Federal Transition Updates for Researchers

In January 2025, the federal government transitioned to new leadership in the White House and in Congress. The new administration has begun to implement new federal policies, regulations and executive orders, including some with the potential to impact research operations at higher educational institutions across the country.

The CU Anschutz Medical Campus leadership, the University of Colorado's federal relations team and legal counsel are working closely to monitor the transitions and to better understand the potential impacts on our research community.

In some cases, there is enough information for us to recommend specific actions. In other cases, we are still seeking additional clarity or awaiting legal adjudication. We will continue to keep this site up to date with the most recent information for the CU Anschutz research community.

Continue to robustly pursue your research activities and our research mission.

Research activities not impacted by active federal orders should continue without interruption. If you have questions about the impact of an order on your specific grant, reach out to the campus federal transition team using this online form.
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.
Please send any direct communications that you receive from federal sponsors regarding grant changes, including stop work orders, new requests or attestation inquiries, directly to our team for our awareness and discussion. With the ongoing legal activity, we will need to review individual notifications on a case-by-case basis to determine what may be impacted by the current directives and restraining orders. You can contact us using this online form.

Communications from Vice Chancellor for Research Thomas Flaig, MD

This latest communication provides updates and potential impacts about legislation passed by Congress that averted a government shutdown, the status of executive orders related to DEI, a new HHS requirement to justify grant draw downs in the payment management system, and updates about NIH study sections.

Any researchers who have received any direct communication from a federal sponsor related to their grants, including a stop work order, should contact our campus federal transition team to discuss.

Read the update to the research community.

In this latest communication, campus researchers are requested to continue to pursue research unless they have received specific directions to stop from a sponsor.

Any researchers who have received any direct communication from a federal sponsor related to their grants, including a stop work order, should contact our campus federal transition team to discuss.

Read the update to the research community.

The U.S. Office of Management and Budget (OMB) issued a memorandum titled "Temporary Pause of Agency Grant, Loan and Other Financial Assistance Programs," as well as additional clarification, which was to go into effect on January 28, 2025, at 5 p.m. On January 28, a judge temporarily halted the federal funding freeze. On January 29, the memorandum was rescinded by OMB.

Read the update to the research community.

The U.S. Department of Health and Human Services (HHS) issued a broad range of temporary restrictions, effective immediately through February 1, affecting communications, study sections, travel and meetings, among other areas within the National Institutes of Health (NIH).

Read the campus update.

Frequently Asked Questions by CU Anschutz Researchers

Last updated April 9, 2025

Recently our campus has observed a change in review of the Foreign Component in NIH applications, with several applications being rejected for not having the Foreign Justification document uploaded at proposal stage. We have confirmed that this is the case at other institutions as well.

Including the Foreign Justification document has always been a requirement of the application, but in the past, the absence of this document was not a reason for proposal rejection, and if needed, it was requested as a just-in-time document.

Because of this change it is vital that any foreign component be identified, and the required documents be uploaded at the proposal stage. Unfortunately, neither NIH ASSIST nor InfoEd will create an error or warning regarding this requirement. Please update any internal checklists that are utilized when completing a proposal.

See below for more detailed information about what is required:

Foreign Component Requirements:

Per the SF424 Application Guide, applications submitted by foreign (non-U.S.) institutions or by domestic (U.S.) institutions with a foreign component, as defined in the NIH Grants Policy Statement, must include a “Foreign Justification” statement as part of the application package. This requirement is applicable regardless of eligibility requirements stated in the Notice of Funding Opportunity. Applications missing the foreign justification attachment are subject to withdrawal prior to review. More details are available in How to Apply – Application Guide | Grants & Funding and Research Instructions for NIH and Other PHS Agencies.

For Research: If you have checked "Yes" to Question 6, you must include a "Foreign Justification" attachment in Field 12, Other Attachments. Describe special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic (U.S.) setting. In the body of the text, begin the section with a heading indicating "Foreign Justification" and name the file "Foreign Justification."

For Training: If you have checked "Yes" to Question 6, you must include a "Foreign Justification" attachment in Field 12, Other Attachments. Describe special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic (U.S.) setting. In the body of the text, begin the section with a heading indicating "Foreign Justification" and name the file "Foreign Justification."  Your justification must include a description of how the foreign (non-U.S.) training is more appropriate than in a domestic (U.S.) setting. Include reasons why the facilities, the sponsor, and/or other aspects of the proposed experience are more appropriate in a foreign setting. The justification is evaluated in terms of the scientific advantages of the foreign training as compared to the training available domestically (U.S.). Foreign training will be considered for funding only when the scientific advantages are clear.

For Career Development: If you have checked "Yes" to Question 6, you must include a "Foreign Justification" attachment in Field 12, Other Attachment. Describe special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic (U.S.) setting. In the body of the text, begin the section with a heading indicating "Foreign Justification" and name the file "Foreign Justification."  Your justification must include a description of how the foreign (non-U.S.) training is more appropriate than in a domestic (U.S.) setting. Include reasons why the facilities, the sponsor, and/or other aspects of the proposed experience are more appropriate in a foreign setting.

Last updated April 9, 2025.

If you receive a termination letter or stop work order, please submit this information to the campus federal transition team via this form,including a note about whether you would like to explore appealing the decision, so that OGC can contact you to discuss options before you contact the federal sponsor.

Last updated April 9, 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 (IC) 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.

Last updated March 18, 2025.

The Office of Grants and Contracts has received responses from a few NIH agencies that they are holding the issuance of new Diversity Supplements currently, and it is unclear if this mechanism will be available in the future. We will continue to follow up on the status. We have not received additional formal guidance on the status of Diversity Supplements that are active and awarded; however, we have noted some instances of non-extension in the new budget year. Please carefully read NIH communications regarding diversity supplements and share these communications with the campus federal transition team.

Last updated April 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.

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 the NIH 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 NIH. We will work with NIH to provide the campus attestation as required by NIH policy.

Last updated March 18, 2025.

The Office of Grants and Contracts (OGC) learned from our research community about a temporary change that occurred in the NIH’s eRA Commons software that tracks applications and manages and reports on federally funded awards. Researchers reported that the option to request a no-cost extension had disappeared from the software. OGC inquired about this change and the NIH informed them that there had been a process change.

On February 15, the option to request a no-cost extension reappeared. OGC has submitted the NCEs, as requested, and has started to receive Notices of Awards for the NCEs.

Last updated February 24, 2025.

Additional FAQs are available from the CU federal relations team. Please visit their website for more detailed information about federal actions and their impact on the broader CU system.

University of Colorado Resources

CU Federal Transition Updates (system)
CU Anschutz Federal Transition Updates (campus)
CU Anschutz Mental Health Resources (campus)

Recent CU Federal Transition Updates

Federal Government Transition Update #2 | April 11th, 2025
An Update on the DOE 15% F&A Cap and Leaked White House Documents from CU Federal Relations and Counsel

Federal Government Transition Update | April 11th, 2025
An Update on F&A, Review-and Repeal of Federal Regulations, New USCIS Social Media Screening, Title IX Investigations Team, Reductions in Force, and FDA Phase out of Animal Testing from CU Federal Relations and Counsel

Federal Government Transition Update | April 4th, 2025
An Update on Student Visas, the Announcement of New Agency Priorities, State-filed Lawsuits on Recission of COVID Funds and NIH Grant Disruptions and Terminations, and the Cancellation of Teaching Grants from CU Federal Relations and Counsel

More Updates

Media Requests

Please direct all CU Anschutz media requests to media@cuanschutz.edu.

External Updates & Resources

Last updated March 27, 2025

National Institutes of Health (NIH) - NIH Grants and Funding Information Status
Association of American Medical Colleges (AAMC) - AAMC Leads
Council on Government Relations (COGR) - 2025 Administration Transition Information & Resources

Office of the Vice Chancellor for Research

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FAQs Updated on April 9: Federal Transition Updates for Researchers Webpage

Federal Transition Updates for Researchers

Communications from Vice Chancellor for Research Thomas Flaig, MD

Frequently Asked Questions by CU Anschutz Researchers

Questions? Documents to share?

University of Colorado Resources

Recent CU Federal Transition Updates

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Office of the Vice Chancellor for Research

FAQs Updated on April 9: Federal Transition Updates for Researchers Webpage

Federal Transition Updates for Researchers

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Communications from Vice Chancellor for Research Thomas Flaig, MD

Federal Agency Transition Update | March 19, 2025

Federal Agency Transition Update | February 7, 2025

Federal Agency Transition Update | January 29, 2025

Federal Agency Transition Update | January 23, 2025

Frequently Asked Questions by CU Anschutz Researchers

NEW: My grant application was rejected for not having the Foreign Justification document uploaded at the proposal stage. Has there been a change in review of the Foreign Component in NIH applications?

UPDATED: What should I do if I receive a termination letter or stop work order?

What is the status of NIH study sections?

What should I do if the requirements of a federal research grant that I’m fulfilling potentially conflict with the directives of an Executive Order (e.g., about DEI) issued since January 20, 2025?

What is the status of new National Institutes of Health (NIH) Diversity Supplements?

Should I keep working on my grants and contracts?

Whom should I contact with questions on federal grants?

Whom should I contact if I receive an attestation or questionnaire requiring signature from NIH or other federal sponsors?

What is the status of No Cost Extensions (NCE) at NIH?

Questions? Documents to share?

University of Colorado Resources

Recent CU Federal Transition Updates

More Updates

Media Requests

External Updates & Resources

Office of the Vice Chancellor for Research