Federal Guidelines

Office of Sponsored Programs

Uniform Guidance

In December 2014, OMB together with Federal awarding agencies issued an interim final rule to implement the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (). This guidance and implementing regulations delivers on President Obama’s second term management agenda and his first term directives under , the , and the objectives laid out in to better target financial risks and better direct resources to achieve evidence-based outcomes. The final guidance, originally published on December 26, 2013 () simultaneously improves performance, transparency, and oversight for Federal awards.

The reforms that comprise the Uniform Guidance aim to reduce the administrative burden on award recipients and, at the same time, guard against the risk of waste and misuse of Federal funds. Among other things, the OMB's Uniform Guidance does the following:

Removes previous guidance that is conflicting and establishes standard language;

Directs the focus of audits on areas that have been identified as at risk for waste, fraud and abuse;

Lays the groundwork for Federal agencies to standardize the processing of data;

Clarifies and updates cost reporting guidelines for award recipients.

*The Guidance was drawn from OMB Circulars A–21, A–87, A–110, and A–122 (which have been placed in past OMB guidances); Circulars A–89, A–102, and A–133; and the guidance in Circular A–50 on Single Audit Act follow-up.

Malign Foreign Talent Recruitment Programs

A Foreign Talent Recruitment Program (FTRP) is an effort organized, managed, or funded by a foreign government or entity to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). FTPRs generally involve two elements: 1) compensation from a foreign country or entity to the researcher in exchange for 2) specific research activities, opportunities, or obligations that may create a risk of conflict of interest, conflict of commitment, loss of IP, or other risks. Compensation need not be cash but could include in-kind contributions, access to resources, research funding, titles, travel, or items of non-de minimis value. FTRPs are not limited to programs with an explicit purpose of recruiting personnel but may have broader goals (e.g.: to recruit the targeted individual to support the foreign country’s research and development initiatives in exchanges for benefits to the individual being recruited).

The prohibits participation in a Malign Foreign Talent Recruitment Programs (MFTRP) by individuals involved with federal research and development awards. MFTRPs most often involve China, Iran, North Korea, or Russia, or entities in those countries, and must meet certain other criteria. Federally funded researchers are required to certify that they are not participating in MFTRPs. NSF requires certification effective March 20, 2024, and the DOD will require certification starting August 2024. Other federal agencies have not published timelines for this certification. The certification has been added to the US Government’s common disclosure forms for Current and Pending (Other) Support and the Biographical Sketch.

Participation in a Malign FTRPs by federally-funded researchers is prohibited under federal law and University policy.

FTRPs raise research security concerns. If you believe you have been contacted by an FTRP, or have any other questions, please reach out to OSP.

Related Resources & References

The DOD has published a (page 18)
White House has for federal agencies regarding FTRPs
The NSF has revised the with new language and certification requirements for addressing MFTRPs

Updates on Federal Research Policies

The Office of Sponsored Programs (OSP), the Office of Academic Affairs, the Office of Finance and Business Affairs, and the Office of the General Counsel are all closely monitoring the situation. For faculty, we’ve created this section to provide ongoing updates and will also send less frequent emails if/when significant updates occur. We encourage researchers to check back regularly as these changes are happening on a weekly and sometimes daily basis.

Updates and Guidance

NIH Updates

In late January, NIH issued a pause on grant reviews, public communications and travel. On February 3, 2025, the NIH began to ease the freeze on grant reviews, but operations remain far from normal. NIH remains to review existing grants for DEI.

All standard RPPRs, invoicing, and submissions of new grants appear active. Grant review panels will be rescheduled.

On February 7, 2025, the National Institute of Health (NIH) issued a new directive capping the allowable indirect cost (IDC) rate grants at 15% for all new and existing grants. This is lower than �鶹��ýӳ��'s federally negotiated rate of 50%. On February 10, 2025, multiple lawsuits were issued, and a federal judge granted a temporary restraining order (TRO), pausing the implementation of that policy. A hearing was held on February 21, 2025 and the TRO was extended.

As of now, the implementation of the IDC cap remains on hold pending a final decision to the legal challenges. For the time being, continue to apply the standard rate to existing grants and new proposals.

On April 4th, a US district judge blocked NIH's indirect cost reduction policy, which would have capped all universities' indirect costs at 15%. While there may be a federal appeal and ongoing negotiations at the federal level regarding indirect rates, for the time being universities can continue to use their existing federally negotiated rates.

NIH released an alert notice, modifying the current terms and conditions of all grants and contracts. The new policy applies to both new and existing awards. In accepting an award, a university and PI must certify that the university does not (a) operate programs that advance or promote DEI and (b) does not engage in boycotts related to Israel.

NSF Updates

On January 28, 2025, the National Science Foundation (NSF) issued a temporary freeze on grant reviews and funding. On February 2, 2025, the NSF lifted the suspension due to a court order. All existing NSF proposals have been reviewed to identify conflicts with an Executive Order concerning DEI.

None of �鶹��ýӳ��’s grants have been found in conflict with Executive Orders. Most active solicitations remain open, but you should review the solicitation to make sure. Some meetings have been cancelled, and due to the federal reduction in force (RIF), you may experience some delays in response times from NSF officials and Program Officers.

NSF has posted a new regarding the new executive orders and it's impact on NSF.

On May 5, 2025 NSF implemented Policy Notice NSF 25-034, capping indirect costs on new grants at 15%. On June 20, 2025, a judge declared the policy invalid. At this time, �鶹��ýӳ�� will still be incorporating it's federally negotiated rate into proposals and awards.

Q&A

(February 24, 2025) - At this time, no. Continue doing the good work you do. If federal policy should change, or should agencies pause funds again in the future, we will issue new directives.

As of this time very few proposals have been affected. PI’s will need to review the funding announcement to make sure it has not been amended or postponed.

In the event a sponsor has contacted you regarding the new policy changes, please contact Mellissa Williams at mellissa.williams@yu.edu.

Any official stop work orders need to be complied with. No grant activity will be allowed once a stop work order has been issued. If you have received a stop work order, please contact Mellissa Williams (mellissa.williams@yu.edu) asap so that we can address it.

While our office is learning about these changes at the same pace other universities are, there may be some questions we would not have the answer to. But if you have any additional questions or concerns, please feel free to reach out to the Office of Sponsored Programs and we will do our best assist you.