Federal Updates for Researchers

NIH has mandated that effective October 1, 2025, Key Personnel on NIH-funded grants must complete training on updated "Other Support" disclosure requirements. Compliance will be effective for applications submitted on or after January 25, 2026, and all active awards that are continuing with future years. 

The Office of Regulatory Compliance (ORC) has purchased training from Citi to meet NIH’s Other Support training requirements. The training is more comprehensive and includes research security training along with Other Support.  The training is titled Research Security Training, and understandably, the title of the training has caused some confusion.

To fulfill the new NIH training requirement for Key Personnel, please complete the "Research Security Training" available on the ORC website. In addition to meeting the NIH requirements, this training also fulfills the requirements of many other non-NIH sponsors for Research Security Training.  

At the end of September 2025, NIH temporarily pulled back their implementation date as they continue to work with the National Science Foundation and other federal agencies to finalize guidance. NIH will publicize a the new implementation date soon. NIH is also developing a centralized process for recipients to certify compliance with NIH Research Security Policies, and updated guidance is expected to be issued in the coming months.

Added November 12, 2025

The Joint Associations Group (JAG) on Indirect Costs is a group comprising national organizations that represent America’s academic, medical and independent research institutions, along with other relevant experts. Established on April 8, 2025, JAG has convened to develop the Financial Accountability in Research (FAIR) model. This is a new approach to indirect cost recovery, or facilities and administrative (F&A) costs that has been proposed as an alternative to the federal government’s proposed across-the-board percentage cap for F&A costs at research institutions across the country. 

In July 2025, the FAIR model was presented as a recommendation to Congress and the Executive Branch to replace the current F&A cost structure. In September 2025, the JAG released a statement urging policy makers to take steps to implement the model. 

Campus leadership is engaged on this topic and closely following developments related to F&A rates and specific impacts on our campus. 

Additional Resources: 

• AAMC: Facilities & Administrative Costs 
  
• COGR: Frequently Asked Questions (FAQs) on JAG Effort and FAIR Model

Added November 12, 2025

CU Anschutz accepts National Institutes for Health (NIH) funds under certain conditions of award. The attestation language broadly includes all campus research programs, not just those grants directly funded by the NIH or other federal sponsors. The legal aspects of these conditions continue to be clarified, and further updates are anticipated, including from the NIH on August 15, 2025.

To assist you in navigating any non-federal grant opportunities in these areas, including research on specific demographic groups, please refer to this campus guidance and rubric, and work closely with the research administration in your school or college while developing your funding applications. Campus guidance may be updated, so please refer to this Federal Updates for Researchers webpage often.

• School of Medicine: [email protected]
• School of Dental Medicine: Jeffrey Stansbury, PhD, Senior Associate Dean of Research, [email protected] 
• College of Nursing: Teresa Hernandez PhD, RN, FAAN, Associate Dean of Research and Scholarship,  [email protected] 
• Colorado School of Public Health: Dana Dabelea, MD, PhD, Associate Dean of Research, [email protected]  
• Skaggs School of Pharmacy: Manisha Patel, PhD, Associate Dean of Research and Graduate Studies, [email protected] 
• Graduate School: Jennifer Richer PhD, Dean, [email protected] 

We will have a campus group review these with representatives from each school/college on a case-by-case basis and advise.

VIEW CAMPUS GUIDANCE

 

 

VIEW CAMPUS RUBRIC

 

 

Last updated October 14, 2025.

A policy change, originally slated for December 1, 2025, was brought forward to July 1, 2025. The updated policy requires Author Accepted Manuscripts accepted for publication in a journal, on or after July 1, 2025, to be submitted to PubMed Central upon acceptance for publication, for public availability without embargo upon the Official Date of Publication. 

The policy applies to all peer-reviewed manuscripts accepted for publication in a journal on or after July 1, 2025, regardless of when the award was originally made, as long as the award was not closed prior to July 1, 2025. 

For awards that were closed prior to July 1, 2025, authors with any subsequent Author Accepted Manuscripts resulting from and citing the closed NIH award are expected to continue to comply with the 2008 Public Access Policy, which allows for an up-to 12-month embargo. 

NIH Resources: 

• Supplemental Guidance to the 2024 NIH Public Access Policy: Publication Costs
• Supplemental Guidance to the 2024 NIH Public Access Policy: Government Use License and Rights
• FAQs: Public Policy Access

Added August 14, 2025.

On August 14, 2025, the National Institutes of Health (NIH) announced that going forward, it would post all grant and cooperative agreement notices of funding opportunities (NOFOs) exclusively at Grants.gov, a federal-wide portal for discretionary funding opportunities.

NIH will no longer post these opportunities in NIH Guide for Grants and Contracts (NIH Guide) nor the weekly NIH Guide Table of Contents subscription emails.

NIH will continue to provide tools in the Funding section of NIH Grants & Funding to identify potential funding categories, topics and opportunities you may be interested in. Any funding opportunity identified through this site will link to Grants.gov for the official opportunity posting.

You can use Grants.gov subscription services to receive notifications of new NIH funding opportunities.

Also, if you haven’t already subscribed to the Office of Research Development and Strategy’s Funding Focus newsletter, your campus source for internal and external funding opportunities, please consider subscribing. 

Added August 27, 2025. 

National Institutes of Health (NIH) provided new guidance on July 17, 2025, about the appropriate use of artificial intelligence (AI) in NIH research applications. According to the policy, which goes into effect on September 25, 2025: 

“NIH will not consider applications that are either substantially developed by AI, or contain sections substantially developed by AI, to be original ideas of applicants. If the detection of AI is identified post award, NIH may refer the matter to the Office of Research Integrity to determine whether there is research misconduct while simultaneously taking enforcement actions including but not limited to disallowing costs, withholding future awards, wholly or in part suspending the grant, and possible termination.”

The new policy also limits the number of new, renewal, resubmission or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year to six.

Added August 14, 2025.

According to new guidance released by National Institutes of Health (NIH) on July 17, 2025, NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator (PI)/Program Director (PD) or Multiple Principal Investigator for all council rounds in a calendar year. Administrative supplements, non-competing renewals and Type 7 applications are not counted toward the maximum. This policy goes into effect on September 25, 2025, and applies to all activity codes except T activity codes and R13 Conference Grant Applications.

A PI/PD’s application limit will be counted based on the calendar year of the Advisory Council date when the application is scheduled to be reviewed. For information on the timelines for the new six-application limit, view this FAQ on the NIH website.

Added August 14, 2025.

While noting the current flux across agencies, institutes and centers of the HHS, such as the Agency for Healthcare Research and Quality (AHRQ) and Centers for Disease Control and Prevention (CDC), we still encourage researchers to submit grant applications; however, please consider the sponsors’ areas of interest, noting that these may change.

Also, please note that beginning September 25, 2025, NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year. Administrative supplements, non-competing renewals and Type 7 applications are not counted toward the maximum. This policy applies to all activity codes except T activity codes and R13 Conference Grant Applications. 

Many sponsors are accepting applications despite reported staff changes.  Principal Investigators are encouraged to contact their specific program officer or manager directly, as this will likely be the most direct way to assess the situation with a specific grant mechanism.

The NIH has started to release new funding opportunities. These opportunities—including forecasted and newly announced opportunities—are increasingly being posted in less traditional locations, such as Grants.gov, rather than solely through the NIH Guide or the NIH funding website.

While many of us rely on these standard sources, we strongly encourage all faculty and staff to subscribe to NIH Grants and Funding and Grants.gov to stay current. CU Anschutz Office of Research and Development will continue to highlight new and anticipated Federal funding opportunities on their Extramural Funding page and the Funding Focus newsletters and Pivot, an interactive, comprehensive web-based database housing extensive research funding opportunities from federal and non-federal sponsors worldwide. 

Last updated August 14, 2025

The National Institutes of Health (NIH) has announced a major structural change for all NIH-funded research involving foreign subawards, effective May 1, 2025. Under the new policy, 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.

Going forward:

• Foreign subawards are no longer allowed. NIH will not issue new, renewal, or non-competing continuation awards that include subawards to foreign entities.
  
• Prior approval requests to add new foreign subawards to existing projects will no longer be considered.
  
• Current awards with foreign subawards will be restructured or renegotiated to remove the foreign subrecipient, or if not possible the award will be terminated.
  
• This policy applies immediately, including to proposals currently in development.
  

Please review all planned foreign collaborations now. Proposals that do not comply with the new structure may be administratively withdrawn or denied funding. OGC pre-award will return any proposals that have foreign subawards.

If you believe your proposals are impacted by this change, please contact the Office of Grants and Contracts using the CU Anschutz Federal Transition Inquiry Form.

Last updated June 6, 2025.

National Institutes of Health (NIH) Standard Terms of Award include the provision for grantees to extend the final budget period of a previously approved project period one time for a period of 1 to 12 months, without additional NIH funds, and without prior approval. 

This request for a No-Cost Extension (NCE) must be made before the project period ends. Typically, the NCE request triggers an automated email notification to the grants management specialist (GMS), and no further action is required by the recipient. 

As of May 7, 2025, NIH temporarily disabled the No-Cost Extension functionality in eRA Commons so that NIH staff can review all existing grants and cooperative agreements to allow the NIH to review the activities of the grant and consistency with funding priorities.

All new requests for NCEs must be submitted as prior approval requests in eRA Commons for NIH review and approval. Given that the Office of Grants and Contracts (OGC) will need to provide documentation and work with the GMS directly, please allow at least 60 days lead time before the end date as this new review process takes place.

If you have an outstanding NCE request in place with OGC, we will contact you for more information and to request the documents needed for the request. Please reach out to us via the CU Anschutz Federal Transition Inquiry Form with any grant-specific questions related to this change.

Last updated May 12, 2025. 

We are seeing delays in receiving some non-competing continuations while others are being issued on time. It is variable, and the Office of Grants and Contracts has not observed specific trends within one agency over another.

Last updated April 23, 2025

As our usual practice, the Principal Investigator or unit is fiscally responsible for pre-award spending if the award is not received. Please keep this in mind if you plan any pre-award spending.

Last updated April 23, 2025

Funding applications to the National Institutes of Health (NIH) are reviewed in study sections (i.e., Scientific Review Groups or SRGs). Review Branches (RBs) are clusters of study sections based on scientific discipline. With the federal government transition, the status of the scheduling of study sections has been unclear, as typically scheduled meetings have either been occurring inconsistently or not at all.

On March 6, 2025, the NIH announced plans to centralize peer review of all applications for grants, cooperative agreements and research and development contracts within the agency’s Center for Scientific Review (CSR). This centralization would eliminate study sections within 23 NIH Institutes and Centers (ICs) that currently review 22% of NIH grant applications.

NIH’s proposal is under review with implementation pending external review. This includes review by HHS and the Office of Management and Budget, providing Congress with a 15-day notification period (until March 22), and issuing a Federal Register notice.

Last updated March 18, 2025.

Researchers have reported that in some instances, the requirements of fulfilling their federal research grants, including required sections, may conflict with Executive Orders (e.g., on DEI) issued by the new Administration.

At this time, we believe researchers should complete all required sections of their federally funded grants, including those that pertain to DEI, if this is a requirement of grant submission.

Please closely monitor grant requirements prior to submitting, as they may change due to conflicting requirements between the federal funder and the Executive Orders.

Also, consider including language to indicate that you are following the requirements of the grant and will adapt your work as needed to comply with any confirmed or final federal requirements communicated by the federal funder.

Some investigators have been contacted with requests to revise proposals in the pre-award stage. If you receive this request, please work with your PO on the recommended changes. If you have further questions, please contact OGC using the CU Anschutz Federal Transition Inquiry Form.

Last updated June 9, 2025.

You should continue to work on your grants and funded research unless you have received specific instructions to stop from a federal sponsor. Please use caution when looking at long-term investments such as expensive equipment, as guidance may change in the coming weeks or months. If you are unsure, please submit an inquiry to our campus federal transition team through this online form, and our team will follow up with you.

Last updated February 7, 2025.

Please submit an inquiry through this online form, and our team will be in touch.

Last updated February 7, 2025.

If you receive any attestation request, a grant-specific questionnaire or any other direct request from a federal sponsor, including but not limited to any attestation regarding DEI, gender ideology or gender affirming care, these inquiries are considered legal terms and conditions and require an institutional authority (AOR Authorized Organization Representative) to attest and submit on behalf of the University. This is typically done at the time of submission by the Office of Grants and Contracts. 

If you receive an email from a sponsor with a request for you to sign an attestation or other document related to your proposal and/or award, please submit it to us via our online form as soon as possible and do not respond to the sponsor. We will work with sponsor to provide the campus attestation as required by NIH policy.

Last updated June 9, 2025.