2025 Federal Changes This page will be updated as new information is provided. Researchers, please send federal agency communications you receive or any questions specifically related to awards to ospa@uky.edu and vpr@uky.edu.
May 9: DoD 2025 Decision Matrix Update
The Department of Defense (DoD) has published the 2025 Decision Matrix to Inform Fundamental Research Risk Decisions. These updates will be effective for all proposals submitted on or after May 9, 2025.
- See more detail on specific updates in our announcement here.
- View the most recent matrix on DoD site here.
May 8: Grant Re-budgeting Requests
If you are approached by a program officer to re-budget or change grant agreement terms, please do not engage with the agency. Immediately alert Collaborative Grants Services (CGS) and Office of Sponsored Projects Administration (OSPA) so that we can develop an institutional response. Only OSPA and the Institutional Official have the authority to negotiate with sponsors.
Past Announcements
May 7: Updated NIH Processes for No-Cost Extensions
NIH has temporarily disabled the No-Cost Extension (NCE) functionality in eRA Commons. The Director of NIH has directed NIH staff to review all existing grants and cooperative agreements to ensure that NIH awards do not fund off-mission activities or projects. Therefore, temporarily disabling the NCE functionality in eRA Commons will allow NIH staff to review and assess all NCE requests to confirm that the activities proposed during the extension align with the NIH mission and agency priorities. At this time, all requests for NCEs must be submitted as a prior approval request in eRA Commons, for NIH review and approval. Requests for activities that do not align with the NIH mission and agency priorities will not be approved. View NOT-OD-25-110 on NIH site.
May 2: Indirect Rates for NSF Grants
On Friday, May 2, the Trump administration instituted a 15% cap on indirect rates for National Science Foundation (NSF) grants, effective on all new awards beginning May 5. You can read more about that order on the NSF site here. The University of Kentucky will submit new NSF proposals at the currently negotiated rate of 54% but will also note that the University will accept the 15% if it is ultimately implemented. On May 3, the Association of Public and Land Grant Universities – of which the University of Kentucky is a member – filed a lawsuit seeking to block this order. As that litigation progresses, we will update this information.
May 1: Certificates of Confidentiality for Research Not Funded by NIH
The NIH Certificates of Confidentiality (CoC) system is temporarily unavailable while undergoing renewal of its Paperwork Reduction Act (PRA) approval. Currently, NIH cannot accept submissions to the CoC system or Institutional Official verifications. An update will be provided by July 2025. Note: CoC for NIH-funded studies (i.e., deemed issued CoC) are not affected. View CoCs NIH site.
May 1: Updated NIH Policy on Foreign Subawards
Effective May 1 until the details of the new foreign collaboration award structure are released, the National Institutes of Health (NIH) will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity. Additionally, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project. In all cases, NIH will allow Institutes, Centers and Offices (ICOs) to renegotiate awards, whether new, renewal or non-competing, to remove subawards to foreign entities and, where the work can be performed domestically, allow the funds to be re-budgeted for use by the prime recipient (domestic or foreign) or a domestic subrecipient. If a project is no longer viable without the foreign subaward, NIH will work with the recipient to negotiate a bilateral termination of the project, taking into consideration any need to support patient safety and/or animal welfare. View full notice: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html.
April 21: NIH Issues New Civil Rights Term and Condition of Award
The National Institutes of Health (NIH) issued a Notice, effective immediately, with a new Civil Rights term and condition that modifies the current terms and conditions for all grants, cooperative agreements and other transaction (OT) awards. View the Full notice on the NIH site.
April 18: NSF Updated Priorities Related to Broader Impacts
The National Science Foundation (NSF) continues to review all projects using Intellectual Merit and Broader Impacts criteria. NSF’s broadening participation activities, including activities undertaken in fulfillment of the Broader Impacts criterion, and research on broadening participation, should not preference some groups at the expense of others or directly/indirectly exclude individuals or groups. Research projects with more narrow impact limited to subgroups of people based on protected class or characteristics do not effectuate NSF priorities. Learn more at NSF.gov.
April 16: Federal Judge Blocks Cuts to DOE Indirect Costs
A federal judge has issued a temporary restraining order, temporarily blocking the Department of Energy (DOE) from cutting its support of indirect costs to 15%.
April 11: DOE to Reduce Indirect Costs to 15%
In a new policy memorandum shared with grant recipients at colleges and universities, the Department of Energy (DOE) announced that it will limit financial support of “indirect costs” of DOE research funding to 15%. Learn more at energy.gov
- The Association of Public and Land-Grant Universities (APLU) – of which UK is a member – along with the Association of American Universities (AAU) and American Council on Education (ACE) filed litigation on April 14 challenging this action. Read more about the litigation here.
April 1: Major Layoffs at Health Agencies
Health Secretary Robert F. Kennedy Jr. announced last week that he was shrinking his department by 10,000 employees. Some senior leaders based in the Washington, D.C., area, including leaders at the FDA, CDC and NIH, received notices that they were losing their jobs. Read more on nytimes.com. UK community members have free access to digital versions of the New York Times and Wall Street Journal by subscribing through UK Libraries.
March 25: NIH Common Forms Implementation for Biosketch and Current and Pending (Other) Support
To further support a successful transition to the Common Forms, NIH is postponing the May 25, 2025 implementation for all applications and Research Performance Progress Reports (RPPRs). NIH will issue future Guide Notices outlining the new effective date and details as they are finalized. NIH applicants and recipients must continue to use the current NIH Biosketch and Other Support format pages for applications, Just-in-Time (JIT) and RPPRs. Read more from NIH.
March 11: Consolidation of study sections under Center for Scientific Review
Announced late last week, NIH is planning to move all of its study sections under the oversight of the agency’s Center for Scientific Review (CSR). Under the new plan, CSR would conduct all first-level reviews, eliminating institute-based study sections. NIH said this cost-cutting effort was planned before the change in administration occurred. CSR has begun posting study section meeting notices to the Federal Register. Read more from NIH.
March 7: Foreign Assistance Review emails
We are aware that some UK investigators have received emails requesting they undertake a “Foreign Assistance Review” from federal agencies. If you receive a such an email, please do not respond but instead send that federal agency communication and any other questions specifically related to research awards to ospa@uky.edu and vpr@uky.edu and those offices will communicate with you to coordinate any required response.
Feb. 26: NIH resumes Federal Register notices
The NIH released a statement saying the agency could now "begin sending notices incrementally to the Office of the Federal Register to advertise meetings of scientific review groups/study sections and begin their resumption." The agency planned to submit Federal Register Notices for the next 50 meetings, according to the statement. That will allow for the first phase of grant application reviews to start to resume. But Federal Register notices for other types of meetings remain "on hold," which means the later stages of grant review remain frozen.
Feb. 21: Federal Judge Extends Pause on Cuts to NIH Indirect Costs
A federal judge has kept in place an order blocking the administration from implementing a cap on how much indirect costs the National Institutes of Health pays grant recipients. The temporary restraining order was set to expire on Monday, Feb. 24, and has been extended until U.S. District Judge Angel Kelley can make a final decision on whether to issue an injunction on the proposed change. Read more on nytimes.com. UK community members have free access to digital versions of the New York Times and Wall Street Journal by subscribing through UK Libraries.
Feb 19: Federal Register hold on submissions
We have been made aware that there is a hold on submissions to the Federal Register, where public notices of upcoming meetings — including NIH study sections — are required by law to be posted. We are also aware that some study sections have been cancelled. We are monitoring the situation and will provide more detail when available. Read more on thetransmitter.org.
Feb 15: Update from NIH to study section reviewers
To align with new administration guidance:
- Do not evaluate, score or factor into final scoring the Diversity Plan section.
- Reviewers must evaluate as usual the scientific justification for Inclusion of Women, Minorities and Individuals Across the Lifespan in applications with human subjects (excluding research that qualifies for Exemption 4).
- Reviewers must evaluate as usual SABV (sex as a biological variable) in vertebrate animal and human studies.
Feb. 12: National Institute of Justice (NIJ) guidance on projects that ask about “gender”
NOTE: This guidance currently only applies to National Institute for Justice (NIJ) grants. However, other federal grantmaking entities may issue similar directives in the future.
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 development or 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 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.
- 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.
- If administration is ongoing, pause administration and change the question(s) to comply with the above Instruction.
Your timely compliance is appreciated. Failure to comply with this directive may affect the award.
Feb. 11: Judge Halts Cuts to NIH Indirect Costs
A federal judge in Boston ordered a nationwide temporary pause on plans by the National Institutes of Health to substantially slash indirect cost reimbursements for research to universities, medical centers, and other grant recipients. Read more on statnews.com.
Feb. 10: NIH Notice on Indirect Cost Rates
The National Institutes of Health (NIH) issued guidance on Feb. 7 regarding cuts to federal research grants. Specifically, the NIH announced it would cap the rate for what are known as “indirect costs” to 15% for all existing and new NIH contract awards. On Feb. 10, litigation was filed by multiple states challenging this decision.
If this policy change is enacted, it will impact the way we do research at the University of Kentucky. It will cost UK tens of millions of dollars annually and will hit our local and state economies. More important than any numbers, though, it will impact the work we do to advance the health of Kentucky in those areas most critical to our future — including cancer, heart disease, Alzheimer’s and substance use disorder.
How the university is responding:
- Our government relations team is meeting with our congressional delegation and others to communicate how fundamentally important and serious this issue is to our community and all those we serve through discovery and healing.
- Our cabinet, deans and other leaders are meeting regularly to confer on this and other issues to ensure we remain careful and prudent stewards of our resources — that we are moving thoughtfully to protect what we do and the future of our research enterprise.
- We will comply with all federal and state laws and policies. That is our responsibility. At the same time, we will forcefully advocate for what we do and our vital mission to advance this state. This includes advocating for the restoration of these critical research dollars.
- We will continue to keep you informed of important updates.
- See President's message: Potential Impact of Federal Research Cuts
Feb 5: eRA Commons Extension Unavailable
We typically extend NIH awards using the "Extension" option in eRA Commons. The extension option is currently not available. We checked several awards that should be eligible for an extension and the extension option wasn’t available. eRA Commons confirmed that further guidance is pending. In the meantime, we need to submit No-Cost Extension (NCE) requests directly to the NIH Grants Management Specialist (GMS). Please work with CGS and OSPA post-award staff to submit NCE requests via this new mechanism.
Feb 4: NIH Study Sections Resume
The National Institutes of Health (NIH) resumed some study sections to review grant applications. An NIH internal notice announced that as of Monday, Feb. 3 advisory councils are now permitted to hold closed sessions to discuss and approve funding for research projects, but not open sessions involving public presentations or discussions. See STAT article.
General Award Guidance
Unless you have received a notice to suspend activities for a specific award from a sponsor, you can continue your research activities.
Indirect Costs FAQ
How do indirect costs impact UK?
The NIH is the largest funder of health research in America. In the past five years the University of Kentucky — as a major health research and clinical institution — received an annual average of $159 million in NIH awards (grants and contracts).
Those awards fund basic science research into the diseases and illnesses that most impact Kentucky: cancer, diabetes, heart disease, children’s health, aging-related illness, opioid use disorder and many others.
Awards have two major components. There are direct costs — dollars directly associated with the scientific research in question.
And there are indirect costs — what are often called Facilities and Administration or F&A. Those are dollars associated with the award to pay for items that make that research possible. That could be the construction and outfitting of a lab, research equipment, utilities such as ventilation, heat and lighting, associated technology and graduate students who work in the lab setting.
That indirect cost or rate is negotiated for a period of time between an institution — like UK — and the NIH. Those rates range from 20% of the cost of a grant to 54%, depending upon the research being conducted and the terms of the award.
For example, a $1 million grant with a 37% indirect rate would mean that $1 million directly funds research; $370,000 ultimately goes to the university to allocate to pay those support costs, like facilities, equipment, technology and personnel. The structure for how those dollars can be used is very prescribed.
Cutting the rate to 15% — what the NIH has described as a benchmark for what private foundations that award grants provide — would cut tens of millions of dollars in essential support services to scientists and clinicians who are asking the most important questions about the biggest health challenges Kentucky faces. This one change, if enacted for the next 12 months, would represent a cut of at least $40 million to the University and its critical research efforts on behalf of the health of our state.
Too, the comparison between a private foundation providing a grant around research in education policy, for example, simply does not involve the same cost or cost structure as a basic science grant that could include building and lab space and all the supports that go along with that infrastructure. The complicated discovery and research our investigators perform cost more than the research often funded by private foundations.
Where can I find more resources about F&A?
The Council on Government Relations (COGR) has many resources on its website.
Notices from Agencies
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Common Forms for Biographical Sketch and Current and Pending (Other) Support (3.26.25)
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Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates: NOT-OD-25-068 (2.7.25)
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Office of Management and Budget (OMB) has rescinded M-25-13 (1.29.25)
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Message from the National Science Foundation (NSF) (1.28.25)
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Q&A from the Office of Management and Budget (OMB), on temporary pause (1.28.25)
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RESCINDED: Memorandum from the Office of Management and Budget, Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs (1.27.25)
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Pause on public communications from Department of Health & Human Services (DHHS) (1.21.25)
Messages from the President
- Our Principles and Priorities as Kentucky’s University (4.29.25)
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Update on Federal and State Issues (3.19.25)
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Update on Federal Policy Changes (1.29.25)
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Update on Federal Policy Changes (1.28.25)
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Monitoring Federal Policy Changes (1.24.25)
Messages from the Vice President for Research
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Resilience in Research (2.27.25)
Additional Resources & Contacts
- University of Kentucky Monitoring Federal Changes 2025
- Council on Government Relations (COGR) 2025 Administration Transition Information & Resources (cogr.edu)
- Association of Public & Land-Grant Universities (APLU) (aplu.org)
Contacts
- Researchers, please send federal agency communications you receive or any questions specifically related to awards to ospa@uky.edu and vpr@uky.edu.
- Employees, please communicate with your supervisors, directors, deans and unit administrators, who should elevate questions and concerns to the appropriate university leaders.
- Leaders and unit supervisors who have questions of law, specifically, should go to the General Counsel.
- Students, please reach out to the Office for Student Success.
- General questions can go to govquestions@uky.edu.

Costs of Federally Sponsored Research
Click below to download a PDF from COGR providing a comprehensive look at the costs of federally sponsored research.