We are closely monitoring potential changes to how federal awards may be awarded, amended and/or discontinued. Information and guidance is being updated on a near daily basis.

Contents

Updated 5/19/2025

Introduction

The President’s recently issued Executive Orders resulted in federal agency policy changes, notifications to pause work, terminate awards, and take other administrative actions. There have been several challenges to these Executive Orders and agency actions, resulting in court decisions that may impact administration of federal funding. In particular, a Temporary Restraining Order (TRO) was issued directing Federal grant-making agencies not to pause or terminate awards and obligations on the basis of the Executive Orders. On February 10th, the Court granted a Motion to Enforce in full. An appeal to the TRO was denied.

Any PIs receiving agency communications related to specific award changes should create an OSP &GCA Award Modification in SAGE, and then forward these to the Office of Sponsored Programs (OSP), emailing osp@uw.edu, along with the MOD#.

The Office of Research is tracking select federal court decisions, links and memos.

Proposals

Sponsor Systems

All federal agency submission systems are operational at this time. Check your funding announcement for any revisions or updates, including updated terms and conditions or the opportunity expiration date.

Indirect Cost Rate

Use UW’s federally negotiated indirect cost (IDC) rates until further notice. Any opportunity that includes an IDC cap will be scrutinized. Review select specific agency information:

  • National Institutes of Health (NIH): NIH issued an IDC cap policy. This IDC cap policy is under a preliminary injunction. Use UW’s federally negotiated rate.
  • National Science Foundation (NSF): 5/19/2025 Update – While NSF pauses implementation of the 15%IDC cap, UW will submit proposals to NSF opportunities using UW’s current negotiated rates.
  • Department of Energy (DOE): DOE issued an IDC cap policy that is under a Temporary Restraining Order (TRO). Use UW’s federally negotiated rate.

Make sure to include in the eGC1 all communicated requirements from a sponsor.

Always list the relevant URL for the Request For Proposal (RFP) in the eGC1.

Terms and Conditions

Watch for inclusion of new grantee eligibility requirements, terms and conditions and other requirements premised on executive orders. In accordance with UW Executive Order 34, as the authorized signing official and as delegated by the Vice Provost for Research, only OSP approves, signs, and transmits proposals to sponsors on behalf of the University of Washington.

Proposals with Foreign Subrecipients

NIH is not issuing awards (new, renewal or non-competing continuation), that include a subaward to a foreign entity. A new award structure, with a subproject model, will be implemented by October. To increase the chance of success, we strongly encourage waiting to submit any proposal to NIH that includes a foreign entity, until we learn more about this structure (e.g. after June/July proposal Cycle). More information is available on our NIH FAQs May 2025 page.

Post Submission

Various federal agencies are assessing funding priorities and making adjustments in operations in response to executive orders and directives. We are aware that there are severe delays in agencies making funding decisions and issuance of funding.

If a federal agency emails a PI with the option to revise recent proposals to remove or change programmatic sections within the proposal, the change may be minor and acceptable to PIs or it may raise concerns. If the PI wants to evaluate if such request is consistent with current legal proceedings, please contact the Office of Sponsored Programs at osp@uw.edu. In no circumstance should a PI make a statement, assurance or certification on behalf of the University regarding compliance with federal policy. If faced with that request, please contact OSP.

If a revised proposal will be submitted, or a response to a sponsor submitted, please follow the processes for these action:

Advance Spend

There are three scenarios where PIs may have worktags that allow spending in advance of official notification of award from a sponsor:

  1. New awards that are either anticipated or under review/processing.
  2. Mid-project spend ahead of the next year’s funding, when that funding is delayed.
  3. End of project spend ahead of a formal no-cost extension approval.

With the increasing uncertainty about federal funding, normal processes for advance spending on research cannot be sustained. At this time, the University is introducing limits on advance spending on federal and federal flow-through awards, as outlined below. As departments, schools, and colleges assume the risk of advance spend, chairs and deans may have additional restrictions.

NOTE on NSF: Advance spend is not allowed on pending or issued NSF awards on HOLD.

Advance Spend requests will only be approved in the following limited cases:

  • New Awards: OSP and GCA will prioritize new awards. However, due to known delays with set-up, an Advance Award may be approved when an NOA is with OSP or GCA. Please use the New Advance Request.
  • For non-competing renewals and no-cost extensions, a Renewal Advance or a Temporary Internal Extension may be set up for 30 days from the current end date of the award. At the end of this period, if formal sponsor approval has not been received, departments should identify alternate funding or
  • initiate temporary HR actions.
  • For NIH SNAP awards that were set up prior to October 1st, 2024. These awards were set up with the initial funding period instead of the full performance period. These awards may be extended via an Award Portal ticket to GCA.

For cases where an Advance is already in place and no NOA has been received, pause on expenditures will depend on the Advance spending start date:

  • If the start date is before 3/1/2025, there must be a pause in expenditures immediately.
  • If the start date is in April, PIs should minimize spending and work with their HR consultant to determine when to pause spending, aiming for 5/31/2025 at the latest.
  • If the start date is 5/1/2025 or later and formal sponsor approval has not been received after 30 days, spending must pause.

When the Advance Award is paused, departments must identify alternate funding or initiate temporary HR actions. For guidance, work with your HR consultant and see HR Support Resources for Federal Policy Impact.

All other non-federal Advance Spend may continue to be requested but may receive increased scrutiny.

Awards

Reports

Stay on top of timely submissions per standard instructions in your award.

Scope Revisions

Some PIs are receiving notices to cease award activities that have become noncompliant with the new Executive Orders, either specific to a particular project or via a broad message from the agency. If you do receive a request for scope changes that requires you to send in a formal revised Statement of Work (SOW), then the revision must be submitted through OSP using the SAGE (MOD) process.

Please create an OSP & GCA MOD, select “Other Changes” tab, and the subcategory of “Executive Branch Directive Change”. OSP is ensuring there is review of such requests prior to submission, in light of the TRO and Motion to Enforce. This information is also being shared with the AG’s office.

If an agency sends a request for changes through a broad directive there is no need to send changes through OSP on an Award Modification. You may continue to send any broad agency communications to osp@uw.edu, for awareness.

Questions about specific activities on your project should be directed to your program manager. Please document any communications that you have with your program manager associated with scope changes.

Terms or Award Changes

We anticipate changes to sponsor requirements for compliance, certifications made by the UW as a grantee/contractor, and award reporting.

Changes may come from a sponsor as a blanket change, by memo, or newly implemented policy. Others may be through individual award amendment. They may be imposing or lifting restrictions. You may also receive informal instructions directly from your Program Officer. In no circumstance should a PI make a statement, assurance or certification on behalf of the University regarding compliance with federal policy. If faced with that request, please contact OSP (osp@uw.edu). If you receive any individual amendment or other specific award change instructions, please submit them as an OSP & GCA Award Modification (MOD) in SAGE select “Other Changes” tab, and the subcategory of “Executive Branch Directive Change”.

National institutes of Health Foreign Subaward Tracking & Monitoring Requests

For NIH, in select cases, Program Officers are approaching PIs to directly submit responses related to foreign subaward participation or tracking, with less than a two day turnaround:

  • PI can respond directly
  • Copy OSP (osp@uw.edu) as Authorized Official
  • Route OSP/GCA SAGE MOD with the email correspondence attached

A PI should refer to UW’s Statement on Foreign Subaward Assessment, Tracking and Monitoring for important institutional level information.

Extensions

All requests to extend a project go through OSP.
Note NIH has disabled the First-Time No-Cost Extension ability in eRA Commons. All extension requests must be submitted as a prior approval request. More information is available on our NIH FAQs May 2025 page.

Stop or Suspend Work Orders

A stop or suspend/pause work order may come to the PI or the PI’s department, or it may come to OSP or GCA. Irrespective of whether the change order is dated before or after the TRO went into place, these guidelines must be followed to ensure proper consideration. Please note that action should be taken as soon as possible – and within 24 hours.

  • If GCA receives a stop/pause work order, they should forward it immediately to osp@uw.edu.
  • When OSP receives a stop/pause work order, an Award Modification will be created and routed to the PI within 24 hours for awareness and additional information. If the change order appears inconsistent with the TRO, OSP will confirm with the sponsor before processing the Award Modification.
  • If a PI or their department receive a stop/pause work order, the PI must create the OSP & GCA Award Modification within 24 hours of being notified. Choose “Other Changes”, and the subcategory of “Stop work Order” in creating the MOD. Include the sponsor communication along with any required documents, identify the sponsor deadline, and route to OSP. Please also email osp@uw.edu with the MOD #.

Within 24 hours of being notified, the PI must contact their department administration, dean’s office and central HR consultant to initiate processes for expenditure management.

Please review UW Human Resources information.

Guidance is available for researchers who have changes related to research involving human subjects or animals.

Resuming Work

Resumption of work authorization may happen in these two situations:

  1. A court decision that is determined to cover an earlier suspension order from the agency. When this occurs, the agency is required to send a broad notice to grantees. Upon receipt of that notice, resumption of work may occur. This still incurs risk if payment is delayed or suspended despite the court order. The University reserves the right to continue a suspension of work if it observes agency violation of the court order.
  2. For federal contracts and pass-through funding, we need formal notification to resume work. If you directly receive a specific resumption notice for your award, please submit it as an OSP & GCA Award Modification in SAGE, choosing “Other Changes” as the Category, and “Resume Work Order” as the subcategory. Be sure to attach the specific award notice to the MOD. Please let osp@uw.edu know the MOD#.

Early Termination

In some instances, we are seeing early termination of active federal and federal flow-through awards. If received, please submit as an OSP & GCA Award Modification in SAGE, choosing “Schedule Change” and the subcategory of “Early Termination”.  Please let osp@uw.edu know the MOD #. Please review UW Human Resources information.

Additional guidance is available for researchers who have changes related to research involving human subjects or animals.

Please review Closeout steps.

Appeals

PIs must work with their department and school/college leadership to review the information provided in the termination notice to determine whether to appeal.

OSP is responsible for submitting the appeals to a sponsor. OSP will work with the PI in developing the justification. Note that all charges to the project must be suspended during the appeal process.

Contact Carol Rhodes, OSP Director at carhodes@uw.edu if you are considering an appeal.

Spending & Expenditure Management

Most activity on your federal awards can continue if there is not a stop work order or termination. However, in some cases, the University is observing a delay or suspension of payments. In those cases, the award activity may need to pause while decisions on next steps occur.

For stop/pause work orders, some scope changes, and severely delayed payments, there will be impacts on employee salary support. If there are insufficient other funding sources to cover salary for an employee, the department must initiate a furlough or layoff. Please work with your Department and School when making these decisions.

Any expenditures benefiting the project incurred after the effective date of the stop/pause work order must be charged to an alternative spending source. Projects with a stop or pause work order will also have a hiring freeze.

Subawards

Subawards will continue to be processed as usual. Additional terms and conditions may apply.

OSP will be actively monitoring change orders for outgoing subawards and will consider broad agency announcements in issuing subawards.

These guidelines are applicable to all subawards, whether or not the subrecipient is foreign or domestic.

Subaward: Assurance Letters

During this period of uncertainty, OSP will no longer be issuing assurance letters to subrecipients on federal funding prior to subaward set-up.

Subawards: Stop work/Suspension Orders

When there is a stop or suspend work order for a specific project:

  • OSP will issue suspension letters to active subrecipients & intended subrecipients consistent with the direction of the sponsor. The UW PI and SAGE Subaward Preparer will be copied on the email to the Subrecipient PI and contact.
  • You do not need to send a subaward request to suspend a subaward. Subawards that have not been processed yet will continue to be processed to cover activity up to the stop work date.

Subawards: Change of Scope

When there is no stop work order, but the agency has issued an amendment ceasing activities associated with categories of recent Executive Orders, and this impacts the subaward:

  • Submit a request to modify the Subaward in the SAGE Subawards Module.
    • Indicate the need for a subaward scope and/or budget change.
  • Include any relevant attachments & information from the sponsor.

Subaward: Early Terminations

When a federal agency issues an early termination for a project and there are subawards:

  • Follow guidance on requesting an Early Termination MOD in SAGE
  • Submit a request to modify the Subaward in the SAGE Subawards Module
    • Indicate the new end date
    • Include any budget changes
    • Include all relevant attachments & communications with the sponsor

If you have questions about a subaward change order, please email ospsubs@uw.edu.

Foreign Subawards

The UW continues to partner with foreign collaborators.

NIH has issued an Updated Policy on Foreign Subawards. Please review guidance on NIH requests for tracking & monitoring foreign subawards as well as guidance on NIH proposals with foreign subrecipients. Please see this NIH Q&A page to review guidance on applying this policy.