf.

Highlights of the Proposed Changes

Based on an initial analysis conducted by AAU, COGR, and the Association of Public and Land-Grant Universities (APLU), the proposed rule includes more than 300 revisions, with some notable changes:

Minimizing Peer Review in Federal Funding Decisions – Under the proposed rule, peer review of submitted proposals would become advisory, and agencies would be directed to consider subjective factors such as institutional direct cost rates, perceived "questionable practices,” and alignment with administration priorities, among others. All discretionary grants would require pre‑issuance review by senior political appointees.
Expanded Authority to Suspend or Terminate Awards – Agencies would be able to terminate grants “for convenience” if an award is deemed inconsistent with evolving agency priorities or the national interest. The proposal also removes the ability to appeal such terminations.
Restrictions on Allowable Costs – The proposal would significantly narrow the types of costs that can be charged to federal awards, including: publication costs and many open‑access fees; subscriptions to academic and professional journals; conference participation unless expressly approved; and memberships in professional organizations unless required for the award.
New Restrictions on International Collaboration – The proposal requires federal agencies to apply a "domestic‑first framework, under which international elements may be included only if the Federal agency determines that such elements are justified, consistent with program objectives, and in the national interest of the United States."
Elimination of Most Fixed‑Amount Awards and Subawards – The proposal would largely eliminate fixed‑amount mechanisms unless specifically authorized by statute, increasing administrative burden and reducing flexibility in managing subawards.

Opportunity to Submit Individual Comments

The proposed rule is open for public comment until 11:59 PM EDT on July 13, 2026. The notice states that the final regulation will be effective October 1, 2026.

If you wish to submit a comment on your own behalf, you may do so through the Regulations.gov website. Investigators may wish to comment on potential impacts on their research programs; effects on collaboration, publication, or data management practices; administrative or financial burdens introduced by the proposed revisions/changes; or implications for student training, workforce development, or long‑term research planning.
The summary of key issues for immediate attention authored by AAU, COGR and APLU provides additional context on the proposed rule.
Regulations.gov has published guidance on submitting effective public comments.

Faculty who wish to pursue additional avenues of engagement are encouraged to consult with the Office of Government and Community Relations team by emailing ogcrgwu [dot] edu (ogcr[at]gwu[dot]edu).

Resources

Resources to help the community understand the proposed changes are listed below.

Blog Post: COGR- OMB Proposed Rule on Uniform Guidance- Immediate Considerations for Research Institutions
Webinar Recording: Attain Partners- Uniform Guidance 2 CFR 200 - May 2026 Updates

2026 Federal Research Updates

NIH Proposal to Cap the Number of Simultaneous Research Project Grants Per Principal Investigator

On June 8, 2026 NIH released Guide Notice NOT-OD-26-086 which solicits public input on the outline for a proposed policy that would cap the number of Research Project Grants (RPGs) an individual can simultaneously serve on as Principal Investigator (PI) or Multi-Principal Investigator (MPI). Comments on this notice can be submitted electronically and must be received no later than August 3, 2026.

Current and Upcoming National Science Foundation Research Updates will appear in this tab.

Current and Upcoming Department of Energy Research Updates will appear in this tab.

Current and Upcoming Department of Defense Research Updates will appear in this tab.

Coming August 5, 2026: NASA Requirements for Research Security Training and Use of Common Forms

On February 5, 2026, NASA Grants Policy and Compliance released a Grant Information Circular (GIC) 26-02 on NASA Research Security Training Requirements. In short, GIC 26-02 states that starting August 5, 2026, “covered individuals” on federal financial assistance awards (grants and cooperative agreements applicants/recipients), must certify to NASA they have taken research security training prior to submission of proposals. This training requirement and certification does not apply to civil servants and contractors who propose to or are funded by NASA.

Potential proposers for NASA financial assistance funding are encouraged to take the training (see second bullet point below) well in advance of the NASA proposal due date.

Who must take the training? Any Principal Investigator (PI) (regardless of level of effort), any Co-PI (regardless of level of effort), and Co-Investigators (Co-I) proposing to spend ten percent or more of their time in any given year on a NASA-funded federal financial assistance award (grant or cooperative agreement).
What training will satisfy this requirement? Information on taking a research security training course through CITI to satisfy these requirements is available through the GW Office of Research Integrity and Compliance.
How does one demonstrate having taken training? Covered individuals on proposals will use NASA’s soon to be updated Biographical Sketch and Current and Pending (Other) Support forms. For active federal financial assistance awards, submit updated forms for covered individuals as part of the regularly scheduled annual progress reports if those progress reports are due on or after August 5, 2026.

Questions may be directed to: hq-dl-grants-policy-compliancemail [dot] nasa [dot] gov (hq-dl-grants-policy-compliance[at]mail[dot]nasa[dot]gov) and hq-researchrecuritymail [dot] nasa [dot] gov (hq-researchsecurity[at]mail[dot]nasa[dot]gov).

2025 Federal Research Updates Archive

Select Executive Actions

While some executive actions are subject to pending litigation or may be subject to a temporary restraining order, PIs should continue working according to the existing terms of their awards unless they have received updated guidance from sponsoring agencies.

The following executive actions are most likely to inform federal agencies as they review solicitations and existing awards:

08/07/2025 - Improving Oversight of Federal Grantmaking
05/23/2025 - Restoring Gold Standard Science
05/05/2025 - Improving the Safety and Security of Biological Research (Fact Sheet)
01/24/2025 - Enforcing the Hyde Amendment
01/21/2025 - Ending Illegal Discrimination and Restoring Merit-based Opportunity
01/20/2025 - Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government
01/20/2025 - Ending Radical And Wasteful Government DEI Programs And Preferencing
01/20/2025 - Unleashing American Energy
01/20/2025 - Putting America First in International Environmental Agreements
01/20/2025 - Reevaluating and Realigning United States Foreign Aid
01/20/2025 - Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats

Federal Agency Announcements

NIH Policy Notice: Interim Guidance on Reopening of NIH Extramural Activities (11/14/2025)

On November 14, 2025, NIH released a guide notice (NOT-OD-26-005) that details the NIH return to operations following the federal government shutdown. This guide notice announces that:

NIH will be rescheduling all October and November grant application submission deadlines (specific dates to be announced in a future notice);
Peer review meetings that were scheduled to take place between October 1 and November 14 have been cancelled and will be rescheduled, details to come; and,
Council meetings that were scheduled to take place between October 1 and November 14 were cancelled and will be rescheduled, details to come.

The guide notice also announces that eRA system employees are currently reviewing service desk ticket requests from entities and individuals that needed assistance with login and passwords during the federal government shutdown. eRA staff will address the tickets on a first come, first serve basis.

Finally, the notice announces that email reminders and submission confirmations for the submission of Research Performance and Progress Reports (RPPRs), Federal Financial Reports, etc. were held during the shutdown and will be sent out in the coming weeks. If any reports were submitted during the government shutdown, no additional action is required unless contacted directly by NIH staff.

NIH Policy Notice: Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects (07/18/2025)

On July 18, 2025, NIH released an additional guide notice (NOT-OD-25-130) that provides an alternate approach for removing the foreign subawards from existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) at the foreign site. For applications submitted before May 1, 2025, and projects active on or before May 1, 2025, this guide notice allows NIH Institutes, Centers, and Offices (ICOs) to renegotiate the award structure with a recipient such that foreign subawards are financially removed from the primary award and awarded as administrative supplement (i.e., Type 3) awards. Each foreign supplement award will only include funds allocated for a single foreign entity. This supplement option is in addition to, and not in lieu of, the other options outlined in the original guide notice (NOT-OD-25-104) and is meant to be a short-term solution permitted only for the current competitive segment. It does not replace the new award structure.

NIH Policy Notice: Guidance on Appropriate Use of AI for Research Applications and Potential Research Misconduct for Non-Compliance (07/17/2025)

Citing NIH Grants Policy Statement (GPS) Section 2.1.2, NIH reaffirmed its expectation that institutions and affiliated research teams propose original ideas for funding. Per NOT-OD-25-132, released on July 17, 2025 and effective for applications submitted to the September 25, 2025, receipt date and beyond, NIH will not consider applications that are substantially developed or contain sections substantially developed by AI. If inappropriate use of AI is detected postaward, NIH may refer the matter to the Office of Research Integrity for research misconduct determination and impose enforcement actions including, but not limited to, disallowing costs, withholding future awards, wholly or in part suspending the grant, and possible termination.

Additionally, NIH set a limit of six new, renewal, resubmission, or revision applications for PI/PD, or multiple PI/PDs in a calendar year, for all activity codes except for T and R13 applications.

DoD Policy Memorandum: Implementation of a 15% Indirect Cost Cap on Assistance Awards to Institutes of Higher Education (06/12/2025)

On June 12, 2025, the Department of Defense (DoD) released a memorandum implementing a 15% cap on facilities and administrative (F&A) rates on all new grants to institutions of higher education. For existing grants, DoD directed its components to renegotiate F&A rates where possible to comply with the announced 15% cap. The effective date of this policy notice is June 12, 2025.

On June 16, 2025, AAU, APLU, ACE and 12 research universities filed a lawsuit contesting the cutting of F&A reimbursement rates for DoD grants. On June 17, 2025, a nationwide temporary restraining order (TRO) was granted by the U.S. District Court of Massachusetts that prevents DoD from implementing or enforcing the change. On July 1, 2025, the TRO was extended for an additional 14 days or until further order of the Court. On July 18, 2025, a preliminary injunction was granted by the court which prevents DoD from implementing the announced 15% F&A rate cap for all awards issued on or after June 12, 2025.

On October 10, 2025, a summary judgement was issued by the court, barring DoD from implementing this change. Judge Brian E. Murphy wrote that the policy “is invalid; was contrary to law; and was arbitrary and capricious.” The ruling gives the Trump administration 60 days to file an appeal and applies to “all institutions in all states nationwide in the case filed by AAU, APLU, ACE and 12 impacted higher education institutions against the U.S. Department of Defense.”

GW leadership is monitoring this situation closely as it develops. At this time, PIs should continue to utilize the university's federally-negotiated indirect cost rates on existing awards and as they develop and submit DoD proposals. Immediately forward any sponsor notices or other relevant communications from DoD (or other sponsors) to the Office of Sponsored Projects (OSP) at osrgwu [dot] edu. OSP will provide responses to any sponsor orders and notifications received as required.

NIH Policy Notice: Early Expiration of Notices of Funding Opportunities Related to the Simplified Review Framework for NIH Research Grant Applications (05/15/2025)

On May 15, 2025, the National Institutes of Health (NIH) released a guide notice announcing the expiry of NOFOs that were not expired or reissued as indicated in the implementation plan outlined in NOT-OD-24-085. The NOFOs listed in the new guide notice will expire at the end of the current application cycle (May 24, 2025).

NIH will accept R01, R21 and R34 continuous submission applications intended for the standard May 7, 2025 AIDS due date through June 1, 2025 (end of the standard continuous submission receipt period). No applications for due dates on or after May 25, 2025 will be accepted.

The full list of NOFOs and the entire guide notice are available on the NIH website.

NIH Policy Notice: Updated NIH Processes for No-Cost Extensions (05/07/2025)

On May 7, 2025, the National Institutes of Health (NIH) released a guide notice announcing that the no-cost extension (NCE) functionality in eRA Commons has been temporarily disabled. At this time, all requests for NCEs must be submitted as a prior approval request in eRA Commons, for NIH review and approval. Prior approval requests are handled by the Office of Sponsored Projects. Please contact the OSP Award Management team by emailing osp_postawardgwu [dot] edu (osp_postaward[at]gwu[dot]edu) with questions about prior approval requests.

NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate (05/02/2025)

On May 2, 2025, the National Science Foundation (NSF) released a notice implementing a 15% cap on facilities and administrative (F&A) rates on all grants to institutions of higher education (IHEs). The effective date of this policy notice was May 5, 2025. On May 5, 2025, AAU, APLU, ACE and 13 research universities filed a lawsuit contesting the cutting of F&A reimbursement rates for NSF grants and cooperative agreements.

On June 20, 2025, a summary judgement was issued by the the U.S. District Court for the District of Massachusetts in favor of AAU, APLU, ACE and 13 research universities. The judgement determined that the NSF policy notice introducing the 15% cap on F&A rates is “invalid, arbitrary and capricious, and contrary to law.” In compliance with the court’s decision, NSF has stated that it will not implement the policy at this time.

Accordingly, PIs should continue to utilize the university's federally-negotiated indirect cost rates on existing awards and as they develop and submit NSF proposals. Immediately forward any sponsor notices or other relevant communications from NSF (or other sponsors) to the Office of Sponsored Projects (OSP) at osrgwu [dot] edu (osr[at]gwu[dot]edu). OSP will provide responses to any sponsor orders and notifications received as required.

NIH Policy Notice: New NIH Foreign Subaward Structure (05/01/2025)

On May 1, 2025, the National Institutes of Health (NIH) issued a guide notice (NOT-OD-25-104) updating NIH policies and practices related to utilizing foreign subawards. Effective with the issuance of the notice, and until NIH releases the new award structure for foreign collaborators, NIH:

will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity; and,
will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.

Notices of Funding Opportunities (NOFOs) that state that foreign components are allowed are superseded by this notice and will be revised to reflect the new award structure.

On May 7, 2025, NIH published a news article that covers the guide notice in more detail, including discussion on potential outcomes related to awards with foreign subawards under the new guidance

GW leadership is reviewing the guide notice closely and will determine if there are any changes to existing policies and procedures required to comply with this NIH guide notice. The Office of Sponsored Projects (OSP) team will be reaching out to PIs with affected awards to schedule meetings to discuss the impact and next steps. PIs should continue working according to the existing terms of their awards unless they have received updated guidance from OSP. NIH anticipates implementing the new award structure by no later than September 30, 2025. PIs working on NIH proposals for submission ahead of that date should contact OSP for additional guidance. Investigators should continue to promptly forward any request for changes in their awards to OSP at osrgwu [dot] edu (osr[at]gwu[dot]edu). Individuals should not confirm any changes to project activities or make any institutional or project-level certifications. OSP will review all requests for certifications and follow up with sponsors for additional guidance.

NIH: Notice of Civil Rights Term and Condition of Award Language (4/21/2025) [Rescinded 6/12/2025]

On June 12, 2025 NIH issued Guide Notice NOT-OD-25-124 which rescinds Guide Notice NOT-OD-25-090, "Notice of Civil Rights Term and Condition of Award Language." NIH is awaiting further federal-wide guidance and will provide a future update to the extramural community. The previous guidance is no longer in effect.

The previous guide notice, issued on April 21, 2025, announced a new term and condition that modified the terms and conditions for all NIH grants, cooperative agreements, and other transaction (OT) awards. Recipients of grant awards were expected to certify that:

"they do not, and will not during the term of this financial assistance award, operate any programs that advance or promote DEI, DEIA or discriminatory equity ideology in violation of Federal anti-discrimination laws”’ and,
"they do not engage in, and will not during the term of this award engage in, a discriminatory prohibited boycott.”

This guidance is no longer in effect.

Investigators should continue to promptly forward any request for certification to OSP at osrgwu [dot] edu (osr[at]gwu[dot]edu). Individuals should not make any institutional or project-level certifications. OSP will review all requests for certifications and follow up with sponsors for additional guidance.

DOE: Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE) (4/11/2025)

A January 27, 2026 Department of Energy (DOE) Policy Flash states that its earlier Policy Flashes limiting indirect cost rates are no longer in effect. The Policy Flash explains that the Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act of 2026, H.R. 6938, was signed into law January 23, 2026 and that its Section 313, “states that DOE is required to apply the indirect cost rates, as described in 2 CFR 200.414, including with respect to the approval of deviations from negotiated indirect cost rates to the same extent and the same manners that was applied in fiscal year 2024.”

Previously, on June 30, 2025, a federal judge in the District of Massachusetts entered an appealable order vacating Policy Flash PF 2025-22 in its entirety. This halted efforts by the DOE to limit indirect cost rates.

At this time, PIs should continue to utilize the university's federally-negotiated indirect cost rates on existing awards and as they develop and submit DOE proposals. Immediately forward any sponsor notices or other relevant requests from DOE (or other sponsors) to the Office of Sponsored Projects (OSP) at osrgwu [dot] edu (osr[at]gwu[dot]edu). OSP will provide responses to any sponsor orders and notifications received as required.

NIH: Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (2/7/2025)

On January 5, 2026, the U.S. Court of Appeals for the First Circuit upheld a district court's decision to permanently enjoin and vacate guidance published by the National Institutes of Health (NIH) early last year which would have imposed a flat, 15% indirect cost rate on NIH-funded research (see guide notice NOT-OD-25-068). Although NIH could seek U.S. Supreme Court review of the First Circuit’s decision, for now this decision confirms that research institutions will continue receiving reimbursement for essential F&A costs at their previously negotiated, institution-specific rates. GW investigators should continue to utilize the university's federally-negotiated indirect cost rates as they develop and submit NIH proposals. Any request by a sponsor to apply a rate different than GW's federally-negotiated rate will require review and approval by a GW authorized representative.

DOE: Notice of Court Order- Temporary Restraining Order (TRO) (2/3/2025)

On January 31, 2025 a Temporary Restraining Order was issued.

NSF: NSF Implementation of Recent Executive Orders (1/28/2025)

This page provides information regarding recent executive orders and their impact on the U.S. National Science Foundation community.

DOE: Executive Order update to Promoting Inclusive and Equitable Research (PIER) Plan requirement (1/27/2025)

The U.S. Department of Energy Office of Science issued a notice on January 27, 2025 announcing that it is immediately ending the requirement for Promoting Inclusive and Equitable Research (PIER) Plans in any proposal submitted to the Office of Science.

USAID: Notice on Implementation of Executive Order: Reevaluating and Realigning United States Foreign Aid (1/24/2025)

The United States Agency for International Development (USAID) issued a notice on January 24, 2025 announcing that it is is pausing all new obligations of funding, and sub-obligations of funding under Development Objective Agreements (DOAGs), pending a review of foreign assistance programs funded by USAID.

GW Announcements

GW Weekly Federal Updates (03/13/2025-Current)- "GW Weekly Federal Update"
03/21/2025 - "Federal Research Funding Guidance for Investigators" from Provost Christopher Alan Bracey and Interim Vice Provost for Research Robert H. Miller
03/14/2025 - "GW's Continuing Response to Executive Actions"
03/12/2025 - "Reminder: Forward Any Communications from Federal Agencies to Office of Sponsored Projects" from Interim Vice Provost for Research Robert H. Miller
03/6/2025 - "Safeguarding Access to Research Datasets" from Dean Geneva Henry and Interim Vice Provost Robert H. Miller
02/11/2025 - "Continue Using GW’s Federally-Negotiated Indirect Cost Rate" from Interim Vice Provost for Research Robert H. Miller
02/11/2025 - "GW Joining Lawsuit Opposing Proposed Changes to NIH Funding" from President Ellen M. Granberg and GW Leadership
02/10/2025 - "Addressing Proposed Changes to NIH Research Funding" from President Ellen M. Granberg and GW Leadership
02/7/2025 - "Updates to Guidance Regarding Research Activities and Funding" from Interim Vice Provost for Research Robert H. Miller
01/29/2025 - "Additional Guidance Regarding Research Activities and Funding" from Provost Christopher Alan Bracey, Exec. V.P., CFO, and Treasurer Bruno Fernandes, and Interim Vice Provost for Research Robert H. Miller
01/28/2025 - "Research Guidance Regarding Executive Actions" from Provost Christopher Alan Bracey and Interim Vice Provost for Research Robert H. Miller
01/27/2025 - "Addressing Recent Executive Actions" from GW President Ellen M. Granberg

Association Resources

01/30/2025 - University Industry Demonstration Partnership (UIDP) OMB Freeze Order Memorandum (Contains information on recent orders, policy explanations, and potential impacts)
01/27/2025 - COGR: 2025 Administration Transition Information & Resources (Contains Executive Orders, Department/Agency Directives, and relevant news articles. Will be updated regularly.)