Federal Funding and Regulatory Updates

Pause On Federal Grants

2/10/25: The federal judge in the Rhode Island District Court issued a followup order reiterating that the initial TRO remains valid and "must be complied with promptly."

1/31/25: Two federal judges in the Rhode Island District Court and Washington D.C. District Court issued temporary restraining orders (“TROs”) suspending federal agencies’ ability to terminate the impacted research activities. The Department of Justice summarized the notice for agencies, stating that “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’s recently issued Executive Orders.” In light of this update, the prior agency directives we communicated to you are temporarily paused and grantees may resume the activities that they were previously directed to stop.

Please note that a TRO has a temporary effect and that the judges in these cases are actively hearing arguments regarding whether they should remain in place. In addition, federal agencies have been tasked to examine all grants to ensure that funds are used in compliance with Federal law. Therefore, it is possible that agencies may exercise their own authority to pause, amend, or terminate certain activities in the future. 

1/29/25: OMB Memorandum M-25-14 was released, rescinding M-25-13.

1/28/25: A followup memorandum with related guidance to M-25-13 was issued.

Before the pause could take effect, a federal judge temporarily blocked instructions contained within the OMB memo (as outlined above) based upon challenges by multiple non-profit groups and states.

1/27/25: OMB Memorandum M-25-13 was released that instructs federal agencies to temporarily pause all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders, including, but not limited to, "financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal". Effective January 28, 2025 at 5pm, agencies must pause: (i) issuance of new awards; (ii) disbursement of Federal funds under all open awards; and (iii) other relevant agency actions to the extent permissible by law.

Agencies must complete a comprehensive analysis of all of their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders. By Feb 10, agencies must submit to OMB detailed information on any programs, projects or activities subject to the pause. OMB will review and provide guidance to the agencies. To the extent permissible by law, agencies are instructed to cancel awards already awarded that are in conflict with Administration priorities.

At this time, we do not know which programs will be subject to this pause or cancelation. We are closely monitoring this situation.

Guidance by Department

• National Endowment for the Humanities (NEH)
  • On Wednesday, Mar 5, the NEH updated their website with information to "comply with all judicial rulings that result from any such litigation... challenging the legitimacy of any Executive Orders."
  • On Tuesday, Feb 11, the NEH updated their website with information to "comply with recent Administration Executive Orders". "As required by the Administration’s Executive Orders, NEH awards may not be used for the following purposes:  
    • promotion of gender ideology;  
    • promotion of discriminatory equity ideology;  
    • support for diversity, equity, and inclusion (DEI) or diversity, equity, inclusion, and accessibility (DEIA) initiatives or activities; or  
    • environmental justice initiatives or activities."
• National Institutes of Health (NIH)
  • On Wednesday, Mar 5, Judge Angel Kelley of the United States District Court for the District of Massachusetts issued a preliminary injunction halting the implementation, application, or enforcement of the National Institutes of Health’s February 7 supplemental guidance imposing a cap of 15% on F&A costs. The injunction applies to all institutions nationwide. The injunction follows a hearing held on February 21, 2025, during which both the government as well as representatives from separate lawsuits filed by AAU, APLU, ACE, 12 member universities, and one university system; the Association of American Medical Colleges; and 22 state attorneys general presented arguments concerning the motion for preliminary injunction. The government is expected to appeal the decision.
  • NIH’s role in sustaining the US economy: 2024 update. This infographic explains how the National Institutes of Health is a catalyst for innovation and economic growth and a source of hope to patients and families affected by disease. Failure to robustly fund the NIH now will have a negative impact on U.S. leadership in biomedical research and innovation and the benefits that has on our health and economy.
  • On Friday, Feb 7, the NIH issued a statement the effective immediately "there will be a standard indirect rate of 15% across all NIH grants for indirect costs in lieu of a separately negotiated rate for indirect costs in every grant." This impacts any new grants issued as well as existing grants.
  • On Monday, Feb 10, the Association of American Medical Colleges (AAMC) filed a lawsuit challenging this order. A temporary restraining order was granted later that day.
• Department of Health and Human Services (HHS)
  • Pause on external communications through Feb 1, 2025 (1/21/25)
  • Alerts from HHS Payment Management Services (1/27/25)
    • Payment Delays: Due to Executive Orders regarding potentially unallowable grant payments, PMS is taking additional measures to process payments. Reviews of applicable programs and payments will result in delays and/or rejections of payments
    • Cancellation & End of Fiscal Year 2025 Payment Processing Deadlines: Awards funded from 2020 fixed appropriation will cancel on September 30, 2025. Undrawn award funding issued from 2020 fixed appropriation account funds will no longer be available for program expenditures, obligations or payment requests in the Payment Management System
• Department of Energy (DOE)
  • Awarding grants and announcing funding opportunities is paused until further notice while a review of DOE activities is conducted. (1/21/25)
    
• Department of Agriculture (USDA)
  • All National Institute of Food and Agriculture Requests for Applications are under review. (1/22/25)
• National Aeronautics and Space Administration (NASA)
  • Requires NASA contractors and grantees to immediately cease and desist all DEIA activities required of NASA contracts or grants (1/23/25)
    
• Agency for International Development (USAID)
  • Awarding grants and announcing funding opportunities is paused until further notice while a review is conducted. (1/24/25)
• National Institute of Justice
  • At this time, NIJ has cancelled all previously posted Notices of Funding Opportunity and associated webinars.Check back to NIJ.OJP.gov and Grants.gov to keep up to date on future NOFO and webinar postings. (1/27/25)
• National Science Foundation
  • NSF review panels were cancelled on Monday Jan 27, 2025. On January 28th, they released a statement that, "all review panels, new awards, and all payments of funds under open awards will be paused as the agency conducts the required reviews and analysis" outlined by the OMB memo. They have also created an executive order implementation webpage to ensure the widest dissemination of information and updates. (1/27/25)
• Health Resources and Services Administration (HRSA)
  • the HRSA sent an email to award recipients on January 31, 2025 stating that "HRSA grant funds may not be used for activities that do not align with Executive Orders (E.O.)".
  • On February 5, 2025, the HRSA sent a followup email rescinding that communication.

2/24/25: This slideshow describing Direct Costs and F&A was presented at a faculty town hall.

2/10/25: the Association of American Medical Colleges (AAMC) filed a lawsuit challenging this order. A temporary restraining order was granted later that day.

2/7/25: the National Institutes of Health (NIH) issued a statement the effective immediately "there will be a standard indirect rate of 15% across all NIH grants for indirect costs in lieu of a separately negotiated rate for indirect costs in every grant." This impacts any new grants issued as well as existing grants.

Research Communications

Communication across the university’s research enterprise is essential to ensure continuity of Emory’s research enterprise. The Office of SVPR will partner with the SVPR Research Council, which includes research leaders from each school and college, to provide guidance about the federal budget, grant-seeking, and new opportunities as actionable information becomes available. Faculty are encouraged to maintain contact with their unit’s research leadership.

The Office of SVPR will continue to transparently share monthly reports about Emory’s proposals, awards, and other indicators. A suite of reports is accessible on the Research Data Analytics webpage.

Emory Leadership Communications

Teams from across Emory are monitoring and responding to new federal directives and policy changes that affect our work. View updates from university leaders including a note from President Fenves.

• Grant Forward. Identifying alternative funding sources for research will be critical for many investigators. The Office of Research Development manages the university’s subscription to Grant Forward. Faculty are encouraged to create a profile and utilize this service to consider new funders. A quick start guide for using Grant Forward is available here.
• Private Funding. The Office of Corporate and Foundation Relations is available to discuss alignment with potential private funders. This office also manages the university’s subscription to the Foundation Directory
• Internal Funding. The Office of Research Development maintains a list of all internal funding sources available to Emory researchers, which is available here. There are 42 internal funding opportunities, more than half of which are open to researchers from all academic units

• Continue to prepare federal proposals
• Some solicitations have been revised. We encourage faculty to read all solicitations carefully. Revisions, especially deletions, may or may not be highlighted. Reconfirm that you are working with the latest solicitation and review it very closely while preparing your proposal
• Be aware that due dates may change, and some funding opportunities may close or be postponed. The normal cycle of awards may be impacted

• Please be aware of Emory’s Provisional Award Number (PAN) process. A PAN may be requested by a Principal Investigator for the purposes of initiating a sponsored project and incurring expenses prior to the institution's receipt, acceptance, and processing of the award when the award contractual information is forthcoming to Emory.
  
• As per policy, this process is coordinated with the department, unit, and school to assess the need for a PAN and to evaluate the risks for setting up a PAN and supporting a project prior to finalization of the contractual commitment.

• Ensure you understand the terms, especially clauses related to funding availability and reimbursement, by reviewing your grant agreement, touching base with your RAS contact, or reaching out to the Office of Sponsored Programs
• In coordination with your research administrator, monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed
• Complete timelysubmissions any RPPRs, technical reports, or deliverables
• The terms and conditions of your executed award remain enforceable so long as your award is active. This includes the ability to invoice and receive reimbursement. Please continue with business as usual. If there is a change to your award, Emory’s Office of Sponsored Programs will receive an amendment that will be shared with youfor review and execution
• If you are a PI and receive a stop-work order directly from a funding agency or prime awardee, please forward it immediately to the Office of Sponsored Programs (OSP) at osp@emory.edu. OSP will provide guidance regarding how PIs must implement the order and will transmit any needed follow-up communications to the funding agency.

Make America Healthy Again Commission (2/13/2025)

Please see the Council on Government Relations website for a full list of government actions impacting higher education.