Federal Updates for Researchers

Dear Colleagues,

On June 22, the Research Development Office asked CU Denver federally funded researchers to provide input on the White House Office of Management and Budget’s proposed revisions to the Uniform Guidance (2 CFR Part 200). Thank you to the faculty and staff who shared feedback. Your input helped shape a coordinated CU Denver response.

CU Denver submitted its comments on the July 13 public comment deadline.

In developing the response, we considered feedback from the CU Denver research community, analyses from peer institutions and national higher education organizations, and research administration comments being prepared by CU Anschutz, our institutional partner.

The final comments present a CU Denver perspective informed by local experience and national research policy developments. They recognize OMB’s goals of strengthening stewardship, accountability, transparency, and efficient administration while recommending targeted revisions to preserve the stability, clarity, and competitiveness of the U.S. research enterprise.

Our recommendations focused on six broad priorities:

• § 200.205(b) Pre-Issuance Review: preserving independent expert peer review as the primary basis for research funding decisions
• § 200.220 Prohibition of Using Federal funds for Covered Foreign Collaborations: strengthening research security while preserving legitimate international scientific collaboration
• § 200.340 Termination and Suspension: preserving research continuity through predictable award administration and clearly defined termination standards
• § 200.432 Conferences: recognizing presentation and participation in research conferences as integral components of federally funded research
• § 200.461 Publication and Printing Costs: recognizing publication and dissemination as integral components of federally funded research
• Describing several provisions we felt may increase administrative burden on researchers and research administrators including: additional subaward reporting requirements, related-entity reviews, expanded monitoring expectations, suspension and termination procedures, and new compliance reviews tied to national policy provisions

The public comment period has now closed. According to APLU, OMB received nearly 500,000 comments from individuals, universities, professional societies, scientific organizations, industry, lawmakers, and others. OMB will review the comments before deciding whether and how to revise the proposed regulation.

We will continue to share significant updates through the Research website, newsletter, and campus communication channels as additional information becomes available.

Thank you again to everyone who contributed to this effort and to our research community for your continued commitment to CU Denver’s research mission.

Best regards,

Phillip De Leon
Associate Vice Chancellor for Research
University of Colorado Denver

Chancellor and Provost Message on Government Shutdown
Added October 1, 2025.

During a shutdown, program managers at federal agencies are unlikely to be able to communicate with principal investigators (PIs). Federal employees are also unlikely to be available to answer phone calls, respond to emails, maintain websites, hold meetings, review applications, send proposals out for peer review, process new awards or issue manual payments.

Added October 1, 2025.

Principal Investigators (PIs) should continue to work on active federal awards but note the following exceptions:
 

• For new non-competing continuation segments or awards, where you have not received an NOA, use caution for pre-award spending. The PI or unit is fiscally responsible for pre-award spending if the award is not received.
• Faculty working at a federal agency on an IPA agreement should immediately contact the agency to determine next steps
• For federal contracts, “Stop Work” orders may be implemented, in which case, those employees can no longer be paid with federal funds allocated to that contract. Be aware of limitations of funds or costs terms in contracts.
• Faculty working in federal labs/facilities and possibly on cooperative agreements and joint awards may be most immediately affected. They could receive notification that they are not permitted to work on associated awards during the shutdown.

Added October 1, 2025.

• No new grants will be awarded during the shutdown. 
• Funding for active grants that are due for renewal or no-cost extensions may not be processed. 
• Payments and federal drawdowns may be suspended.

Added October 1, 2025.

Submission portals (e.g., Grants.gov, Research.gov) should remain open for submission. Therefore, all published grant and nomination deadlines must still be met, even during a shutdown. Principal Investigators (PIs) are encouraged to continue to submit grants proposals, while recognizing that grant proposals will not be processed until normal operations resume. Peer reviews/study sections are not expected to occur during the shutdown, which could delay start dates.

Added October 1, 2025.

Agencies will experience backlogs once operations resume, which could further delay award announcements, review panels, meetings and public launches of new programs.

Added October 1, 2025.

• Department of Education
• Department of Energy
• Department of Health & Human Services (DHHS)
  • National Institute of Health
• Department of the Interior
• Department of Commerce
• Department of Transportation
• Department of War
• Department of Treasury
• National Science Foundation
• NASA

Added October 1, 2025.

The Office of Research Services (ORS) held a virtual town hall on Wednesday, May 28.

[ Video | Slides ]

This session provided updates for Denver Campus researchers and research support staff on navigating the evolving landscape of federal research priorities and funding under the new administration as we understand them today.

Topics included:
• The current state of campus research
• Updates from federal agencies and legal developments
• Guidance and resources for sponsored projects

The ORS team wanted to highlight some recent changes to NIH policies on Foreign Subawards and No-Cost Extensions, as well as further guidance on proposal submissions with recent agency Indirect Cost Rate Cap efforts and litigation:

• NIH and Foreign Subawards:  Effective May 1, foreign subawards can no longer be issued under prime recipient awards. Instead, there is a temporary pause while NIH is creating a new structure for subprojects with an anticipated release date of September of this year. Effective immediately and including proposals currently in development:
  • Foreign subawards are no longer allowed;
  • Prior approval requests to add new foreign subawards to existing projects will no longer be considered; and
  • Current awards with foreign subawards will be restructured, renegotiated or terminated.
• NIH and No-Cost Extensions:  Effective May 7, NIH temporarily disabled the No-Cost Extension functionality in eRA Commons to allow NIH staff to review all existing grants and cooperative agreements for consistency with funding priorities. All new requests for NCEs must be submitted as prior approval requests in eRA Commons for NIH review and approval.
  • The Office of Grants and Contracts (OGC) will need to provide documentation and work directly with the grants management specialists. With these changes, OGC will need at least 60 days’ lead time before the end date of your grants to facilitate.
• Indirect Cost Rate Caps:  The National Institutes of Health (02/07/25), the Department of Energy (04/11/25), and the National Science Foundation (05/02/25) have all separately issued policy notices regarding new indirect cost limitations.  These are all in various stages of being challenged in court.  The current guidance from the Office of Grants and Contracts (OGC) is to continue to route and submit your proposals using our current federally approved negotiated rates unless programmatically required by the specific solicitation or as otherwise directed by OGC.

If you believe you have been impacted by these changes or if you have received any other direct sponsor communications related to the federal government transition including termination letters or stop work orders, or if you have any other questions, please contact us through this form.  This will immediately notify the Denver Campus Federal Transition Team (including OGC, University Counsel, and ACE), and the appropriate contact will reach out to you directly.

Dear Colleagues,

We wanted to highlight and give further context to some of the most recent updates from the CU System’s Office of Government Relations for the Denver Campus research community.

• On March 14, Congress passed legislationto fund the federal government through September 30, 2025 and avert a shutdown. Notably, the seven-month continuing resolution increases defense funding by $6 billion and decreases non-defense spending by $13 billion, including a reduction in the Congressionally Directed Medical Research Programs (CDMRP) funding from $1.5 billion to $650 million. Funding for other sponsored agencies remains largely flat, and the bill retained language prohibiting changes to Facility & Administrative rates. 
• On March 14, an appeals court lifted a block on executive orders seeking to end government support for diversity, equity, and inclusion (DEI) programs. In overturning the preliminary injunction, the government is now permitted (during the pendency of the lawsuit) to enforce the termination, attestation, and enforcement sections of the DEI executive orders. This could impact grants at our institution. It is the responsibility of the Office of Grants and Contracts (OGC), not the individual investigator, to provide any campus attestation. If you receive an attestation, or any other specific grant requests related to the executive orders, please work with your research administrator contact to complete the CU Denver Federal Transition Inquiry/Update Form. This immediately notifies the Campus Federal Transition Team and OGC, who will respond as required.
• Several agencies intend to issue guidance or have announced new rules for institutions that draw down grant funds from federal payment management systems to align with Executive Order 14222which requires grant recipients to provide justification explaining the purpose of the payment for each grant drawdown. OGC has worked with University Counsel to provide a standard response related to overall expenses. There is no action required of investigators or units.

Please remember that whenever you receive any direct communication from a federal sponsor related to your grants, including stop-work orders, it is important that you contact the Denver Campus Federal Transition Team for guidance. The team reviews your questions and any individual sponsor notifications on a case-by-case basis to determine what may be covered by the current directives and subsequent court orders.

We recognize this is a challenging time for our research and creative works community. The Office of Research Services is here to support and assist you. Please review the ORS Federal Transition Updates for Researchers website for guidance for our campus research community. For other general information related to the federal transition, please continue to visit the Denver Campus Federal Transition site and the CU System Federal Transition Updates.



Sincerely,

Phillip De Leon

Associate Vice Chancellor for Research

The Office of Research Services sent notification through the ORS listserv a note regarding the NIH Announcement on a standard facilities & administrative (F&A) rate of 15%:

Dear Colleagues,

I wanted to share important updates about the National Institutes of Health (NIH) announcement. On Friday, Feb. 7, the NIH revealed that it will impose a standard facilities & administrative (F&A) rate of 15% for all NIH grantee institutions. This new rate is significantly lower than CU Denver’s federally-negotiated rate for research of 56% and will apply to both existing and future NIH grants starting today. As you know, indirect cost recovery (ICR) is fundamentally important to support the physical and operational infrastructure of the research enterprise. This infrastructure includes critical components such as

• environmental health and safety (EHS)
• grant administrative services
• management and security of data
• lab operations and maintenance
• research IT

Universities such as ours, pay these expenses as we conduct sponsored research, and the sponsor then reimburses a portion of these necessary research expenses.

The annual spending bill that funds NIH includes language from Congress prohibiting the Administration from making changes to F&A rates. CU System and CU Denver leadership is committed to preserving research support and mitigating the impact of this announcement. We already know attorneys general are seeking a court order to halt this action.

For decades, Coloradans and people across the country have benefited from NIH-sponsored medical research as well as other federally-sponsored research which has led to scientific breakthroughs and life-saving discoveries. Like most research universities across the country, much of CU Denver’s research is funded through federal agencies. Weakening the long-standing partnership between research institutions and the federal government, which also serves as a model around the world, will have far-reaching consequences.

For now, please continue your important work unless you hear otherwise from a program officer or sponsor. In that case, please contact your College/School research administrator, the Office of Research Services, and General Counsel Chris Puckett. In addition, please visit campus resource webpages:

• https://www.cu.edu/blog/government-relations
• https://ucdenver.edu/federal-updates/
• https://research.ucdenver.edu/resources/federal-transition-updates

Our campus and university leadership remain committed to CU Denver’s research, scholarly, and creative work. Our shared commitment to advancing research, including medical and health-related work, has never been more important.

The Office of Research Services sent notification through the ORS listserv highlighting the latest CU System’s Office of Government Relations guidance. The message included the following:

“On Friday, a federal judge issued a restraining order restricting the activities of the Office of Management and Budget and federal agencies. As noted by the system message, “The guidance clarifies that federal agencies cannot “pause, freeze, impede, block, cancel or terminate” any federal grants on the basis of the now-rescinded OMB memo from January 27 or any recent Executive Orders. This includes stop work orders issued to institutions as well as individual PIs on specific grants. Based on this ruling and the accompanying guidance, we recommend that all researchers, faculty, and staff continue working on their grants as normal.” 

If you still have questions about your grant, we encourage you to reach out to your program officers. If you receive information from your program officers that impacts your grant, please immediately contact your College/School research administrator and ORS. If you believe you have received a request that may disrupt your work, please copy Managing University Counsel Chris Puckett.”

On January 29, OMB released a memo, Rescission of M-25-13, that rescinded the order freezing federal grants. Read the January 29 Federal Government Transition Update for more details.

The University of Colorado Denver (CU Denver) has issued a memo addressing concerns about recent Executive Orders and governmental changes affecting research activities. Campus leadership, CU legal counsel, and the Office of Research Services (ORS) are monitoring developments and offering support. Researchers are encouraged to contact program officers with concerns and report any funding or operational impacts to ORS. CU Denver acknowledges the uncertainty these changes create and will provide updates as more information becomes available.

Read the full memo.

All research activities should proceed as planned unless directed otherwise by a federal sponsor.

• Research activities not impacted by recent changes should continue without interruption.
• Continue to submit grants using the most updated information from the program announcements or program officers to guide the development of your applications.
• Check this website regularly for the latest updates, and reach out to us with any questions using this online form.