New Administration
Federal Funding Updates

• ORS will continue to submit proposals.
• While federal agencies navigate any pauses in funding in specific areas, sponsor proposal review timelines may be extended.

How to Prepare:

• Changes to proposal deadlines may occur. Please double check deadlines.
• Make sure that funding announcements have not been changed or postponed. If available, signing up for alerts from the agency or sponsor is highly recommended.

• Changes to research compliance requirements are anticipated. The update may be implemented by the federal agency/sponsor or may require an amendment on a project-by-project basis. Any information will be shared with the PI. It is important to quickly ensure compliance, as it could jeopardize funding.
• Changes to award reporting requirements are anticipated, either directly by the federal agency/sponsor or may require an amendment on a project-by-project basis. Failure to act promptly could jeopardize funding.
• If specific programs are terminated or restructured, PIs may encounter difficulties accessing funds or meeting new criteria. Typically, federal agencies managing these programs will issue guidance on how to proceed.
• If a program or initiative is reduced or defunded, there could be delays or pauses in payments for existing grants under those programs. While this is rare, it may occur if funding for a program is rescinded or redirected.
• If specific programs are terminated or restructured, you may encounter difficulties accessing funds or meeting new criteria. Federal agencies managing these programs will typically issue guidance on how to proceed. We will pass this along promptly if/when received.

How to Prepare:

• Review the Award Agreement. Ensure the terms are understood, especially clauses related to funding availability and reimbursement.
• Closely monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to availability of funds and should not be considered guaranteed.
• Maintain communication as appropriate with the federal sponsor’s program officer and forward any important information to ORS.
• Reports and Deliverables. Prioritize the submission of any technical reports or deliverables that may be past due.
• Monitor Policy Updates. Look out for announcements from the federal agency overseeing your grant for any updates on funding or compliance requirements.

ORS Advance Account Requests

• Requests to ORS for advance accounts for federal funding should be carefully considered and limited given the current uncertainties.
• Effective immediately, departments shall ensure requests for advance accounts of federal funds include only the essential and minimal amount needed for the immediate future. These amounts will be limited as follows:
  • Duration: Up to three (3) months of operating expenses per request. Projects determined to be high-risk may be limited to one (1) month advance periods; and
  • Budget: Up to a three (3)-month proration or 25% of the total anticipated award amount (whichever is less). Detailed budgets and budget narratives will be required.
• High-risk awards may require additional approvals at the chancellor level.

UH Campuses / System

• Upon receipt of a termination or stop work order, the Office of Research Services (ORS) notifies the Principal Investigator (PI) and Fiscal Administrator (FA). In cases where the termination or stop work order is issued directly to the PI, the PI shall immediately notify ORS.
• Potentially, a termination or stop work order may have been issued but NOT received by the PI or ORS. If the PI believes their project may be affected or if there is reason for concern, he/she shall notify his/her ORS Contracts & Grants Specialist to inquire further with the sponsor.
• The PI assesses project implications, especially for progress-to-completion, payroll implications, including affected graduate students, and compliance and safety requirements.
• The PI informs the department chair and the dean/director. For UH System awards, PIs should contact their appropriate vice president, while vice presidents should contact the Vice President for Research and Innovation, if further assistance is required.
• The college / unit makes a first assessment and decides whether RTRF reserves can be utilized to provide for the necessary time notifications to unionized employees per the collective bargaining agreement;
  • Please consult with UH Office of Human Resources (OHR) or the RCUH Office of Human Resources regarding required notifications.
  • RCUH employees need to be notified per RCUH policy 3.285 RCUH Termination of Employment.
  • If your college / unit does not have RTRF reserves, a request should be made to the campus (provost, chancellors) for consideration in using available campus RTRF reserves.
• Principal Investigators should direct graduate students to apply to the Graduate Student Success Fund emergency relief fund for temporary salary relief. There is a limited amount of funds established for this purpose. To apply please contact the Office of the Vice Provost for Research and Scholarship at UH Manoa at ovprs@hawaii.edu.
• During the stop work order period, the PI and dean should determine if affected employees can be appropriately reassigned to a new project; if FTE can be reduced (in case of multiple accounts only use the ones where there is no stop work order); or if the employee will need to be terminated.
• If personnel termination becomes necessary, the PI and/or employee supervisor should contact the OHR or the RCUH Office of Human Resources for further consultation, other employment opportunities within the UH System, and information on benefits.
• ORS shall immediately notify all subrecipients of the termination or stop work order, and appropriate steps may be needed to terminate or stop work on the subaward.
• All fiscal transactions must cease and/or be cancelled in compliance with the terms of the termination or stop work order.

Compliance Assessment

• Inventory all compliance protocols (such as human research, vertebrate animal research, biosafety, etc.) that may be impacted by a stop work order or termination notice.
• Work with the relevant review board on protocol-specific requirements for project close-out, as these will vary depending on the nature of the work and regulated activities. Any proposed changes to a protocol, including early close-out, must receive prior approval by the appropriate board (i.e. IRB, IACUC, IBC) before they are implemented.
• If a protocol is ending early due to funding changes, provide a final report to the relevant board with the revised end date. Include a description of how the work was terminated in a safe and compliant manner.
• Patient / animal safety should be addressed for an orderly closeout.
• Document all costs of termination, as recovery may be available depending on the contract or grant.

Closeout

• Identify and record all allowable costs incurred prior to the termination date (§200.343) and any costs that would not have occurred had the award not been terminated (§200.472).
• Review all outstanding obligations. All reasonable efforts should be made to discontinue or cancel such obligations and written documentation should be maintained. If certain costs cannot be discontinued or cancelled immediately after the effective termination date, such obligations may be considered an allowable termination cost under §200.472. Other costs that may qualify under §200.472 include:
  • Loss of value of special tooling, machinery, and equipment
  • Rental costs under unexpired leases
  • Settlement expenses including termination and settlement of subawards
  • Indirect cost allocable to such settlement expenses
  • Administrative costs associated with any closeout activities
• PI should develop a written closeout cost budget and obtain approval from the sponsor.
• Costs incurred after the termination date that have not been approved by the sponsor shall be transferred to an RTRF account or other available funding sources.
• Confirm closeout as soon as possible.

Appeals

• If the PI determines that an appeal would be feasible, the notice of award, sponsor’s regulations and applicable statutes should be reviewed to determine the allowability and process for submitting an appeal. If warranted, the request for an appeal should be submitted to the assigned ORS Contracts & Grants Specialist. ORS will obtain confirmation from the applicable dean/director that bridge funding is available to support the program while the appeal decision is being considered by the sponsor, then work with the University officials and general counsel to approve the appeal request before submitting it to the sponsor.

Other Fiscal Considerations

• Continue to exercise fiscal constraint on federally-funded projects, especially those that may be at high risk of being terminated. Difficult decisions may need to be seriously considered, such as delaying/pausing the hiring of new employees, travel, making large expenditures, and the issuance of new/continuation subawards and vendor subcontracts.
• Ensure that all project costs are being charged directly to project accounts in a timely manner to reduce the need for after-the-fact transfers. Projects may not be able to move expenses after a termination or stop work order is received. The PI and FA should coordinate with ORS accounting to ensure all project costs charged up to the termination or stop work date order are included in the final invoice.

As federal agencies issue official guidance and updates, additional sections will be added below.

 APLU: Association of Public & Land-Grant Universities

• Statement on Pause on Federal Grants (Jan. 28, 2025)
• Overview of Executive Orders (Jan. 23, 2025

 DoD: Department of Defense

• Statement Clarifying Defense Contracting (Jan. 28, 2025)

 DOE: Department of Energy

• Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE) (Apr. 11, 2025)
• Cease all activities associated with DEI and CBP (Jan. 27, 2025)
• Agency-wide Review of Program and Administrative Activities (Jan. 20, 2025)

 DOJ: Department of Justice

• Notice of Court Order (Mar. 6, 2025)
• Order Granting in Part and Denying in Part Motion for Preliminary Injunction (Mar. 6, 2025)

 DHHS: Department of Health & Human Service

• Memorandum and Order on Motion for Preliminary Injunction (Mar. 5, 2025)
• Notice of Court Order & Temporary Restraining Order (Feb. 2, 2025)
• Health Resources & Services Administration (HRSA) letter (Jan. 31, 2025)
• Centers for Disease Control and Prevention (CDC) letter (Jan. 31, 2025)
• Immediate Pause on Issuing Documents and Public Communications (Jan. 21, 2025)

 ED: U.S. Department of Education

• Title VI of the Civil Rights Act in Light of Students for Fair Admissions v. Harvard (Feb. 14, 2025)
• U.S. Department of Education Takes Action to Eliminate DEI (Jan. 23, 2025)

 FEMA: Federal Emergency Management Agency

• Message to Grant Recipients on Manual Review Process (Feb. 28, 2025)

 NASA: National Aeronautics and Space Administration

• Initial Guidance Regarding Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government Executive Order (Feb. 6, 2025)
• Initial Guidance Regarding President Trump’s Executive Order Defending Women (Jan. 30, 2025)
• Initial Guidance Regarding Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders (Jan. 23, 2025)

 NIH: National Institutes of Health

• Updated NIH processes for No-Cost Extensions (May 7, 2025)
• Updated NIH policy on foreign subawards (May 1, 2025)
• NIH bans all future grants to universities with DEI programs or Israel boycotts (Apr. 21, 2025)
• NIH 15% Cap on Indirect Cost Reimbursement – Information & Resources
• Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (Feb. 7, 2025)
• Trump hits NIH with ‘devastating freezes on meetings, travel, communications, and hiring (Jan. 22, 2025)

 NSF: National Science Foundation

• UH response to NSF Policy 25-034: Implementation of a Standard 15% Indirect Cost Rate
• NSF Implementation of Recent Executive Orders

 USAID: U.S. Agency for International Development

• Executive Order Reevaluating and Realigning United States Foreign Aid (Jan. 24, 2025)