General Guidance

Overview

Several Executive Orders have been issued (White House News), which reflect shifts in federal priorities. Please review the guidance below on the impact of these changes as federal agencies and sponsors adapt to these developments.  

If you receive information that isn’t already on this page, please forward it to Kerry Peluso, Associate Vice President for Research Administration and Finance (kpeluso@fsu.edu) for inclusion.

Proposals

• Proposals will continue to be submitted under FSU’s existing processes and procedures.
• Sponsor proposal review timelines may be extended while federal agencies navigate pauses on federal assistance funding in specific areas.
• Pre-award spending is not recommended at this time. Requests for Advance Accounts will require additional reviews and may not be approved.

What to Do:

• There may be changes to proposal deadlines. It is recommended to reconfirm the deadline and program dates.
• Reconfirm that the funding announcement has not been revised, postponed, or removed. If available, consider signing up for alerts from the federal agency or sponsor.
• Expect DEIA-related aspects to be removed from solicitations.

Awards

• The terms and conditions of your executed award remain enforceable so long as your award is active.  This includes the ability to invoice and receive reimbursement.  Please continue with business as usual.   If there is a change to your award, FSU will receive an amendment for review and execution.
• We anticipate possible changes to research compliance requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis. We will share any information we receive with you, though you may also receive instructions directly from your Program Officer. It is crucial to act swiftly to ensure compliance with any new requirements, as failure to do so could jeopardize funding.
• We anticipate updates to award reporting requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis. We will share any information we receive with you, though you may also receive instructions directly from your Program Officer.  It is crucial to act swiftly to ensure you comply with any new reporting requirements, as failure to do so could jeopardize funding. If you need assistance managing any requests, please contact your Grants Officer in SRA.
• Delays or pauses in payments for existing grants are anticipated.
• Federal agencies have issued notices to immediately cease all DEIA (Diversity, Equity, Inclusion, and Accessibility) activities. These include training, reporting, staffing-related, and other activities. If you are unsure if this would apply to your activities, please contact Kerry Peluso, Associate Vice President for Research Administration and Finance to discuss.

What to Do:

• Review your Grant Award: Ensure you understand the terms, especially clauses related to funding availability and reimbursement.
• Cease any DEIA activities (per note above).
• Funds budgeted for DEIA activities should remain unspent and NOT be rebudgeted to other areas.
• Monitor spending on your projects: Closely monitor obligated budget balances to avoid deficits while awaiting future obligations. Anticipated future funding remains subject to the availability of funds and should not be considered guaranteed. All pre-award spending on existing advance accounts should be kept to a minimum (ensuring that the requirements of the project continue to be met and the project is not negatively impacted).
• Monitor due dates: Ensure reports and deliverables are addressed in a timely manner. Prioritize the submission of any technical reports or deliverables that may be past due.
• Monitor Policy Updates: Keep an eye on announcements from the federal agency overseeing your grant for any updates on funding or compliance requirements.
• Monitor communications from OVPR (Office of the Vice President for Research) and SRA (Sponsored Research Administration): Closely monitor your emails and this dedicated page for Federal Research Updates for any communications regarding updates and changes.
• When engaging in procurement activities for federally funded projects, please consider the following:
• If federal funding has not been obligated to FSU to pay for the procurement, consider postponing or canceling the procurement until the required funds are awarded.
• If a procurement is in process, review the terms and conditions of the agreement for cancellation provisions and upcoming payment milestones.

NIH Guidance

FSU Researchers: 

Please see the recently issued NIH policy on foreign subawards. Please contact the SRA Pre-Award General Mailbox SRA-Pre@fsu.edu or your Grants Officer if you have any questions. The full policy can be accessed at https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html

Issued by NATIONAL INSTITUTES OF HEALTH (NIH)

This Guide Notice updates NIH policies and practices utilizing foreign subawards. NIH recognizes that some recipients do not accurately report on subawards consistent with Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements (NIH GPS 8.4.1.5.5), which state that recipients must report on all subawards/subcontracts/consortiums equal to or greater than $30,000. This includes awards that are initially below $30,000 but subsequent grant modifications result in an award equal to or greater than $30,000. This lack of transparency is particularly concerning in the case of foreign subawards, in which the United States government has a need to maintain national security.

In an effort to maintain strong, productive, and secure foreign collaborations in support of the NIH mission, NIH must ensure it can transparently and reliably report on each dollar spent. Therefore, NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report. NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026.

Applicability

NIH’s policy change applies prospectively to all NIH grants and cooperative agreements to domestic and foreign entities (new, renewal and non-competing continuation). NIH will not retroactively revise ongoing awards to remove foreign subawards at this time. NIH continues to support direct foreign awards. This policy applies to all monetary foreign collaborations. It does not apply to funds provided to support foreign consultants, or purchasing unique equipment or supplies from foreign vendors. NIH plans to expand this policy to domestic subawards in the future, for consistency in implementing the new award structure.

Policy

Effective with the date of this notice and until the details of the new foreign collaboration award structure are released, NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity. Additionally, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project. In all cases, NIH will allow Institutes, Centers and Offices (ICOs) to renegotiate awards, whether new, renewal or non-competing, to remove subawards to foreign entities and, where the work can be performed domestically, allow the funds to be rebudgeted for use by the prime recipient (domestic or foreign) or a domestic subrecipient. If a project is no longer viable without the foreign subaward, NIH will work with the recipient to negotiate a bilateral termination of the project, taking into consideration any need to support patient safety and/or animal welfare.

Notices of Funding Opportunities (NOFOs) that state that foreign components are allowed are superseded by this notice. NIH will revise NOFOs to reflect the new award structure.

NIH Guidance

FSU Researchers: 

Please see the notice below, received from the National Science Foundation, regarding a new annual certification requirement for Principal Investigators (PIs) and Co-Principal Investigators (CoPIs) that takes effect on June 7, 2025.  Please contact the SRA Pre-Award General Mailbox SRA-Pre@fsu.edu or your Grants Officer if you have any questions.  

Dear Colleague,

The U.S. National Science Foundation (NSF) is providing this correspondence to inform organizations, and Authorized Organizational Representatives, of a new annual certification requirement for Principal Investigators (PIs) and co-Principal Investigators (co-PIs) regarding Malign Foreign Talent Recruitment Programs (MFTRP).

Starting on June 7, 2025, in accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii), all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP. Individuals who are currently a party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. NSF is providing notification of this new requirement to impacted PIs and co-PIs.

What you need to know about completing the required MFTRP certification in Research.gov:

• There is no organizational certification requirement, the certification requirement is for PIs and co-PIs.
• Impacted PIs and co-PIs will be prompted to complete the MFTRP certification after signing into Research.gov using the Sign In link at the top of www.Research.gov.
• PIs and co-PIs with more than one active award made on or after May 20, 2024, are only required to certify once, annually.
• Once completed, PIs and co-PIs can view their MFTRP certification response under the Academic/Professional Information section of their profile.
• NSF is working to expand the MFTRP annual certification requirement for all senior/key personnel roles at a future date. Additionally, NSF is working to provide organizations with access to the annual certifications.
• Please see PAPPG Chapter II.D.1.d(ix) for information about Authorized Organizational Representative (AOR) responsibilities regarding senior/key personnel MFTRP certifications.
• Frequently Asked Questions and MFTRP contract examples will be available on the MFTRP section of the Office of the Chief of Research Security Strategy and Policy website shortly.

If you have any questions about this requirement, please contact researchsecurity@nsf.gov for additional guidance. System-related questions should be directed to the NSF IT Service Desk at 1-800-381-1532 (7:00 AM - 9:00 PM ET; Monday - Friday except federal holidays) or to the Research.gov team rgov@nsf.gov.

Best regards,

NSF Office of the Chief of Research Security Strategy and Policy