Recent federal agency policy changes

In fiscal year 2027, the National Institutes of Health (NIH) will no longer allow letters of support but will instead require letters of collaboration to document any collaborative relationships with individuals who are not identified in the application as senior/key personnel or other significant contributors (Forms J). This policy change, which is part of the agency's ongoing efforts to increase efficiency and minimize applicant burden, is aligned with the format currently used by the National Science Foundation.

Letters of collaboration will be used to document other relevant contributions to the project's success, such as material transfer agreements. Letters designed to endorse the application without an intent to collaborate or provide material support will no longer be permitted in NIH grant applications.

Letters of collaboration should not be provided from trainees or staff in the laboratory of the program director/principal investigator(s), including graduate students, postdoctoral fellows and technicians. When Forms J are implemented, applicants should disregard any NOFO-specific instructions regarding content pertaining to letters of support as those instructions will be superseded by the new guidance.

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The NIH is soliciting public input on a proposed policy that would cap the number of research project grants (RPGs) an individual can simultaneously serve on as a principal investigator (PI) or multi-principal investigator (MPI)

The NIH must ensure that it uses funding approaches that maximize scientific productivity and innovation. One way to do this is through policies that allow the agency to support a greater number of investigators.

Respondents can provide feedback on any or all of the topics listed below (or any other relevant topics):

• Pros and/or cons of the policy
• The optimal number of RPGs for the cap (2, 3 or 4)
• Strengths and weaknesses of the proposed implementation strategies
• Possible unintended consequences or policy loopholes

Submit comments electronically by Aug. 3, 2026. 

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NIH issued this notice to clarify that it has not expanded the definition of a foreign component, despite recent questions from the research community. A foreign component is defined as the performance of any significant scientific element or segment of a project outside the United States — whether or not grant funds are expended. This includes involvement of human subjects or animals at a foreign site, extensive foreign travel for data collection, or collaborations with foreign investigators anticipated to result in co-authorship.

NIH notes that most instances of co-authorship represent a foreign component, but recognizes that minor contributions (such as providing a single reagent) may not rise to that level. Recipients should report any foreign co-authorship to their NIH funding Institute or Center as soon as they become aware of it.

Researchers are also reminded to check the Notice of Funding Opportunity (NOFO) for each award, as some — such as IDeA program grants — do not permit foreign components at all. Additionally, NIH reminds recipients to acknowledge federal funding in all publications per the Stevens Amendment, accurately attribute publications only to grants that actually supported the work, and list correct institutional affiliations on publications.

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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.

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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.

As part of ongoing efforts to strengthen research security, the National Science Foundation (NSF) is preparing to implement a new research security policy prohibiting collaborations on NSF-funded projects with entities on the U.S. restricted parties list. The policy will go into effect some time during the federal government's upcoming fiscal year (October 2026 through September 2027).

Under the new policy:

• NSF-appropriated funds may not be used for grants, contracts, other transactions or other assistance to an organization if the purpose is to conduct research in collaboration with restricted entities. This funding prohibition also extends to the employees of such restricted entities.
• Senior/key personnel are prohibited from holding an appointment or position with, or receiving research support from, a restricted entity. Further, senior/key personnel are prohibited from collaborating with a restricted entity and its employees on research funded by their NSF award.

The university's Research Security and Compliance team has tools to identify these restricted parties, which they use when reviewing proposals and awards with international activities. Please email researchsecurity@missouri.edu with questions.

Read announcement. 
 

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. 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.

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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