Recent federal agency policy changes

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. 

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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. 

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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.

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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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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.

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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. 

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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.

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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.

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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