Federal Executive Orders (EOs) & Other Policy Directives

Last updated: June 13, 2025

This page will be updated as new information is available related to federal executive orders, court actions, and other policy directives that impact the University of Minnesota research community. Sponsored Projects Administration (SPA) and the Research and Innovation Office (RIO) remain in close communication with the UMN Federal Relations team and other UMN partners, peer institutions, and national associations to monitor these impacts and to advocate for the needs of the University community.
 
 

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Recent Legal Updates & Current Guidance for UMN Researchers

DoD Announces 15% Indirect Cost Cap on Higher Education Awards (Updated 6/13/25)

The Department of Defense (DoD) has issued a memo announcing the Implementation of a 15% Indirect Cost Cap on Assistance Awards to Institutions of Higher Education. DoD had previously shared plans to implement the rate cap but had not formally announced it.

The 15% indirect cost (F&A) rate cap applies to new awards effective immediately. DoD states that existing DoD grants and cooperative agreements will need to be renegotiated by no later than 11/10/25. At this time, we can continue to charge our negotiated F&A rates on existing grants.

The University of Minnesota has not approved the submission of proposals or acceptance of new awards at the 15% rate. Principal investigators (PIs) should continue to budget normally using the University's federally negotiated rates.

PIs should not take any action if they are contacted by the DoD sponsor. If contacted, they should forward the communication to their SPA Grant and Contract Officer (GCO) and copy both David Hagen and April Coon on the email. SPA staff will determine whether there is any action required.
 

Unsolicited Inquiries from NSF (Updated 6/13/25)

SPA staff have heard about multiple cases recently of National Science Foundation (NSF) personnel reaching out directly to principal investigators (PIs) and asking them to: a) modify their scope of work, b) certify their adherence to NSF’s new priorities, and/or; c) certify their adherence to Federal anti-discrimination statutes.

If you receive such a request, please contact your SPA Grant and Contract Officer (GCO) immediately. Please also copy your associate dean for research on any such correspondence. SPA GCOs will coordinate with their managers and with PIs in developing a compliant response.

The requested scope changes may involve a request to remove DEI-related activities. While work scope changes do not need to go through SPA, SPA staff can assist in coordinating appropriate responses.
 

NIH Rescinds "Notice of Civil Rights Term and Condition of Award" (Updated 6/12/25)

On June 9, the National Institutes of Health (NIH) rescinded Guide Notice “Notice of Civil Rights Term and Condition of Award” (NOT-OD-25-090). NIH is awaiting further Federal-wide guidance and will provide a future update to the extramural community. The previous guidance is no longer in effect.

Questions about specific awards may be directed to your SPA Grant and Contract Officer.

Update: This notice was removed from the NIH website, and the previous guidance is still in effect.
 

NSF Policy Notice to Implement a 15% F&A Rate (Updated 5/23/25)

On May 2, the National Science Foundation (NSF) issued a Policy Notice implementing a standard 15% Indirect Cost Rate (or F&A rate) on modified total direct costs (MTDC) for Institutions of Higher Education (IHE). It also states that NSF funding opportunities issued after May 5, 2025 will include notice of this policy change. NSF asserts that this new policy overrides previously negotiated rates for all awards. A lawsuit contesting this F&A reduction is pending. NSF has agreed not to require the 15% cut pending a court hearing on June 13. 

Until further notice, PIs may continue spending on existing awards using the F&A rate shown on the Notice of Grant Award and approved budget. This policy change does not impact awards issued prior to May 5, 2025.

For proposals that need to be submitted immediately, PIs should continue to budget normally using our federally negotiated rates. More information will be shared as it becomes available.
 

Updated DoD Decision Matrix (Updated 5/14/25)

The Department of Defense (DoD) published an updated Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions, effective for all proposals submitted on or after May 9, 2025. The updates include removing the requirement for institutions to have a policy prohibiting participation in a malign foreign talent recruitment program, changing some of the dates that would trigger expected or suggested mitigation measures, and removing the distinction between “associations” and “affiliations.”
 

NIH Policy Change on Foreign Subawards (Updated 5/8/25)

On May 1, the National Institutes of Health (NIH) issued an Updated Policy on Foreign Subawards that significantly changes how foreign collaborations will be structured in NIH-funded research. Existing awards are not currently affected, but starting May 1, 2025, NIH will not approve new foreign subawards or components under existing grants. Institutions receiving NIH grants will not be permitted to issue subawards to organizations based outside of the United States. The policy applies only to financial arrangements. It does not affect collaborations with foreign consultants or purchases of unique goods or services from international vendors.

For Principal Investigators:

  • If your new project includes a foreign subrecipient, this change will require restructuring the collaboration as an independent subproject rather than a subrecipient.
  • If your ongoing project includes a foreign subrecipient, a restructuring of the collaboration with the foreign entity will be required at the time of renewal or non-competing continuation.
  • For studies that rely on international fieldwork or expertise (e.g., infectious diseases endemic to specific regions), replacing foreign components with domestic partners may not be feasible.

More information may be found in the May 8 memorandum from April Coon and David Hagen.
 

Executive Order on Improving the Safety and Security of Biological Research (Updated 5/7/25)

On May 5, President Trump issued the Improving the Safety and Security of Biological Research Executive Order (EO). This order pauses research that could make a naturally occurring pathogen or toxin more dangerous to American citizens and directs federal agencies to develop a new policy within 120 days. The new policy is intended to replace the 2024 Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential (DURC-PEPP Policy) and supersedes its previously set May 6, 2025 implementation. 

This EO is far more broad reaching than the DURC-PEPP policy. All investigators conducting research involving infectious agents or toxins should review the EO and be prepared to evaluate the new policy when it is released to understand how their work will be impacted. The NIH has released a notice (NOT-OD-25-112) to specify that it intends to suspend ongoing funding in accordance with guidance developed under Section 3(b) of the Executive Order. Also, the NIH will not accept competitive applications for grants and cooperative agreements submitted for due dates after 5/7/25 and/or R&D contract proposals submitted to solicitations issued after 5/7/25 for dangerous gain-of-function research. Please read the notice and visit the University's DURC-PEPP webpage for more detail. 
 

NSF Award Terminations and Statement of Priorities (Updated 4/21/25)

On April 18, the National Science Foundation (NSF) issued a Statement of Priorities reaffirming its commitment to supporting research aligned with its mission and statutory obligations. This includes continued use of the Intellectual Merit and Broader Impacts review criteria, as well as emphasis on broadening participation in STEM in ways that "create opportunities for all Americans" that do not "exclude individuals or groups based on protected characteristics."

As part of this shift, NSF has also undertaken a review of its award portfolio and notified institutions of the termination of specific awards that the agency has determined no longer align with current NSF priorities. This action, effective immediately, was made under the “Termination and Enforcement” clause of NSF’s General Conditions (GC-1). At the University of Minnesota, six awards have been terminated as of April 18, 2025.

We are closely monitoring the situation, including any further guidance or implications this may have for active or planned proposals. NSF has already shared some guidance in its FAQs

More information may be found in the April 21 memorandum from April Coon and David Hagen
 

DOE Policy Flash to Implement a 15% F&A Rate (Updated 4/16/25)

On April 11, the Department of Energy (DOE) released a Policy Flash (2025-22) that instructs DOE contracting offices and grants offices to implement a 15% F&A rate for institutions of higher education. The memo stated that the DOE will no longer use a University's federally negotiated indirect cost rate and will instead use a standardized 15% indirect cost rate. DOE has said that they intend to terminate all existing awards that do not use the 15% rate, but that recipients will receive separate notice and guidance.

On April 14, a legal challenge contesting this F&A reduction was filed jointly by the American Association of Universities, the American Council on Education, and the Association of Public and Land-Grant Universities, along with several impacted research universities. And on Wednesday, April 16, the US District Court of Massachusetts issued a temporary restraining order that prevents the DOE from implementing the changes in the Policy Flash.

Until further notice, PIs may continue spending on existing awards using the F&A rate shown on the Notice of Grant Award and approved budget.

If a termination notice is received within the coming days or weeks from DOE or anyone other than SPA, immediately send it to your SPA Grant and Contract Office and copy April Coon ([email protected]) and David Hagen ([email protected]).

More information may be found in the memorandum from April Coon and David Hagen.
 

Stop Work Orders and Terminations and Associated Appeals (Updated 5/2/25)

As of May 2, the University has received 79 terminations or full stop work orders and there are additional partial orders impacting a project by stopping certain work, temporarily halting payments, eliminating outyear funding, or otherwise modifying the terms under which work can be conducted. Each communication is being evaluated to ascertain whether the University can legally “push back” on the specific action, given the evolving status of the temporary restraining orders and preliminary injunctions. Where a case can be made, and with the PI’s concurrence, the University will submit appeals.
 

NIH Rate Cut Continues To Be Paused (Updated 3/18/25)

On March 5, a preliminary injunction replaced the original February 21 temporary restraining order and extended the prohibition against NIH implementing a 15% F&A cap until further notice. The preliminary injunction applies to all institutions nationwide, and applies to both current and future awards. In addition, the existing federal appropriations Continuing Resolution (CR) for FY2025 includes the same language as in recent past years restricting NIH from altering the way they calculate F&A. This means that the University of Minnesota will continue to use our federally negotiated rates (e.g, 54% MTDC for on-campus research) in all proposals and awards, as well as continue to accept federally negotiated rates from our subrecipients.
 

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UMN Guidance for Proposals, Awards, & Spending

Proposals (Updated 3/17/25)

Check the agency’s funding websites or Grants.gov to verify availability and search for updates to your funding opportunity announcement (NOFO) or request for proposal (RFP). If the agency or NOFO/RFP has an alert system, consider signing up for it. In general, and if the opportunity continues to be available in a federal system, proposals should continue to be prepared and submitted normally. Some agencies (e.g. USDA NIFA and AFRI, NIH Diversity Supplements) have currently removed access to funding announcements or Grants.Gov packages. In these cases, proposals to these agencies and programs will not be able to be submitted. If they choose to apply, PIs should adopt modified forms or requirements if an agency has modified these to comply with one or more of the Executive Orders.

Updated: If they choose to apply, PIs should adopt modified forms or requirements if an agency has modified these to comply with one or more of the Executive Orders.
 

Pre-Award Accounts/Advance Accounts/Early Spending

Pre-award and advance accounts continue to be available. Departments may wish to exert extra caution before approving spending prior to award receipt and acceptance. This includes continuation awards or incremental funding actions as well as awards anticipated but not yet received, or awards received but still under negotiation by the University. Any costs incurred prior to award acceptance remain the risk decision of the department.

Unless SPA tells you otherwise due to an agency stop work order, existing obligated funds shown on your Notice of Grant Award (NOGA) and approved Peoplesoft budget can be expended. No information is available about delays/impacts to anticipated-but-not-yet-committed funding from federal agencies. This includes continuation awards, supplements, renewals, or planned increments of funds. It is recommended that, absent a compelling reason, departments defer beginning or extending work beyond already approved/funded levels. This is particularly true if the subject matter or content of the award is closely related to restricted or impacted activity under one or more Executive Orders (e.g., foreign financial assistance activities, DEIA programs or activities). 
 

Awards

Work on awards should continue normally and terms/conditions remain intact unless specific official direction is given to the contrary. If you receive direction from your Program Officer to make a change to your scope of work or to what may be charged, immediately contact your SPA Grant and Contract Officer. Ensure timely completion of reports and deliverables, prioritizing the submission of any technical reports or deliverables that are past or soon-to-be due.

SPA will also send you official guidance about changes that agencies impose on individual projects typically via a revised Notice of Grant Award (NOGA) or via a combined email and NOGA. Sponsored Financial Reporting will continue to bill normally. At this time, changes to approved awards should not be made based on news articles, peer discussions, copies of communications transmitted within an agency (but not yet directed to award recipients), or other informal mechanisms.

Previous Updates Related to Federal Executive Orders (EOs) & Other Policy Directives

COGR Summary of Executive Orders
COGR maintains a listing of Executive Actions issued by the federal administration and their potential impacts on research activities.
 

Court Action Relative to the Executive Orders on DEIA (Updated 3/24/25)

On Friday, March 14, the US Court of Appeals for the Fourth Circuit enabled the federal government to terminate or change award terms if those awards contain Diversity, Equity, or Inclusion (DEI) activities. The 4th Circuit also enabled the resurrection of certifications that the University does not engage in unlawful DEI activities as a condition of federal funding. This development occurred when the 4th Circuit issued a stay on the nationwide preliminary injunction related to the DEI Executive Orders (EOs) that was previously issued by the federal district court in Maryland. The appeal to the 4th Circuit will continue while the stay is in place, but the University's Office of the General Counsel (OGC) believes that the most likely timeline for an outcome to that appeal will not be until the end of April or possibly May.

The University is currently working on how to most appropriately respond to this change. PIs will be notified if an award arrives with terms that require discussion. The most current information at this time may be found in the memorandum from Pamela Webb and April Coon.
 

Implementation of DOGE Cost Efficiency EO - Impact for Payments from HHS (Updated 3/18/25)

As of March 17, Health and Human Services (HHS) will require that all payment requests submitted through the Payment Management System (PMS) include a justification for the basis for each payment. NASA, who also uses this payment system, has notified us that they are working to provide guidance as well. This is consistent with the Executive Order implementing DOGE that requires agencies to build a centralized technological system to enable the Agency Head to pause and rapidly review payment requests. At this time, PIs do not need to take any additional action as the required information is being furnished by Sponsored Financial Reporting. The degree of detail required to justify each payment is evolving and PIs and units will be engaged if needed. See more information about this Executive Order below
 

Current Status of 2025 Federal Budget (Updated 3/17/25)

A Continuing Resolution was signed on March 14, solidifying funding for the remainder of the federal government's fiscal year 2025, ending on September 30, 2025. Information about specific cuts to specific agencies or programs will be forthcoming. The NIH F&A 15% proposed rate is not expected to re-occur during the current federal fiscal year but this issue is expected to arise again based on further legal action and future appropriations language.

Memos from University Officials

June 13, 2025: DoD Announces 15% Indirect Cost (F&A) Rate Cap - from April Coon and David Hagen

June 13, 2025: Unsolicited Inquiries from NSF - from April Coon and David Hagen

May 29, 2025: Delayed Award Setup for NIH and NSF Grants- from April Coon and David Hagen

May 23, 2025: Federal Funding Updates

May 14, 2025: Federal Funding Updates

May 8, 2025: NIH Policy Change on Foreign Subawards - from April Coon and David Hagen

May 2, 2025: NSF Policy Notice to Implement a 15% F&A Rate - from April Coon and David Hagen

April 21, 2025: NSF Award Terminations and Statement of Priorities - Monitoring and Next Steps - from April Coon and David Hagen

April 16, 2025: DOE Policy Flash to Implement a 15% F&A Rate - from April Coon and David Hagen

March 24, 2025: Supporting Our Research Community Amidst Changing Federal Actions - from VPR Shashank Priya

March 24, 2025: DEI Executive Orders Reinstated – from Pamela Webb and April Coon

March 4, 2025: Navigating the complex federal landscape from President Cunningham

February 27, 2025: Federal Developments Related to Research Projects

February 18, 2025: NIH 15% Indirect Cost Rate Cap – from Pamela Webb and David Hagen

February 11, 2025: Temporary Restraining Order (TRO) on NIH Indirect Cost Rate Change – from Pamela Webb and April Coon

February 10, 2025: In support of our research enterprise – from UMN President Rebecca Cunningham

February 8, 2025: Important Update: NIH Guide Notice – from VPR Shashank Priya on NIH announcement

February 7, 2025: Clarification and Update on Survey Request for Federally Funded PIs - from Pamela Webb and JoonHyung Cho

February 5, 2025: Memorandum with updated information - from Pamela Webb and JoonHyung Cho 

February 3, 2025: Message from President Cunningham about Diversity, Equity and Inclusion, and International Scholars

February 3, 2025: Federal Immigration Policies — Support and Resources

January 31, 2025: Message from EVP Gregg Goldman on Changes in Federal Immigration Policies

January 29, 2025: Memorandum from Pamela Webb and JoonHyung Cho

January 29, 2025: A message to the University community from President Cunningham addressing federal policy changes (Video)