UW Research

Guidance on New Administration Policy for Federal Research

Contents

Updated 2/12/2025

Guidance for Responding to Award Change Notifications

Introductory Section

On January 31, 2025, a Federal Court issued a Temporary Restraining Order (TRO) directing Federal grant-making agencies not to pause or terminate awards and obligations on the basis of the President’s recently issued Executive Orders. On February 10th, the Court granted a Motion to Enforce in full. An appeal to the TRO was denied.

As a result, agencies are responding by lifting earlier restrictions, usually through broad agency memo, rather than specific to any one award.

As we earlier advised, while the TRO is in effect researchers can continue working on their federal awards but there are exceptions for federal contracts and some subawards, as described further below. PIs will be notified when their award is approved to resume, if it received an earlier stop-work order. Any PIs receiving agency communications related to specific award changes should continue to 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#.

We are closely monitoring potential changes to how federal awards may be awarded, amended and/or discontinued.

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. However, with the Motion to Enforce the TRO, we are hopeful that these will abate. If you do receive a request for scope changes that requires you to send in a revised Statement of Work (SOW), then the revision must be submitted through OSP using the SAGE (MOD) process. 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. Because there are not yet specific guidelines related to DEI (and other EO topics) that apply to all agencies, 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.

Some federal agencies have emailed PIs with the option to revise recent proposals in submission to change or remove sections in light of the EOs. However, with the Motion to Enforce the TRO, this type of request is in contempt of court. The TRO applies to current awards. It is up to you whether revisions would make sense for your work.

Revisions must be submitted through OSP – see General Award Guidance (Post-Submission) below for further details.

Recent agency communications:

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. We will try to collect what is known here and any impact to sponsored programs as a whole. However, if you receive any individual amendment or other specific award change instructions, please submit them as an Award Modification (MOD) in SAGE.

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, GCA or Procurement. 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 or Procurement receive 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 “Other Changes/Sponsor approval required” 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. In some cases, exceptions to stop work orders may be granted, but PIs must still forward the stop work order to OSP.

Resuming Work

Direct grants and cooperative agreement awards made to UW that were paused prior to the TRO, and any associated subrecipients, have been authorized to resume. 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” as the Category, and “Other Change” as the subcategory. Be sure to attach the specific award notice to the MOD. Please let osp@uw.edu know the MOD#.

Expenditure Management

For stop/pause work orders and some scope changes, 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. We are beginning to see resumption of work notices, therefore 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.

For Projects Involving Subawards

While the TRO is in place, subawards will continue to be processed as usual. If the TRO is lifted or other orders are introduced, the following guidelines apply.

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

  • When there is a stop or suspend work order for a specific project, OSP has issued suspension letters to active subrecipients consistent with the direction of the sponsor. Pending subawards will only be issued for activity through the date of the stop work order, with obligated award funds that do not fall under EOs. Suspension will be lifted if/when the prime sponsor authorizes resumption of award activity or the University deems it possible under the TRO.
  • When there is no stop work order, but the agency has issued a broad mandate for ceasing activities associated with categories of recent EOs (e.g. DEIA, gender identity), the PI must notify OSP at ospsubs@uw.edu as to the impact on subrecipient work. The PI should either notify OSP that there is no need for a scope change, or submit an Award Modification in SAGE indicating the need for a subaward scope and/or budget change or a stop work order. The broad mandate will be considered in light of the TRO and a decision made about whether to issue a new subaward or subaward modification with updated terms. Any pending subawards will be issued with additional terms and conditions for work beyond the date of the agency notification.
  • For all other federal awards, new subaward actions will be handled as per usual business process. Additional terms and conditions may apply.

These guidelines are applicable to all subawards, whether or not the subrecipient is foreign or domestic. The UW PI and unit contact will be copied on correspondence with the subrecipient.

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

General Award Guidance

Researchers should continue working on funded projects and continue to submit proposals. If you have any questions regarding your federal awards, please reach out to your unit administrators. We will provide regular updates via MRAM and this webpage.

Proposals

All federal agency submission systems are operational at this time. Check your funding announcement for any revisions or updates, including the opportunity expiration date. Consider signing up for alerts from federal agencies or sponsors.

If the NOFO has requirements that run counter to the TRO (e.g. imposing a 15% cap on IDC) and you were unable to get clarity from the sponsor agency contact:

  • Make sure to include all attachments that are required for successful submission (e.g. passes validations)
  • It is okay to include a statement regarding the TRO in cover letter or budget justification document, such as “The University recognizes this program falls under recently issued Temporary Restraining Orders. In order to meet the submission deadline, the University submits this application with required components and reserves the right to amend it consistent with current Court rulings”.

Please use UW’s federally negotiated indirect cost rates until further notice.

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 NIH study sections have been impacted due to an HHS freeze. We are aware of specific funding decisions that have been delayed while assessment occurs. Some federal agencies have emailed PIs with the option to revise recent proposals to remove sections no longer required within the proposal. Revised proposals and pre-award correspondence to sponsors should be sent through OSP.

Advance Spend

Advance budgets may not be approved during this period of uncertainty. If you have an already approved advance budget, keep it to essential expenditures. Remember that incurring expenses ahead of the award is a risk assumed by the PI and department.

Awards

Spending

Unless you have received a stop work or change order, please consider it business as usual for activity on your federal awards. Any specific change that impacts spending should be processed as an Award Modification in SAGE.

Reports

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

Travel

The HHS freeze impacts ability to travel. There may be delays in conferences, on site activity, and presentations.

Subaward

During this period of uncertainty, OSP will no longer be issuing assurance letters to sub-recipients prior to subaward set-up.

Temporary Internal Extension

Under certain circumstances, if requested by the PI, OSP may process an internal extension. As is always the case, note that any expenditures incurred ahead of the formal sponsor approved extension is a risk assumed by the PI and department.