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Executive Actions and Federal Agency Updates

Specific Agency Guidance & Recommendations for Researchers

 

 

 

Recent presidential actions, including executive orders (EO), proclamations, and memorandums, may indicate changes in federal priorities, potentially affecting your current and pending projects and upcoming deadlines/programs funded by federal agencies or other sponsors.

As federal agencies and sponsors adjust to these changes, we will keep you informed.


Recommendations:

1. Review your award agreements
  • Carefully examine your award terms and conditions and make sure you understand the terms, particularly those concerning funding availability and reimbursement.
2. Award Performance
  • Performance should continue as long as funding is available unless a stop-work order or official agency communication has been issued.
  • Please follow all stop-work orders and project-specific sponsor notices and directives. 
  • For active federal awards, OSP has been reaching out to PIs directly to provide additional information and discuss project impacts.
    • Unlike with a stop work order, receiving an agency memo does not necessarily mean that your project is impacted.
    • UPDATE:  Per the Temporary Restraining Orders, even if your project is implicated, all work may continue as normal. 
    • If you reach out to your sponsor for clarification, please be patient, given the pace of the changes.  
3. Diversity, Equity, Inclusion, and Accessibility (DEIA)
  • UPDATE: Per the Temporary Restraining Orders, any implicated federal award with Diversity, Equity, and Inclusion (DEI) activities may continue to work on DEIA activities.
  • Expect that any DEI-related aspects will be removed from solicitations or not reviewed as part of the selection process.
4. Monitor budget balances:
  • Keep a close watch on your budget balances to prevent deficits while waiting for future funding. Remember, anticipated funding is not guaranteed and depends on fund availability.
  • Be sure that all billing and invoicing are current, including that of subrecipients.
  •   Anticipated future funding remains subject to the availability of funds and should not be considered guaranteed. Researchers requesting preliminary projects and preliminary extensions should proceed with caution.
  • UPDATE: Funds allocated for DEIA activities can continue to be spent.
5. Travel
  • Concerns that travel in some federal awards may be immediately suspended have significantly lessened.  Unless you've received a stop-work order, please continue with travel as planned.
  • The NIH began hosting virtual study sections, but some NIH-sponsored meetings may still be canceled. Other federally sponsored scientific meetings, study sections, and panels may also be affected. Please verify before traveling. 
6. Submit reports and deliverables:
  • Make it a priority to submit any technical reports or deliverables that are overdue or nearing their due date.
7. Stay updated on sponsor announcements:
  • Stay alert for any updates from your award sponsors, and check the information below regarding funding or compliance requirements.
  • If you receive an agency memo, it does not necessarily mean that your specific project is non-compliant with the executive orders.
8. Proposals
  • Cayuse has confirmed that the Grants.gov submission service is still operational. Please continue preparing and submitting applications to any posted opportunities.
  • Exercise discretion when pursuing new federal opportunities, as submission dates may change, or the Notice of Funding Opportunity (NOFO) could be withdrawn and revised.

 FEDERAL AGENCY SPECIFIC UPDATES & GUIDELINES

UPDATE: On February 21, 2025, the Temporary Restraining Order was extended. Any implicated federal award may continue to work as normal unless instructed not to via a stop work order. Given the complexity of the executive actions and orders, researchers may wish to proceed with caution and defer starting new activities until there is more clarity especially if the work is closely related to impacted activities (DEIA, environmental justice, gender ideology, etc.). If you receive project-specific sponsor directives, stop-work orders, or awards with changes to F&A, please bring them to the attention of your OSP officer.

February 11, 2025UPDATE - Message to Resesarch Recipients

In compliance with the Temporary Restraining Order issued on January 31, 2025, in the United States District Court in the District of Rhode Island, the purpose of this communication is to rescind the following CDC communications effective immediately:

  • January 29, 2025: Cease DEI Activities on ALL CDC funded awards
  • January 31, 2025: Cease ALL Activities Promoting Gender Ideology

Please direct questions to PRISM@cdc.gov

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Cease DEI Activities on CDC Awards

The  Centers for Disease Control (CDC) has issued a January 29, 2025 notification requiring DEI Activities cease on CDC Awards.

According to the letter the University must :

Immediately terminate, to the maximum extent, all programs, personnel, activities, or contracts promoting 'diversity, equity, and inclusion' (DEI) at every level and activity, regardless of your location or the citizenship of employees or contractors, that are supported with funds from this award. Any vestige, remnant or renamed piece of any DEI programs funded by the U.S. government under this award are immediately, completely, and permanently terminated.

No additional costs must be incurred that would be used to support any DEI programs, personnel, or activities.

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Cease Gender Ideology Activities on CDC Awards

The CDC has issued a letter, received January 31, 2025, immediately terminating award activities that "promote or inculcate gender ideology". 

The January 23, 2025  NIFA Notice states that all NIFA Requests for Applications and Funding Opportunities are under review.

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The USDA has issued a January 21, 2025  memorandum to all agency and office heads placing a moratorium on the obligation of funds through grants, cooperative agreements, and contracts.

According to the memo:

In order to ensure that grants, cooperative agreements, and contracts entered into on January 21,
2025, and thereafter conform to all applicable laws and policies of the new Administration, a short-
term moratorium on the execution of such documents is effective immediately. In addition, no
action shall be taken to issue new requests for proposals and no notices of funding availability shall
be issued.

Actions that will be taken regarding grants, cooperative agreements and contracts submitted to
your agency or office for execution are temporarily suspended in order for the Office of Budget and
Program Analysis and the Office of the General Counsel to determine if the agency may refrain from
execution of the document without incurring any liability.

The DOD has issued a January 28, 2025 Release Department of Defense Statement Clarifying Defense Contracting

The DOD has stated they will "expeditiously analyze [their] financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President's executive orders."

The Dept. of Ed issued a January 23, 2025 News Release: U.S. Department of Education Takes Action to Eliminate DEI

The DOE has issued a January 27, 2025  Memorandum for all DOE Funding Agreements or Awards  and a follow-up January 31, 2025 letter suspending the following activities in all sponsored projects:

  • Diversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; and
  • Community Benefits Plans (CBP);
  • Promoting Inclusive and Equitable Research (PIER) Plans; and
  • Justice40 Requirements, conditions, or principles

Per the memo, "Recipients who have DEI and CBP activities in their awards will be contacted by their Grants Officer to initiate award modifications consistent with this Order."

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On January 20, 2025, the DOE issued guidance indicating that, until further notice, there will be delays in any funding actions.

We recommend closely monitoring your project’s budget to ensure that work aligns with available funds.

DOJ issued the following email notice on February 12, 2025.

Subject:
Executive Order on Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government

Attention All Awardees:

Consistent with the Executive Order (EO) entitled Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government (Defending Women), the U.S. Department of Justice’s National Institute of Justice (NIJ) is providing the following instruction and procedures and is seeking award information on or related to surveys, forms, or other data collection tools that ask about “gender” or “gender identity.” 

Instruction.  If an award-funded project includes a survey, form, or data collection tool that asks about “gender” or “gender identity,” it must instead ask about “sex,” with only two available responses:  “male” and “female.”  A “choose not to disclose” response is not permitted. All questions about “gender identity” must be removed.   Therefore:

  • If the project’s survey/form/data collection tool is under developmentor will be under development later in the project timeline:
    • Ensure that the question complies with the above Instruction.
  • If the project’s survey/form/data collection tool has been developed, but has not yet been administered:
    • If it has been reviewed and approved by the Institutional Review Board (IRB) but not by NIJ’s Human Subjects Privacy (HSP) team, change the question(s) to be in compliance with the above instruction before submitting the package to NIJ for HSP review.
      • This may require resubmission for review and modification approval by the IRB.
    • If it has not yet been approved by the IRB, change the question(s) to comply with the above Instruction before submitting the package for IRB and NIJ HSP review.
  • If the project’s survey/form/data collection tool has been developed, approved, and administered:
    • If administration is ongoing, pause administration and change the question(s) to comply with the above Instruction.
      • This may require resubmission for review and modification approval by the IRB.
    • Submit the updated package to NIJ for HSP review and approval. Administration of the survey/form/data collection may resume only upon the award recipient’s receipt of notice of NIJ approval.

Your timely compliance is appreciated. Failure to comply with this directive may affect the award.

Thank you,

National Institute of Justice (NIJ)

NETL has issued a January 28, 2025  Memorandum for all DOE Funding Agreements or Awards suspending the following activities in all sponsored projects:

  • Diversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; and
  • Community Benefits Plans (CBP); and
  • Justice40 Requirements, conditions, or principles

Per the memo, "Recipients who have DEI and CBP activities in their awards will be contacted by their Grants Officer to initiate award modifications consistent with this Order."

On January 22, 2025, the Department of Labor Employment and Training Administration issued Training and Employment Notice 21-24 re: Immediate Implementation of Executive Orders "Ending Radical and Wasteful Government DEI Programs and Preferencing" and "Ending Illegal Discrimination and Restoring Merit-Based Opportunity".


Effective Immediatly, all recipients of federal financial assistance awards are directed to cease all activities related to "diversity, equity, and inclusion" (DEI) or "diversity, equity, inclusion, and accessibility" (DEIA) under federal awards... Additional Guidance will be provided.

The U.S. Department of State has issued the following NOTICE OF SUSPENSION for FOREIGN ASSISTANCE AWARDS:

NOTICE OF SUSPENSION

January 24, 2025

Dear Recipient:

 

The U.S. Department of State hereby notifies the recipient that all foreign assistance awards are immediately suspended. As of January 24, 2025, this award no longer effectuates agency priorities and is suspended in accordance with the U.S. Department of State Standard Terms and Conditions.

This suspension may be further codified through an amendment to the award reflecting the termination date, if appropriate.

 

Effective immediately upon receipt of this Notice of Suspension the Recipient must stop all work on the program and not incur any new costs after the effective date cited above. The Recipient must cancel as many outstanding obligations as possible.

  

Sincerely,

 

Wanda Howell

   /obo Ruta Chagnon

Grants Officer


Recipients of these foreign assistance awards should immediately follow the Stop Work Orders Procedure.

As part of the federal hiring freeze, the Dept of Veterans Affairs is not issuing new/renewal IPAs.

The VA will only consider new/renewal IPAs once the freeze has ended (date unknown). Further, OSP's understanding is that once the VA starts issuing them, they will not have retroactive start dates; the VA has said they will only sign new/renewal IPAs with start dates after the freeze has ended. 

This February 19, 2025 summary letter (sent to dept administrators that frequently use VA IPAs) from OSP provides more detail. 

Please note that IPAs that are in their current period of performance are continuing as normal, but if they end before the federal hiring freeze is lifted, we do not expect those to be renewed.

Please direct questions to Lisa O’Hara at the Salt Lake City VA.

Health Resources and Services Administration (HRSA) has issued the following January 31, 2025 Message for HRSA Award Recipients:

Dear Recipient:

Your Health Resources and Services Administration (HRSA) award is funded in whole or in part with U.S. government funds.

Effective immediately, HRSA grant funds may not be used for activities that do not align with Executive Orders (E.O.) entitled Ending Radical and Wasteful Government DEI Programs and Preferencing, Initial Rescissions of Harmful Executive Orders and Action,Protecting Children from Chemical and Surgical Mutilation, and Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government (Defending Women). Any vestige, remnant, or re-named piece of any programs in conflict with these E.O.s are terminated in whole or in part.

You may not incur any additional costs that support any programs, personnel, or activities in conflict with these E.O.s

If you have any questions, contact us at DGMOCommunications@hrsa.gov. 

NASA has issued a February 6, 2025 Memorandum for NASA Contractor and Grantee Community re: "Gender Ideology". 

Per the memo, NASA will be discussing necessary contract or grant modifications required to comply. If researchers are asked to remove gender ideology activities as it pertains to their contract or grant requirement, please share this information with OSP.

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NASA has issued a January 23, 2025 Memorandum re: Initial Guidance Regarding Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders  terminating all DEIA activities required of their contracts or grants. 

This include, but is not limited to, the following activities:

  • DEIA plan requirements, training, reporting, considerations for staffing or any other direct or indirect activity

PIs who have these requirements/activities in thier awards should actively engage their Contracting Officer or Grants Officer re: the removal of DEIA activities.

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NASA has also issued Amendment 109: Removing DEIA Requirements from ROSES-2024.

NASA is "in the process of amending open Program Elements in Roses-2024 to end the Inclusion Plan Pilot Study, remove requirements for Inclusion Plans and the evaluation factors associated with them, and adjust the content of some other Program Elements to remove references to NASA's DEIA programs."

Program elements that have already received proposals will not be amended, but if they required Inclusion Plans, those plans will not be reviewed and will not impact the selection of proposals.

On February 6, 2025, the NEA issued a press release providing information on the updated FY 2026 Grants for Arts Projects guidelines and an accompanying FAQ

A webinar covering the updated guidelines will take place on Tuesday, February 18, 2025, at 2:00 p.m. ET. No registration required. Learn more.  A recording will be posted shortly after the presentation in the Applicant Resources section of the Grants for Arts Projects webpage.

The NEH provides ongoing information regarding recent Executive Orders and their impact on the NEH here.

NEH is revising its NOFOs to comply with Executive Orders and adding serveral new prohibited categories to its funding restrictions. 

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.  

On February 7, 2025, NIH issued NOT-OD-25-068 which sought to implement a standard indirect rate of 15% across all NIH grants in lieu of our separately negotiated rate.

On February 10, 2025, a federal judge in U.S. District Court for the District of Massachusetts granted the Association of American Medical Colleges (AAMC) motion for a nationwide temporary restraining order (TRO), preventing the February 7 notice from the NIH from going into effect.

  For all NIH applications submitted during the TRO, OSP and OGC are requiring the addition of the following language to the F&A section of the budget justification: 

“The University of Utah acknowledges NOT-OD-25-068 (Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates). To the maximum extent permitted by applicable law, the University of Utah is submitting this application and budget using the indirect rates agreed upon for “grants, contracts and other agreements with the Federal Government” as set forth in that certain Colleges and Universities Rate Agreement, by and between the University of Utah and the Department of Health and Human Services, dated effective as of December 16th, 2021 (the “Rate Agreement”). Any adjustments to the indirect rates set forth in the Rate Agreement shall only be made to the extent required under applicable law at the time of award.”

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NIH No-Cost Extensions

As of February 13, 2025 NCE links have been gradually reappearing but NIH has not made any announcements. Researchers are encouraged to continue working with OSP to check the availability of the NCE link.

As of February 4, 2025, the National Institutes of Health (NIH) has removed the ability to request 1st time automatic no-cost extensions

Since each project is unique, we encourage you to reach out to your Senior Leadership or OSP Officer for guidance and next steps. The eRA Commons prior approval module may still be available for 2nd and 3rd NCEs. At this point, OSP expects all NCE requests to receive higher levels of scrutiny.

This makes federal (and federal flow-through) preliminary extensions more precarious than in the past, and as we continue to note in the recommendations at the top of the page  “preliminary extensions should proceed with caution”.

The National Science Foundation (NSF) has issued the following January 28, 2025 MESSAGE to the NSF PI Community:

MESSAGE to the NSF PI Community,

Office of Management and Budget (OMB) Memorandum M-25-13, issued on January 27, 2025, directs all Federal agencies to conduct a comprehensive review of their financial assistance programs to determine programs, projects, and activities that may be implicated by the recent Executive Orders. Therefore, 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.

NSF has created an Executive Order Implementation webpage to ensure the widest dissemination of information and updates. We will continue to communicate with you as we receive additional guidance.

All NSF grantees must comply with these Executive Orders, and any other relevant Executive Orders issued, by ceasing all non-compliant grant and award activities. Executive Orders are posted at https://www.whitehouse.gov/presidential-actions/. In particular, this may include, but is not limited to conferences, trainings, workshops, considerations for staffing and participant selection, and any other grant activity that uses or promotes the use of DEIA principles and frameworks or violates Federal anti-discrimination laws. Please work with your institutional research office to assist you in complying with the Executive Orders. You can also direct your questions through the form on this NSF webpage.  

Thank you for your work advancing science, engineering, technology and innovation for our nation.

Sethuraman Panchanathan
Director

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On January 28, 2025, NSF 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 for information and updates.

On January 24, 2025, USAID issued this Notice on Implementation of Executive Order on Reevaluating and Realigning United States Foreign Aid

The notice directs contracting and agreement offices to "immediately issue stop-work orders, amend, or suspend existing awards, consistent with the terms and conditions of the relevant award".  

Those with USAID awards should anticipate receiving a stop-work order or similiar notice. If/when you receive a stop-work order, please follow the procedure.

On January 24, 2025, GSA issued an Acquisition Pause Memorandum instructing the short term suspension of any new GSA-funded awards and modifications. Some exceptions are outlined in the memo. 

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On January 22, 2025, GSA issued the Memorandum: Contractor Notice re: Implementation of Executive Order stating its intent to "take immediate action to begin forbearing enforcement of all contract clauses, provisions, terms, and conditions, related to diversity, equity, and inclusion (DEI)." The memorandum does not specifically direct the University to take any immediate action under contracts we may have. 

 

 

For questions or feedback, please contact:

Brent Brown
Director, Office of Sponsored Projects
  801-581-3003
 brent.brown@osp.utah.edu

Todd Bjorklund
Associate Director, Office of Sponsored Projects
  801-585-6946
  todd.bjorklund@osp.utah.edu

  VPR Office Hours: Friday Research Administration Q&A

The Office of the Vice President for Research (VPR) is hosting weekly Q&A sessions each Friday in February via Zoom.
Date: Friday, February 28, 2025
Time: 12:00pm MT

ask a question in advance

zoom link

 

  VPR Town Hall: Federal Funding Updates 

The Office of the Vice President for Research (VPR) invites all faculty, staff, post-docs, and students to attend weekly VPR town halls to ensure support and awareness for the University research community.
Date: Tuesday, March 4, 2025
Time: 12:00 – 1:00 pm MT

information & Registration


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Last Updated: 2/27/25