Dear Research Leaders and Colleagues,
Due to the rapidly changing nature of ongoing federal research policy changes, I will share more regular communications on what we know and any updated guidance. Please help us continue to highlight the most salient points. If you know of a new concern that we haven’t addressed below or have heard new information that should be shared broadly in this update, email my office at vcresearch@ucsd.edu.
We continue to track award disruptions and delays. If you receive a termination or stop work order from your funding agency specifically for your award, email vcresearch@ucsd.edu. While we weather this situation, campus urges units to assess the situation and take any actions needed. We recognize that these award disruptions and delays are incredibly stressful to campus as a whole and are devastating to the important work of the PI’s and teams that are directly impacted.
The following updates address new terms and conditions from federal agencies:
Update on NIH Awards
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Recent and ongoing notices of awards issued by the NIH include DEIA, anti-discrimination, and gender ideology terms and conditions. As a result, UCOP requested that all campuses temporarily pause accepting new awards, renewals, and non-competitive continuations while the terms were being reviewed by legal counsel and discussed with the Chancellors. Last week, campus leadership determined that the campus may start accepting new and continuing awards. The SPO has resumed processing direct and flow-through NIH awards. Note that guidance on our shared responsibility to ensure these terms are met will be issued by the Chancellor’s office.
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Automated No-Cost Extensions (NCE) Function Disabled: The NIH has temporarily disabled the automated first No-Cost Extension (NCE) function in the electronic Research Administration (eRA) Commons for all active NIH grants and cooperative agreements. Institutions must now submit the first NCE request as a prior approval through eRA Commons, including detailed project plans and clear justifications that align with NIH priorities. Approval is no longer guaranteed, and requests may be denied if they don’t meet NIH requirements.
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Guidance: PIs and departments are urged to submit NCE requests to the Sponsored Projects Office (SPO) through the Direct Federal Grants Prior Approval & NCE Request Form 60 days before the project end date. As the new process requires more lead time, prior approval must be sought 30 days before the proposed change. SPO will review all NCE requests before submission to ensure that the activities proposed in the extension period are clearly stated to justify the request. For any questions, please contact researchadmin@ucsd.edu.
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Effective May 1, 2025, and until the details of the new foreign collaboration award structure are released (by September 30, 2025), NIH will not issue awards (new, renewal or non-competing continuations) that include a foreign subaward.
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NIH will no longer accept prior approval requests to add a new foreign component or subaward to current projects. Existing awards will be renegotiated to remove foreign subawards, and funds will be reallocated for domestic work. If a project cannot continue without a foreign subaward, NIH will coordinate with grantees to terminate it while considering patient safety and animal welfare.
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Guidance For Existing NIH Awards with Outgoing Foreign Subawards
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NIH has indicated that the updated policy on foreign subawards will apply prospectively. As such, activities involving foreign subawards may continue until the prime award is up for renewal or a non-competing continuation. However, we strongly recommend that PIs begin preparing for potential changes now and notify their foreign subrecipients that their subaward will not be extended. PIs should consider how the project could be modified or renegotiated in alignment with the NIH guidance should the award be impacted.
- PIs should contact their PO immediately to discuss if and how they can restructure the foreign subaward to meet New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight, and National Security of NIH Funded Research.
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Guidance For Upcoming NIH Proposal Submissions with a Foreign Subawardee
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Please be aware, per guidance above, that NIH proposal submissions with foreign subawardees may be rejected. That said, if you choose to submit an NIH proposal with a foreign subawardee because of the irreplaceable necessity of that subawardee’s contributions to the project, we suggest that if possible, you wait until additional NIH guidance is available. If you cannot wait, and your proposal needs to be submitted before additional NIH guidance is available, we suggest adding the following language to both the Cover Letter and Budget Justification: “Should the project be funded, the campus will work with NIH to implement roll out of the award under the new NIH structure.”
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If you are considering a new proposal that requires a foreign subawardee, you should contact the PO listed in the Notice of Funding Opportunity to discuss if and how you can restructure your foreign subaward to meet New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight, and National Security of NIH Funded Research.
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Effective May 5, 2025, NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to Institutions of Higher Education (IHEs) for which indirect costs are allowable.
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- Guidance for Proposals:
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At this time, we are advising all proposals to be submitted using our institution’s current Federally-Negotiated IDC rates with a disclaimer in the budget justification: “We are aware of the May 2, 2025, National Science Foundation Policy Notice: Implementation of Standard 15% Indirect Cost Rate. We will honor the rate identified in this guidance if imposed, but we reserve the right to re-implement the negotiated rate in the event that this guidance is rescinded, modified, held unlawful, or otherwise not applicable to this grant application.” This disclaimer should also be included in the cover letter for proposals where UC San Diego is a subrecipient.
- If a proposal is funded, NSF may request a 15% IDC rate, potentially requiring a rebudget. We await more guidance on how to address this and will provide an update when we have more information.
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Thank you for your continued vigilance and attention as we work to support and advocate for our outstanding research, discovery and innovation community.
This is a rapidly evolving policy landscape, and the information included in these updates reflect our best understanding at the time of distribution. Guidance may change as federal agencies issue new clarifications or revised policies. We appreciate your flexibility and patience as we continue to monitor developments and provide timely updates.
Best,
Cori
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Corinne Peek-Asa, PhD
Vice Chancellor for Research and Innovation
UC San Diego
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