2025 Federal Transition and Policy Updates
Department of Health and Human Services
Updated May 9, 2025
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Department of Health and Human Services updates
Please note that agencies within the Department of Health and Human Services have different approaches and mandates. For example, the Centers for Disease Control and Prevention (CDC), the National Institutes of Health (NIH), and the Health Resources and Services Administration (HRSA) have issued specific mandates and shared those with principal investigators (PIs).
Apr. 16, 2025: HHS has released new grant terms and conditions addressing certain activities in violation of federal anti-discrimination laws. The University is aware of this change is actively reviewing the updated requirements to ensure compliance.
Guidance for faculty
- Faculty must comply with agency-specific mandates (see guidance below).
- Work on existing awards may continue if obligated funds are available and the sponsor has not issued a stop-work order.
- Notices of new, continuing, or supplemental funding will be delayed, and awards currently under negotiation are on hold until further notice from the sponsor.
National Institutes of Health (NIH) updates
May 7, 2025: The NIH released an updated process for no-cost extensions indicating that the NIH has temporarily disabled the [automatic first] No-Cost Extensions (NCE) in eRA Commons to allow staff to review all grants and ensure awards do not fund off-mission projects. All NCE requests now require prior approval in eRA Commons. Requests for activities that do not align with the NIH’s mission or priorities will not be approved.
May 1, 2025: The NIH released an updated Policy on Foreign Subawards that indicates starting on or before September 30, 2025, the NIH will establish a new award structure that will prohibit foreign subawards from being nested under the parent grant, and instead will include a prime with independent awards that are linked to the prime award to allow NIH to better track foreign expenditures. Pending the new award structure, NIH will not issue awards to domestic or foreign entities that include a subaward to a foreign entity, and NIH will allow in all cases an attempt to renegotiate awards to remove subawards to foreign entities. The University is actively reviewing this Notice and discussing its scope and impact with our peers and professional organizations.
Apr. 21, 2025: The NIH has released new grant terms and conditions addressing certain activities in violation of federal anti-discrimination laws. The University is aware of this change is actively reviewing the updated requirements to ensure compliance.
Mar. 26, 2025: The NIH has created an Implementation of New Initiatives and Policies page that serves as a central location with the latest information on recent and upcoming changes that impact applications and grants administration, including changes to application requirements, proposal review, awarding, and reporting. We encourage individuals to bookmark this page to stay up-to-date on the latest changes from the NIH.
Feb. 20, 2025: The NIH is updating plans for future council meetings, including canceling certain meetings. Please review the NIH advisory committees page for the latest updates.
Feb. 8, 2025: NIH released a “Supplemental Guidance” indicating that “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.”
Guidance for faculty
- We recommend you submit your no cost extensions (NCE) at least 90 days in advance of the project period end date.
- For proposals due through 5/31/25 that may include a foreign subaward, we recommend that the Principal Investigator(s) speak with their program officer to confirm that a foreign subaward will be supported on your particular program announcement.
- For proposals due to NIH in the immediate, consider submitting budgets with existing rates and including a statement in the budget justification that your institution will comply with applicable law and guidance governing indirect cost rates upon award.
- We are working actively with our government relations team and our national organizations, including AAMC, AAU and COGR, to address this issue.
- We are also closely monitoring the situation and will provide updates as they become available.
Centers for Disease Control (CDC) updates
Feb. 11, 2025: In compliance with a Temporary Restraining Order, the CDC has rescinded its January 29, 2025 communications regarding ceasing DEI activities on all CDC-funded awards and its January 31, 2025 communications regarding ceasing all activities promoting gender ideology.
Guidance for faculty
- Proceed as normal with your research efforts until further notice.
Jan. 31, 2025: Investigators may have received an email with the subject line “Cease Gender Ideology Activities on CDC Awards.” According to the memo, the following response is needed to implement the Executive Order Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government:
- Immediately terminate all programs, personnel, activities, or contracts that promote or incorporate “gender ideology” at any level if supported by CDC funds.
- Any “gender ideology”-related programs funded under a CDC award are immediately, completely, and permanently terminated.
Jan. 29, 2025: Memo sent to investigators regarding the implementation of the Presidential Executive Order Ending Radical and Wasteful Government DEI Programs and Preferencing and Initial Rescissions of Harmful Executive Orders and Actions stated the following:
- Immediately terminate all programs, personnel, activities, or contracts that promote diversity, equity, and inclusion (DEI) at any level if supported by CDC funds.
- Any DEI-related programs funded under a CDC award are immediately, completely, and permanently terminated.
Health Resources and Services Administration (HRSA) updates
Feb 5., 2025: HRSA rescinds notice titled “Important Message for HRSA Award Recipients” distributed January 31, 2025.
Guidance for faculty
- Proceed as normal with your research efforts until further notice.
Jan. 31, 2025: Investigators may have received an email from HRSA stating, effective immediately, HRSA grant funds may not be used for activities that do not align with the following Executive Orders. Note: Any vestige, remnant, or re-named piece of any program in conflict with these orders are terminated in whole or in part.