Federal Updates for Researchers

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In November 2025, NIH released Leveraging Institute, Center, and Office (ICO) Funding Policies along with a rubric by which ICO funding strategies are to be developed, implemented and evaluated effective with the January 2026 Council round. All ICO funding policies should: 

• Align with the NIH's mission 
  
• Prioritize scientific merit; ICOs should consider peer review information in its entirety 
  
• Integrate a breadth of topics and approaches relevant to the ICO’s priorities 
  
• Consider investigator career stage and promote sustainability of the biomedical research workforce 
  
• Promote broad distribution and geographic balance of funding, considering the total amount and type of NIH funding already available to each investigator
• Align with the availability of ICO funds 

First Level of Peer Review

When making funding decisions, ICOs will continue to consider the overall impact score, scores and critiques received during peer review. ICOs will no longer employ cutoff points from rank ordered applications in overall impact scores to determine which applications to fund. Moving forward, ICOs will consider peer review information in its entirety when assessing scientific merit. Learn more about NIH’s first level of peer review. 

Second Level of Peer Review

• Advisory councils perform the second level of peer review for applications. Their duties include: 
  Offer recommendations on policy and program development, program implementation, evaluation and other matters of significance to the ICO mission
• Assist ICOs in identifying cases in which further investment in a particular area or principal investigator is not justifiable relative to competing priorities 

Who Makes Funding Decisions

ICO Directors will continue to decide what is funded by their ICOs. In addition to the core tenets for funding policies, ICO Directors will carefully consider the budget to award for each grant, not relying solely on the requested budget as evaluated by peer reviewers, but also assessing the actual needs, opportunity costs and stewardship of taxpayer investments.

Added January 8, 2026

On November 24, 2025, NIH provided updated guidance on the reopening of extramural activities following a lapse in appropriations.

• Rescheduling October Application Due Dates: Applications with due dates between October 1, 2025, and December 5, 2025, are accepted through 5:00 PM local time December 8, 2025. 
  
• Post-submission Materials:  
  
  • January 2026 Council: Materials accepted up to one week before the scheduled peer review meeting. 
    
  • May 2026 Council: One-page update with preliminary data accepted as post-submission materials for applications submitted under all activity codes, ONLY if the Notice of Funding Opportunity used for submission allowed preliminary data in the application. The deadline is 30 days before the study section meeting. Review the details in NOT-OD-19-083. 
    
• Research Performance Progress Report (RPRR) Submitted During Shutdown: Submitted RPPRs that were due between October 1, and November 13 do not need to be resubmitted unless requested by the funding institute, center or office. 
  
• Rescheduling Peer Review Meetings: The following changes have been made to catch up for the January and May 2026 councils and are in effect through the May 2026 Advisory Council. 
  
  • Reduction from 50% to 30-35% of applications discussed in most meetings 
    
  • Applications voted in the middle third will be designated “competitive but not discussed” and considered for funding, along with the discussed applications. 
    
  • Applications voted in the lowest third will be designated “not competitive and not discussed.” 
    
  • Summary statements simplified to a sentence describing degree of consensus in the committee vote, plus bullets listing the main score driving points. 
    
• Early Stage Investigator Eligibility: Status will automatically be adjusted for applicants affected by the shutdown delay. 
  
• K99/R00 Eligibility: Information updating program timelines will be issued separately. 
  
• Loan Repayment Program: The Extramural LRP Application Submission Deadline is now December 4, 2025.
  
• Financial Operations under a Continuing Resolution: NIH has published a notice on financial operations under a continuing resolution. 

Added December 17, 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.

Last updated February 10, 2026.

NIH mandated that effective October 1, 2025, all Senior/Key Personnel on NIH-funded grants must complete training on updated "Other Support" disclosure requirements as well as Research Security, and these requirements have generated many questions from you on how to comply.

Our campus has taken a proactive and simplified approach and purchased a Citi training module that meets both requirements: "Research Security Training (Combined Course)." 

This training is required for Proposals, JIT, RPPRs and NIH Prior Approval Requests submitted on or after January 25, 2026.

Complete the training module purchased by the campus..

The requirement also applies to external collaborators, community partners, or other stakeholders who will be designated as Key Personnel on an NIH application. If these individuals do not have access to Research Security Training through their home institution, they may complete a free, NIH-accepted training available through the NSF Secure Center website.

Updated January 30, 2026

Effective July 1, 2025, the 2024 NIH Public Access Policy requires that NIH-funded Author Accepted Manuscriptstooltip (AAM) accepted for publication be submitted to PubMed Central (PMC) upon acceptance. These manuscripts must be made publicly available without embargotooltip on the date the final, edited article is first published – whether in print or online. Public access to the online journal or publisher websites alone does not meet this requirement.

The policy applies to all peer-reviewed manuscripts resulting from NIH-funded research that are accepted for publication on or after July 1, 2025, regardless of when the award was originally made, provided the award was not closed prior to July 1, 2025. 

For awards closed prior to July 1, 2025, authors with subsequent AAMs resulting from and citing the closed NIH award must continue to comply with the 2008 Public Access Policy, which allows for an embargo period of up to 12-months.

Choosing Journals for Article Submission 

• Authors can publish in one of these journals that do not hold an embargo. 
  
• Authors can publish in the open access option of a selected journal, which may require the payment of article processing charges (APCs). Please note, the Strauss Health Sciences Library has agreements in place with select publishers to waive or reduce costs.

Submission of the Author Accepted Manuscript (AAM) into PubMed Central (PMC)

After an article is accepted for publication in a journal without embargo, compliance with the 2024 NIH Public Access Policy is achieved in one of two ways: 

• The author deposits the electronic version of the AAM to PubMed Central (PMC), or
• With prior arrangement through the contract with the journal, the journal deposits the article on the author’s behalf.  

Compliance is evidenced by the assignment of a PMC Identifier (PMCID) to the article. When AAMs are deposited into PMC, an NIH Manuscript Submission Identifier (NIHMSID) may be used temporarily until the submission process is complete, and a PMCID is assigned.

For further information and advice, visit the Publishing and Authorship webpage on the Strauss Health Sciences Library website.

NIH Allowable Publication Costs

On July 8, 2025, NIH director Jay Bhattacharya announced that NIH intends to implement a cap on allowable publication costs starting in FY 2026. The announcement was followed by a request for input by Sept. 15, 2025, from all interested individuals and communities on proposed options for limiting costs. A decision by NIH on potential caps has not yet been announced.

Resources: 

• 2024 NIH Public Access Policy
• NIH Public Access Policy Frequently Asked Questions
• NIH PubMed Central Journal List (Journals that do not hold an embargo)
• NIH Selective Deposit Collections (Journals willing to deposit per author agreements)
• Strauss Health Sciences Library Journal Agreements 

Last updated December 18, 2025

A journal embargo is a delay imposed by the journal after publication of a manuscript, before the manuscript is made available to the public in PubMed Central. For more information about making manuscripts available in PubMed Central to comply with 2024 NIH Public Access Policy, please review this FAQ: What are my options for making my article open access without embargo so that I can comply with the 2024 NIH Public Access Policy?

A media embargo gives journalists early access to peer-reviewed research with the agreement that they will publish their coverage after the journal’s embargo lifts and once the paper is available online. This window, which is usually 48 to 72 hours before a paper publishes, gives journalists time to interview authors, verify findings and prepare accurate, well-contextualized stories to be ready to publish as soon as the embargo lifts.

Contact [email protected] to work with the CU Anschutz media team to get media publicity for upcoming peer-reviewed papers.

Added December 18, 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

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.