Federal Transition Updates 2025

Key Guidance for Principal Investigators

While the university continues to monitor the potential impact of federal actions on our research enterprise, we want to ensure that our research community remains supported and prepared in the context of this shifting landscape. To that end, we encourage researchers to continue their research to the extent possible, keeping the following guidance in mind:

F&A Rate for NIH Proposals

• NIH’s F&A rate announcement (NOT-OD-25-068) is the subject of litigation – including a lawsuit that GW has joined as a co-plaintiff. A nationwide temporary restraining order (TRO) has been granted by the U.S. District Court of Massachusetts that prevents federal agencies from implementing or enforcing the change. The TRO is in effect until further notice from the courts. Investigators should continue to utilize GW’s federally-negotiated F&A rate as they develop and submit NIH proposals. Any sponsor requests for changes to GW budgets on proposals or new and existing awards, including any exception to the use of the current federally-negotiated F&A rate, require the approval of a GW authorized representative.

Proposals

• Regularly check sponsor websites to track any changes to solicitation requirements or possible removal or revisions of solicitations (both new and competing continuations).
• Confirm and adhere to all announced proposal deadlines.
• Plan ahead and submit proposals early as some sponsor portals may become unavailable without prior notice.  OSP continues to track the status of federal sponsor portals (e.g., Grants.gov and eRA Commons) and will communicate any known interruptions and outages to the research community.
• Continue to work on proposals following established GW guidelines for proposal development and budget preparation, including guidance on IDC, unless otherwise advised by OSP. 

Certifications

• Promptly forward any request for certification to the Office of Sponsored Projects (OSP) at [email protected]. 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.

Award Terms and Conditions

• Carefully examine award terms and conditions to ensure you understand any new terms, particularly any that concern funding availability and prior approvals.

Sponsor Stop-Work Orders, Notices and Communications

• Immediately forward any stop-work orders, sponsor notices or other relevant communications from your sponsor to OSP at [email protected]. OSP will provide responses to any sponsor orders and notifications received as required.

Award Management

• Continue with planned activities unless otherwise notified (e.g., by a sponsor or OSP).
• Adhere to all previously announced deadlines for progress and annual reports. Before submission, please review carefully for any new terms or certifications that have been added within sponsor reporting portals, and contact OSP before submitting reports.
• Please allow time to receive grantor/sponsor approved no cost extensions and other sponsor prior approvals. Please ensure required prior approvals are in place before implementing the requested changes.
• Bring to the attention of your associate dean for research (ADR) any component of the sponsored project that you believe might be impacted under the Executive Actions referenced below.

Monitor Budget Balances

• Please make sure all allowable expenses are posted in a timely fashion, to help avoid delays in invoicing or reporting.
• We encourage prudent spending of non-compensation grant funds to ensure that funds remain to cover compensation expenses. We do not anticipate any immediate disruptions to payroll, particularly research staff compensation.

Continuations

• If you are expecting non-competing continuations, please consult with your research support team (RST) and associate dean for research on how to proceed. Monitor your obligated budget balances to avoid deficits while awaiting future funding.

Project Specific Assistance

• If you have questions regarding impact of federal guidance on your specific project, engage OSP and ADR for additional guidance.

Impacts of Executive Actions on Other GW Programs

• For all other activities (i.e., if your project is not a federally-funded sponsored project), promptly forward all requests for certification, federal directives and other questions to [email protected]. Individuals should not make any institutional or project-level certifications. All queries will be routed to the appropriate units for review.

Access to Federal Agency Data for Your Research

The Research Data Management (RDM) Task Force is a collaboration between Libraries and Academic Innovation, Himmelfarb Health Sciences Library, GW Information Technology, the Office of the Vice Provost for Research, and the Office of Ethics, Compliance, and Risk. RDM is coordinating with a number of external organizations and GW departments to ensure long-term stability and preserve access to critical research data. If you have questions about data initiatives at GW or need support accessing or preserving data, contact them at [email protected].

• Data Preservation Efforts and Data Sources (GW Libraries)

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:

• 1/24/2025 - Enforcing the Hyde Amendment
• 1/21/2025 - Ending Illegal Discrimination and Restoring Merit-based Opportunity
• 1/20/2025 - Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government
• 1/20/2025 - Ending Radical And Wasteful Government DEI Programs And Preferencing
• 1/20/2025 - Unleashing American Energy
• 1/20/2025 - Putting America First in International Environmental Agreements
• 1/20/2025 - Reevaluating and Realigning United States Foreign Aid
• 1/20/2025 - Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats

Federal Agency Announcements

• National Institutes of Health (NIH): Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (2/7/2025)
• US Department of Energy (DOE): Notice of Court Order- Temporary Restraining Order (TRO)  (2/3/2025)
• National Science Foundation (NSF): NSF Implementation of Recent Executive Orders (1/28/2025)
• US Department of Energy (DOE) Office of Science: Executive Order update to Promoting Inclusive and Equitable Research (PIER) Plan requirement (1/27/2025)
• United States Agency for International Development (USAID): Notice on Implementation of Executive Order: Reevaluating and Realigning United States Foreign Aid (1/24/2025)

Federal Agency Communications with GW

Agencies have been issuing stop-work orders or other communications directly to institutions. Principal investigators (or project staff) with active awards should immediately forward any stop-work orders or other relevant notices received directly from a funding agency to the Office of Sponsored Projects at [email protected]. Please coordinate with your pod staff and OSP Post-Award staff, who will provide guidance regarding how PIs must implement any orders, and will transmit any needed follow-on communications to the funding agencies.

GW Announcements

• 1/30/2025 - University Industry Demonstration Partnership (UIDP) OMB Freeze Order Memorandum (Contains information on recent orders, policy explanations, and potential impacts)
• 1/27/2025 - COGR: 2025 Administration Transition Information & Resources (Contains Executive Orders, Department/Agency Directives, and relevant news articles. Will be updated regularly.)