Frequently Asked Questions re: Federal Impacts on UC/UCI Research

Federal Executive Orders and Directives

Can we assume that our current grants will continue to receive funding?

This is a dynamic situation that UCI leadership is monitoring closely. Principal Investigators (PIs) should not adjust spend rates for extramurally funded research projects. Performance on active awards can continue if obligated funds are available and a stop-work or termination order has not been issued by the agency.

Do we know if awards are reviewed in their entirety or if specific parts are considered for cancellation separately from the entire grant?

We understand that agencies are reviewing projects in their entirety but are also considering the preponderance of the type of activities when making termination decisions. Please reach out to your Contracts and Grants Officer if you are contacted by an agency with a request to modify your project.

Is it advisable to wait before submitting a new or revised application?

Proposals may be submitted to available federal funding opportunities. However, agency proposal review timelines may be delayed due to agency-specific implementation plans and funding guidelines. Please reach out to  your Contracts and Grants Officer if you have any specific questions about an application.

Has UCI been able to successfully draw down funds for all our existing federal awards since January 21st?

Contracts and Grants Accounting continues to successfully draw down funds on active federal awards.

Has there been any information or announcements regarding the approval of second or third no-cost extensions for federally funded projects at UCI?

While UCI Sponsored Projects promptly processes first no-cost extensions upon receipt, the response to second and third extension requests varies among federal agencies. Some agencies are actively responding to these additional extension requests, while others have delayed in responding to extension requests.

Are there any updates about the NSF Graduate Research Fellowship Program (GRFP)?

UCI has not received any notices impacting or guidance about the GRFP.

When a federal grant shows all funds as obligated and awarded in the official documentation, does this necessarily mean that the entire grant amount has been transferred to and is currently available in UCI's accounts?

Federal grants operate on a cost reimbursement basis. This means that UCI does not receive the funds upfront. Instead, Contracts and Grants Accounting at UCI draws down funds from the federal agency to reimburse expenses already incurred and recorded in the university's ledger. This draw-down process occurs weekly, specifically every Monday.

If an award is cancelled or terminated, are dispersed funds required to be returned to the agency?

No, federal awards are cost reimbursable. Funds that have already been expended or dispersed do not need to be returned. However, further spending on the project after the termination date should be limited to allowable termination and/or closeout costs in accordance with Uniform Guidance. Please reach out to your Contracts and Grants Officer if you have any specific questions about a terminated award or allowable costs.

Should I change my spending patterns for any of my federally funded projects?

PIs should not adjust spending rates for extramurally funded research projects. Expenditures should proceed as they would under standard conditions.

Are there any institutional funds available for PIs impacted by recent stop work orders or terminations?
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Federal Impact Q&A Form

National Institutes of Health (NIH)

The NIH has announced the imposition of a standard 15% indirect cost rate for Facilities and Administration (F&A) costs, replacing the previously negotiated rate; however, implementation of this rate has been suspended by court order. The rationale behind this change is to allocate more funds directly to scientific research. How crucial are these F&A funds for establishing essential research infrastructure, and what impact does reducing these funds have on the research conducted?

F&A or indirect costs are critical for the research enterprise at UCI. F&A supports research infrastructure, facilities, and administrative support that are not directly charged to grants, but necessary for the research community. The following FAQs from the APLU detail the importance of indirect costs. https://www.aplu.org/wp-content/uploads/frequently-asked-questions-about-facilities-and-administrative-fa-costs-of-federally-sponsored-university-research.pdf

Is the Sponsored Projects office aware of any first No-Cost Extensions (NCE) being approved at NIH, not just allowed to submit, but actually approved?

NIH has reinstated grantee-approved first no-cost extensions, and Sponsored Projects is processing them as received. We have not had any disapproved first no-cost extension requests due to federal EOs or directives.

Have any NIH grants been reduced or have any carryforwards been disallowed?

Sponsored Projects has not received any formal notifications from NIH indicating nonstandard reductions in award amounts or disapprovals of carryforwards because of these Executive Orders and Directives.

Notice of Early Expiration of Notices of Funding Opportunities

NIH announced a new peer review framework for research project grants on October 19, 2023. Some Notices of Funding Opportunities (NOFOs) expired on May 24, 2025.

Supporting Fairness and Originality in NIH Research Applications (NOT-OD-25-132). This Policy is effective for applications submitted to the September 25, 2025 receipt date and beyond. “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…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.” How are applications counted going forward?

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.

The January 2026 Advisory Council in calendar year 2026 is the first to follow the new Policy and corresponds with scientific review dates in October to November 2025 (Cycle II). For 2027, the application limit resets for applications scheduled to be reviewed at the Advisory Council in January 2027, which corresponds with applications submitted for the May 25, 2026, receipt date or later dates and scientific review dates in October to November 2026.

Applications submitted to receipt dates before the September 25, 2025 receipt date will not be counted towards a PI/PD’s limit for calendar year 2026 and will not be withdrawn if they exceed a PI/MPI’s limit of 6 applications in a calendar year. Applications submitted to the September 25, 2025 receipt date and later dates will be counted towards a PI/PD’s limit for calendar year 2026.

Only applications where the investigator is listed as a PI/PD or MPI count toward the investigator’s yearly limit. 

Any of the following applications count towards an PI/PD’s or MPI’s limit of six applications: new, renewal, resubmission, or revision submissions. Administrative supplements, non-competing renewals, Type 4 applications, and Type 7 applications are not counted toward the maximum. The Policy applies to all activity codes except T activity codes, Loan Repayment Programs, X01 Applications that are not Council reviewed, R25s, and R13 Conference Grant Applications. Applications that are withdrawn after peer review count toward the maximum.

For more information on dates for review cycles, including scientific merit review and Advisory Council dates, see: https://grants.nih.gov/grants-process/submit/submission-policies/standard-due-dates.

National Science Foundation (NSF)

The following are just a few of the most pertinent NSF FAQs from the NSF website. Please check the NSF FAQs regularly as new and updated information is posted regularly.

Has NSF paused the implementation of the new 15% indirect cost rate policy?

Yes, NSF has entered into a consent agreement with the court to pause the implementation of NSF-25-034 Policy Notice: Implementation of Standard 15% Indirect Cost Rate pending resolution after a June 13, 2025 hearing. Effective May 19, 2025, NSF will revert to issuing awards according to the institution's negotiated rates while implementation is on hold.

My award cancellation letter indicates that I am not eligible to appeal. Should I send an appeal request to NSF anyway?

No; appeals are not being considered.

Please clarify if the summary of progress under the award requested in the termination notice from NSF, due 30 days from the termination date, will be in lieu of the final annual project report and final project outcomes report. Or is this a requirement in addition to the final annual project report and final project outcomes report?

The summary of progress is the financial accounting of cost due within 30 days of termination, including an estimate to cover the closeout costs required to submit the final/annual report within 120 days. Project Outcomes Reports are waived for terminated awards.

My award was terminated on the basis that it "no longer effectuates the program goals or agency priorities." Can I appeal or seek alternative dispute resolution?

Appeals for terminated awards will not be reviewed or considered. Terminations of awards on the basis that they no longer effectuate program goals or agency priorities are the final agency decision and are not appealable to NSF. In these instances, NSF does not allege a deficiency occurred (e.g., noncompliance with award terms and conditions or research misconduct of the awardee). Because there are no allegations of deficiencies by the awardee to dispute, there are no grounds for agency appeal. Similarly, alternative dispute resolution is not available where terminations were based on effectuation of program goals or agency priorities.

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