Recent federal agency policy changes

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support, and NIH Biographical Sketch Supplement will be required for all application due dates and Just-In-Time (JIT), Research Performance Progress Report (RPPR), and Prior Approval submissions on or after May 8, 2026.

The NIH set the deadline for use of the forms to Jan. 26, 2026, but extended a leniency period until May 7 after users experienced technical issues.

During the remainder of the leniency period, NIH will continue to provide system warnings and will not withdraw applications containing the: NIH Biosketch, NIH Other Support format pages, or non-compliant Common Forms. On May 8, 2026, system warnings will change to errors that will stop any submission not using compliant Common Forms. This timing will also provide applicants with additional time to address errors before the May 25 standard receipt date for Cycle 2.

Read notice.

CFR Part 75 continues to apply to NIH awards. Accordingly, NIH indicates that at this time, it “will not apply updated thresholds outlined within 2 CFR Part 200.”

As a result, NIH rescinds the following Uniform Guidance flexibilities included in prior guidance (NOT-OD-25-059 ):

• The updated Modified Total Direct Cost (MTDC) definition (including the $50,000 subaward threshold).
• The updated 15% de minimis indirect cost rate.

While the notice does not restate specific thresholds, NIH’s direction to apply 45 CFR Part 75 reflects a return to the prior framework for indirect cost calculations, including:

• MTDC with up to the first $25,000 of each subaward.
• A 10% de minimis indirect cost rate for eligible entities without a negotiated rate.

Note that the MTDC definition does not include the threshold for equipment. That threshold is in the equipment definition, and the prior guidance is, therefore, still in place:

2 CFR 200.313 (e) Equipment: NIH recognizes the updated threshold value for equipment, increasing from $5,000 to $10,000.

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Effective for applications submitted for due dates on or after May 25, 2026, applicants and recipients are required to use a new, simpler format for Data Management and Sharing Plans (NOT-OD-26-046).

The National Institutes of Health Data Management and Sharing Policy requires applicants to submit a Data Management and Sharing Plan (DMS plan) for any NIH-funded or conducted research that will generate scientific data. The new format is part of NIH's ongoing efforts to increase efficiency and minimize applicant burden.

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The NIH announced an updated policy for late submission of competitive applications. Specifically, it: 

• Ends continuous submissions after Aug. 10, 2026.
• Modifies reasons considered for late submission.
• Prohibits fellowship, small business and international collaboration late applications.
   

Late application submission policy

The updated policy will go into effect for submission due dates on or after May 25, 2026.

To be considered under the late policy, investigators must submit their applications within two calendar weeks of the original due date, even if there is more than one reason for the delay. NIH considers those two calendar weeks the late application period. If an application due date extends to the next business day because it falls on a weekend or federal holiday, the late application period is calculated from that business day.

Applications can be submitted during the late application period if all of the following are true:

• One or more of the PD/PIs listed on the application encountered extenuating circumstances that led to the missed deadline.
• The PD/PI's extenuating circumstances are documented in the cover letter submitted with the late application
• The application is in response to a program that allows late submission. NIH will not accept late submission for:
  • Fellowship (e.g., F30, F31, F32, F33, F99/K00) and small business (e.g., R41, R42, R43, R44, SB1, UT1, U44) applications that have the shortest processing time prior to review.
  • Collaborative International Research applications (e.g., PF5, UF5).
  • Any funding opportunity that states in the Key Dates section that late applications will not be accepted.

Investigators may also submit during the late application period, if within four calendar weeks before or after the due date, any PD/PI named on the application participates in:

• An NIH peer review study section or special emphasis panel.
• An NIH Board of Scientific Counselors, Program Advisory Committee or an NIH Advisory Board or Council.

This specific review service is the only pre-authorized reason for a late submission (i.e., automatically accepted once review service information provided in the cover letter is confirmed). Other types of NIH activities and services for other federal agencies or private organizations are not acceptable reasons for late submission.

Read more detailed notice.

NIH and other federal agencies use eRA and its suite of systems to award and manage grants.

To align with the Common Forms requirements detailed in NOT-OD-26-018, eRA has changed or enhanced:

• Prior Approval Change of PD/PI Request
• Just-in-Time (JIT)
• Research Performance Progress Report (RPPR) Participants section

The use of the Biographical Sketch and Current and Pending (Other) Support (CPOS) Common Forms and the NIH Biographical Sketch Supplement will be required for all individuals submitting one of the above documents, including all senior/key personnel, on or after Jan. 25, 2026.

See summary of changes.
 

Make sure to carefully review NIH notice of funding opportunity (NOFO) instructions.

NIH is no longer requesting or accepting letters of intent as part of the application process. Because the agency's Center for Scientific Review now centrally manages all application reviews, letters of intent that were previously requested in some funding opportunities to help institutes and centers estimate work loads and recruit reviewers are no longer needed.

NIH no longer requires applicants requesting $500,000 or more in direct costs (excluding consortium F&A costs) in any one budget period to contact the funding institute or center before application submission. In line with this change, applicants also are no longer required to include a cover letter identifying the program official and confirming the institute or center has agreed to accept assignment of the application.

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In an effort to support strong collaboration among federal research agencies, NIH is adopting the Common Forms for Biographical Sketch and Current and Pending (Other) Support per the White House Office of Science and Technology Policy memorandum.

Read this notice for details on the Common Forms, NIH Biographical Sketch Supplement and instructions for application due dates and Research Performance Progress Report submissions on or after Jan. 25, 2026. 

Note that individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP ) are not eligible to serve as senior/key personnel on NIH grants or cooperative agreements, effective Jan. 25. NIH will require MFTRP certifications from applicants and individuals identified as senior/key personnel with its implementation of the Common Forms for Biographical Sketch and Current/Pending (Other) Support.

NIH implementation of Research Security Training requirements outlined in the CHIPS and Science Act of 2022 goes into effect for applications submitted for due dates on or after May 25, 2026.

Senior/key personnel listed on an NIH grant application must certify that they have completed the training within 12 months of the date of application submission. NIH does not collect Current and Pending (Other) Support at the time of application based on our Just-in-Time policy. Therefore, NIH will collect the individual certification at the time of the application submission, through the Biographical Sketch in SciENcv.

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The NIH canceled more than 370 peer review meetings between Oct. 1 and Nov. 14. These meetings had enlisted more than 11,000 reviewers to review more than 24,000 applications.

To address the backlog of applications scheduled for peer review, the NIH is making the following emergency modifications to its review processes and policies that will remain in place through the May 2026 Advisory Council:

• Reducing the percentage of applications discussed in most meetings. This change will allow nearly all review meetings to run within one day and make recruiting reviewers and rescheduling meetings easier. Committees will vote for which applications to discuss in three groups:
  • The top third (30 to 35 percent) will be discussed in the review meeting and considered for funding.
  • The middle third will be designated as “competitive but not discussed” and considered for funding.
  • The lowest third will be designated as “not competitive and not discussed.”
     
• Simplifying summary statements, which will continue to provide the necessary information regarding applications’ scientific merit to advisory councils and program staff. Summary statements will have:
  • A sentence describing the degree of consensus in the committee vote.
  • Bullets describing the main score driving points.
  • Written critiques from the three assigned reviewers.
  • For discussed applications, the overall impact score.

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The NIH posted information on how agency operations are resuming after the government shutdown, including:

• Rescheduled submission dates and peer review meetings.
• Instructions for post-submission materials, research performance progress reports and other areas.

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The NIH is working to reschedule October and November deadlines for grant and contract submissions and dates for missed review meetings, training and other activities that were scheduled to occur during and immediately following the period of the government shutdown.

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On Sept. 11, 2025, the NIH announced that research security training would be required in January 2026.

Today the NIH rescinded its notice in an effort to coordinate with the National Science Foundation and other federal research agencies and finalize guidance on each of the required elements outlined in the Office of Science and Technology Policy Guidelines for Research Security Programs at Covered Institutions, and to develop a centralized process for recipients to certify compliance. An implementation date has not been set.

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The NIH has recognized that current application and award structures for subawards have failed to meet federal reporting and oversight needs. This has raised concerns for national security. To address these needs, NIH announced that it will no longer be accepting new applications that request funds for foreign components using the traditional grant subaward/consortium structure.

• Proposals with foreign components will be submitted to a new Notice of Funding Opportunity (NOFO).
• Proposals with foreign components will provide an:
  1. Overall component
  2. Research component
  3. International project component
• NIH is developing resources, including FAQs (coming soon). 

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Beginning Jan. 25, 2026, the NIH will require principal investigators, co-investigators and other key personnel to complete annual research security training within the 12 months preceding the date a grant application is submitted.

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NIH has re-enabled the no-cost extension functionality within eRA Commons. Recipients may resume initiating first no-cost extensions in eRA Commons.

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Starting Oct. 1, 2025, NIH grant recipients must provide training for faculty and researchers identified as senior/key personnel on the agency's new policy requirement to disclose all research activities and affiliations (active and pending) in the "other support" section of grant applications. See other support form.

The Division of Research is developing plans to comply with this policy and will be communicating with the grants community.

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The agency is providing guidance on the appropriate use of AI to in proposals to maintain the fairness and originality of the NIH research application process.

NIH also is instituting a new policy limiting the number of new, renewal, resubmission and revision applications that principal investigators can submit in a calendar year.

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The expansion is part of a broader initiative to prioritize human-based research and reduce reliance on animal models. Make sure to carefully read current and upcoming NIH funding opportunities for NAMs-related criteria. 

Guidance from Mizzou's Division of Research, Innovation and Impact

NIH issued a short-term extension to the early-stage investigator eligibility period.

This extension addresses delays impacting grant application submissions, peer review or award processing timelines between Jan. 1, 2025, and May 31, 2025, and seeks to mitigate their effects on the biomedical research community. 

Read notice

Keep on top of the latest changes affecting NIH grants administration and funding by bookmarking this page, which is updated as new information becomes available.

NIH has removed the automatic no-cost extension (NCE) feature from their website. All NCEs must now be requested via the prior approval module. 

Read notice

On May 5, 2025, the White House Executive Action on Biological Research directed federal agencies to end funding for “dangerous gain-of-function research” and develop a new oversight policy within 120 days. In response, the NIH released an updated notice on May 7, 2025, rescinding their previous DURC-PEPP policy implementation guidance. Other federal funding agencies have not yet published updated guidance. The DURC program oversees life sciences research that could be misused to harm public health or national security.

MU will continue to monitor developments and update the Institutional Biosafety Committee homepage as new information becomes available. 

NIH is updating its policy and practice on issuing foreign subawards. 

• The new policy will prohibit foreign subawards from being nested under the parent grant.
• This new award structure will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report.
• NIH anticipates implementing the new award structure by Sept. 30, 2025 (before fiscal year 2026).  

Effective May 1, 2025, and until the details of the new foreign collaboration award structure are released, NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation) that include a subaward to a foreign entity. 

Please note: PIs can eliminate the foreign subaward during this time, and funding will continue. 

Read notice  |  Read article

The U.S. Department of Health and Human Services and the NIH have announced a universal vaccine platform called Generation Gold Standard developed by NIH’s National Institute of Allergy and Infectious Diseases to create broad-spectrum vaccines targeting multiple pandemic-prone viruses like avian influenza (H5N1) and coronaviruses (SARS-CoV-1, SARS-CoV-2, MERS-CoV). 

The initiative aims to improve pandemic preparedness and vaccine effectiveness by focusing on long-lasting, cross-strain protection, beyond current virus strains. Key components of this platform include: 

• BPL-inactivated whole-virus vaccines that preserve the virus's structure while preventing infectivity, generating strong immune responses (B and T cells), and offering protection across various virus families
• Intranasal formulation of the BPL-1357 vaccine, which is designed to block virus transmission and is currently in advanced clinical trials, on track for FDA review by 2029
• Increased government-led transparency and the elimination of commercial conflicts of interest  

The BPL platform could be adapted for future vaccines against other respiratory viruses. Clinical trials for universal influenza vaccines are set to begin in 2026, with FDA approval targeted for 2029.

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NIH announced the compliance date for the revised public access policy will move up by six months, from Dec. 31, 2025, to July 1, 2025. All other aspects of the 2024 public access policy remain the same. 

NIH Director Jay Bhbattacharya issued a statement detailing the benefits of the change.

Read notice 

Sponsored Programs Administration received communication from NIH requesting the early submission of Research Performance Progress Reports (RPPRs ) to allow for processing time of notice of awards. We encourage PIs to submit their RPPRs two months prior to the end date. 

NIH announced its initiative to reduce the use of animals in NIH-funded research. This follows the FDA roadmap released in April, which discussed collaboration with the NIH.  

NIH Director Bhattacharya emphasized that innovations such as organoids, tissue chips and computational models allow for more accurate human-centric research, potentially improving health care outcomes and accelerating the development of treatments. 

As part of the initiative, the NIH will establish the Office of Research Innovation, Validation and Application (ORIVA) to oversee these efforts. ORIVA will focus on promoting non-animal research methods, increasing funding, and ensuring their integration into NIH's broader biomedical research programs.  

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NIH issued a notice that fund recipients must comply with all applicable federal anti-discrimination laws material to the government’s payment decisions. This term applies prospectively to new, renewal, supplement or continuation awards issued on or after April 21, 2025. 

By accepting grant awards, recipients certify that: 

• They do not, and will not during the term of the financial assistance award, operate any programs that advance or promote DEI, DEIA or discriminatory equity ideology in violation of federal anti-discrimination laws.
• They do not engage in and will not, during the term of the award, engage in a discriminatory prohibited boycott, as defined in the notice.  

The NIH reserves the right to terminate financial assistance awards and recover all funds if recipients operate any program that violates federal anti-discriminatory laws or engage in a prohibited boycott. 

Note: The notice applies only to grant award “recipients,” which the NIH defines as the entity that receives the NIH grant award. 

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The NSF Proposal and Award Policies and Procedures Guide (PAPPG) documents the agency's processes for the management of grants and cooperative agreements.

NSF announced it will defer release of the 26-1 version of the PAPPG, previously developed and planned for publication in fiscal year 2026, to ensure alignment with forthcoming Uniform Grant Guidance updates (Executive Order 14332: Improving Oversight of Federal Grantmaking requires the Office of Management and Budget (OMB) to streamline and transform the Uniform Guidance.)

While publication of the PAPPG has been deferred, NSF will continue to publish financial assistance policies to advance administration priorities, implement statutes, memorialize current practices and implement other time-sensitive matters. NSF will issue policy changes via NSF supplemental policy notices in the interim.

Contact the NSF Grants Policy Branch at policy@nsf.gov with questions and please check NSF.gov often for future updates.

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The NSF has established a series of research security requirements (NSF IN-149) to safeguard U.S. science and engineering in alignment with the CHIPS and Science Act of 2022 (P.L. 117-167) and National Security Presidential Memorandum-33 (NSPM-33).

NSF is offering a grace period for enforcement of NSF IN-149.

• The agency will accept proposals that include the earlier version of the Biographical Sketch and Current and Pending Support form between Dec. 2 and Dec. 31, 2025.
• Proposals submitted after Dec. 31 must be fully compliant with NSF IN-149 and will be required to include the latest version implemented under this policy.

To assist research organizations and investigators, NSF has published a Frequently Asked Questions webpage summarizing the new requirements, certification procedures and relevant timelines.

Starting Dec. 2, 2025, new NSF requirements will take effect. 

What you need to know:

• Proposals submitted before Dec. 2, including those submitted during the recent lapse in appropriations, are not subject to requirements originally set to take effect Oct. 10.
• As of Dec. 2, new certifications are required at the time of proposal submission within the cover sheet, biographical sketch and current and pending (other) support forms, including:
  • Completion of research security training by all senior/key personnel.
  • An institution's status regarding contracts or agreements with any Confucius Institute.
• Organizations are required to provide supporting documentation, including copies of grants, contracts and agreements, upon request by NSF.
• Consult NSF's frequently asked questions webpage for more information about these new requirements, certification procedures and timelines.

Read notice

Beginning Oct. 10, 2025, NSF will require principal investigators, co-investigators and other key personnel to complete annual research security training within the 12 months preceding the date a grant application is submitted.

See more details and instructions

A federal district court has ruled that NSF’s 15% indirect cost cap on research grants is invalid.

Read memo

NSF has agreed to continue the pause of the implementation of the 15% indirect cost cap until June 20, 2025. MU will continue submitting proposals and accepting awards with our federally negotiated rate. 

See court docket

Check this resource regularly for updates on priorities and executive orders.

The U.S. National Science Foundation (NSF) informed organizations of a new annual certification requirement for principal investigators (PIs) and co-principal investigators (co-PIs) regarding malign foreign talent recruitment programs (MFTRP).

Starting on June 7, 2025, in accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii), all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to an MFTRP. Individuals who are currently a party to an MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. NSF is providing notification of this new requirement to impacted PIs and co-PIs. 

What you need to know:

• There is no organizational certification requirement, the certification requirement is for PIs and co-PIs.
• Impacted PIs and co-PIs will be prompted to complete the MFTRP certification after signing into Research.gov with their login credentials.
• PIs and co-PIs with more than one active award made on or after May 20, 2024, are only required to certify once, annually.
• Once completed, PIs and co-PIs can view their MFTRP certification response under the Academic/Professional Information section of their profile.
• NSF plans to extend this requirement to all senior/key personnel in the future. Additionally, NSF is working to provide organizations with access to the annual certifications.
• Please see PAPPG Chapter II.D.1.d(ix) for information about Authorized Organizational Representative (AOR) responsibilities regarding senior/key personnel MFTRP certifications.
• Frequently asked questions and MFTRP contract examples will be available soon on the MFTRP section of the Office of the Chief of Research Security Strategy and Policy website. 

Need help?

• For additional guidance about this requirement, contact researchsecurity@nsf.gov.
• Technical issues should be directed to the NSF IT service desk at 1-800-381-1532 (7 a.m.-9 p.m. ET Monday-Friday except federal holidays) or rgov@nsf.gov.

NSF has agreed to pause the implementation of the 15% indirect cost cap to avoid a potential preliminary injunction. The cause is now set for a summary judgement on June 13. MU will continue submitting proposals and accepting awards with our federally negotiated rate. 

Read notice

On May 2, 2025, NSF distributed a new policy limiting indirect costs to 15% (Mizzou’s current indirect rate for on-campus research is 56.5%). NIH and the Department of Energy also proposed similar caps, which were challenged in court and are currently restrained. A lawsuit of 18 parties has been filed to challenge this new policy. At this time, we will continue to utilize our federally negotiated rate for NSF proposals.

Read policy

Starting Dec. 22, 2025, the purchase and operation of drones manufactured or assembled by certain foreign entities will be prohibited in some federally funded university contracts. Get Mizzou policy details and see federally cleared drone manufacturers.

Background
On November 12, 2024, the federal government prohibited the procurement and operation of unmanned aircraft systems (UAS, also known as drones) that are manufactured or assembled by designated foreign entities. This restriction is outlined in Federal Acquisition Regulation (FAR) clause 52.240-1. This FAR clause, along with Department of Defense (DOD) 1260H restrictions, imposes strict limitations on drones associated with certain foreign entities, including popular brands like DJI (Shenzhen DJI Innovation Technology Co. Ltd.)

A temporary restraining order has been issued pausing the implementation of the DOD’s 15% indirect cost cap. 

See notice

A lawsuit has been filed challenging the recent DOD indirect cost limitation of 15%.

See complaint

A DOD memo dated June 12, 2025, states the agency will implement a 15% indirect cost cap on new awards and will renegotiate the indirect rate on existing awards. We anticipate a lawsuit will be filed for this action as well. At this time, we will continue to utilize our federally negotiated rate for DOD proposals.

Read memo

On May 14, 2025, the DOD distributed a memo with a plan to limit indirect costs to 15%. NIH, Department of Energy and NSF also proposed similar caps, but they were challenged in court and are currently restrained. We anticipate a lawsuit will be filed for this action as well. At this time, we will continue to utilize our federally negotiated rate for DOD proposals.

Read memo