June 20, 2025
MRAM Q&A June 2025
Meeting materials are available for your review along with a list of links shared during the session. Q&A from our session are included here for reference and will be available with the other meeting materials shortly.
Within a week or so following every MRAM, an email like this one typically goes out with Q&A from the session and a link to the meeting materials.
- PAFC Hot Topic: Cost Share, NRSA Stipend Levels & Travel Compliance
- NSF: General Award Terms & Conditions
- GIM 1 Publication, Training, and Guidance Updates
- DOGE Draw Requests
- CORE Update
PAFC Hot Topic: Cost Share, NRSA Stipend Levels & Travel Compliance
Q: Does the R1205 report include data from pre-workday?
A: Yes – cost share converted to Workday at Go Live is included under the cost share grant worktag and will appear on the R1205 and R1234 reports. When viewing cost share expenditure details, converted cost share will show up under the ledge account: “89998:Conversion – Life to Date Grant Expense”
NSF: General Award Terms & Conditions
Updates are regularly posted to the Office of Research Guidance on Federal Administration Research Policy, Federal Administration Updates, and the Select Court Cases webpages.
As of 6/20/2025: Court declares that the NSF’s 15% Indirect Cost Rate and the Policy Notice are invalid, arbitrary and capricious, and contrary to law.
Q1: Has UW seen any NOAs for continuing increments with the conditional 15% cap language or only is this language only appearing on new awards? And by “conditional cap language”, I mean…”In accordance with the court’s order dated May 19, 2025, NSF is temporarily staying effectuation of Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034). If a court decision permits application of the policy..”
A1: Yes. We have seen this language in new and incremental awards. As of 6/20/2025: Court vacated the NSF’s 15% Indirect Cost Rate and the Policy Notice which allows us to move forward.
Q2: For NOAs for new awards that arrived with the conditional cap language that are currently on “hold” with OSP, will new NOAs be needed from NSF without this conditional cap language (in the event the court decision provides clarity that the cap should not be applied)?
A2: No.
Q3: In the event the court decision provides clarity that the NSF cap should no be applied, will departments need to submit escalation requests to OSP for those NSF ASRs currently on hold to be processed, or will those ASRs be prioritized without escalation requests?
A3: No. ASRs and MODs that were on hold are being processed.
GIM 1 Publication, Training, and Guidance Updates
Publication of GIM 1 revisions is scheduled for 7/01/2025.
Review the June 2025 MRAM presentation on GIM 1 resources and training material being developed.
DOGE Draw Requests
Q1: Are the DOGE requests random or does there seem to be a pattern either on details or types of transactions or agencies?
Seems like some sort of audit, any idea what they are looking for and do we need to do anything differently than following our usual compliance guidelines?
A1: We have not received enough requests to know if there is a pattern. It is hard to tell what they are looking for, there is definitely not a materiality threshold for the request.
Q2: Are you seeing more DOGE requests from one specific agency over others?
A2: NIH has the highest number of requests, but we have received requests for other agencies including NASA, CDC, and HRSA.
Q3: Have there been responses to these requests that have been rejected or pushed back on?
A3: So far just one, and with additional work from the department it was accepted.
Q4: Are you able to confirm that DOGE requests are only related (so far) to pending payments and not asking about historic items that have been previously paid.
A4: Yes, but as we are doing draws I am not sure we would be receiving requests for items that are already paid.
Q6: Is there any template or language guidelines that we can develop with your team to help folks turn these around quickly, accurately, and appropriate to submit? Anything we can do to streamline this?
A6: A wide range of responses have been accepted, but samples are available in the June 2025 MRAM – DOGE Requests slide deck that can be used for reference.
Q7: If DOGE is not satisfied with one of the transaction justifications, will DOGE hold the entire multi million dollar draw? Or, is it still too early to tell?
A7: Yes, the entire draw is held until all the requests from that draw are accepted.
Q8: How do we know if your team has submitted a request? Not sure if the delay in response then delays the follow no year NOA.
A8: I try to respond to the email when I submit the request.
Q9: Seems like most are related to non-descriptive object classes (internal service delivery, etc.). Some of this could potentially be resolved by using a field that provides more description as to the charge.
A9: The justification field when we submit the draw is limited to 1000 characters. We cannot provide descriptions for individual transactions.
Q10: When DOGE refutes the justification are we supposed to following their decision – just wondering if there is potential conflict between interpretation what is and is not allowable.
A10: This has only happened once and it was accepted after additional information was provided.
Q11: We are proposing to combine all the F/A lines for example and provide one explanation for the 20 lines. Is that ok?
A11: I have submitted responses that combined F&A and they have been accepted.
Q12: If you don’t receive a timely response from campus, will you escalate to the Dean’s Office?
A12: Yes, thank you.
Core Update
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