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Office of Research and Innovation
Research Administration and Compliance

2025 Federal Transition

Last update: Friday, Nov. 14, 2025

Note: Important updates are highlighted in yellow below.

The presidential administration’s Executive Orders and guidance have impacted federal agencies and sponsors that fund research, instruction and outreach at NC State, including proposal review and award processes. These orders, agency internal communications and related media coverage raise questions about how our programs supported by federal funds will be affected.

This page is focused on federal sponsored programs. Executive Orders, Stop Work Orders, Terminations and associated actions have other implications for our campus community. COGR, an association of research universities, affiliated medical centers, and independent research institutes focused on federal policies and regulations, is closely tracking the federal administration transition activity and providing updated information.

Updates

  • On Nov. 12, 2025, the federal government shutdown ended.
  • On Oct. 1, 2025, a government shutdown took effect. This has resulted in federal agencies halting all non-essential functions. This does have broad effects on our federally funded research. The APLU has also created a page with resources to help manage information as this situation evolves.
  • On July 18, 2025, a federal district judge granted a preliminary injunction preventing the Department of Defense (DoD) from implementing its 15% indirect cost cap for universities. If you receive any proposal, request or condition from the DoD limiting indirect costs at 15%, send this information to your College Research Office and the Office of Sponsored Programs and Regulatory Compliance (SPARCS) at SPS@ncsu.edu.
  • On June 20, 2025, a federal district judge ruled in favor of the APLU and other plaintiffs, declaring invalid and vacating the National Science Foundation’s (NSF) implementation of a standard 15% indirect cost rate. The court further ordered that the NSF provide written notice of its decisions to funding recipients affected by the 15% indirect cost rate.
  • On May 19, 2025, the NSF entered into a consent agreement to pause the implementation of Policy Notice: Implementation of Standard 15% Indirect Cost Rate. This pause will continue until June 13, 2025, when a hearing is scheduled on the motion for preliminary injunction. Colleges should contact SPARCS at SPS@ncsu.edu before submitting a new proposal to NSF.
  • On May 15, 2025, a federal district judge granted a preliminary injunction preventing the Department of Energy (DOE) from implementing the 15% indirect cost cap for Institutions of Higher Education. If you receive any proposal, request, or condition from the DOE limiting indirect costs at 15%, send this information or request to your College Research Office and to the Office of Sponsored Programs and Regulatory Compliance (SPARCS) at SPS@ncsu.edu.
    • Some institutions have received “conditional terminations” notices from the DOE. Individuals should not respond to these notices. The notices should be sent to their CRO and SPARCS (SPS@ncsu.edu). 
  • On May 14, 2025, the DoD released a memorandum announcing a 15% cap on indirect costs for new grants, to be implemented within 21 days of the memo’s publication. In addition, DoD has stated it will notify institutions of higher education of its intent to renegotiate all existing contracts to the 15% indirect cost cap within 30 days, with termination where agreement is not achieved by 180 days. DoD will develop and publish new formal policy guidance. Colleges should contact SPARCS at SPS@ncsu.edu before submitting a new proposal to the DoD.
  • On May 5, 2025, the Association of Public and Land-Grant Universities, Association of American Universities and the American Council on Education, along with 13 research universities, filed a joint lawsuit in the US District of Massachusetts court challenging the NSF’s indirect cost reduction. We will continue to monitor the case and provide updates.
  • On May 2, 2025, the NSF released a Policy Notice: Implementation of Standard 15% Indirect Cost Rate. Colleges should contact SPARCS at SPS@ncsu.edu before submitting a new proposal to NSF.
  • On April 11, 2025, the DOE announced through a press release that it would limit DOE financial support of “indirect costs” for Institutions of Higher Education research funding to 15%. It is unclear how this will be implemented at this time. Additional guidance from DOE is forthcoming.
  • On April 4, 2025, a federal district judge granted a permanent injunction preventing the NIH from implementing a 15% indirect rate change. The Trump administration has filed a notice of appeal with the First Circuit Court of Appeals.
  • The university has received new assurance requests, including certifications, questionnaires and data requests in many forms from various agencies. Individuals should not respond to these but should forward them to SPARCS at SPS@ncsu.edu and your College Research Office.
  • The President issued Executive Order Establishing and Implementing The President’s “Department of Government Efficiency.”
  • A federal district judge issued a preliminary injunction against certain provisions of Executive Order Ending Radical and Wasteful Government DEI Programs and Preferencing and Executive Order Ending Illegal Discrimination and Restoring Merit-Based Opportunity. The Fourth Circuit Court of Appeals stayed this preliminary injunction on March 14, 2025.
  • The Office of Management and Budget Memorandum (OMB) M-25-13 was rescinded. While you might have seen this memo referenced in agency communications, we cannot infer how the rescinded memo will change the actions the agencies are required to take.

Resources

Terminations

  • If you receive a termination notice, please forward the notice to your College Research Office, SPS@ncsu.edu, and researchadministration@ncsu.edu. Your College Research Office will work with you and SPARCS to:
    • Review the terms and conditions of your grants and contracts
    • Understand what federal regulations govern the termination
    • Determine how to properly closeout and recover any allowable costs on your grant or contract
    • Determine the timelines and next steps

Termination Appeals

Proposals

  • Proposals to the NIH and DOE should continue to follow opportunity-specific guidance. Please consult your College Research Office for budget assistance.
  • Submit proposals according to published deadlines. Most proposals are electronically time-stamped, so they will be accepted or deemed late according to electronic submission. It is not clear when or how proposals for various agencies and programs will be reviewed.
  • Review the original electronic copies of funding announcements you are responding to in order to identify any changes to due dates, scope or other requirements. Sign up for automatic alerts where available. Some opportunities have been suspended and others modified to implement Executive Orders.

Awards

  • Contracts, grants and other agreements with federal agencies and federal contractors remain in effect unless formally modified, Stop Work Order or a Termination is received. 
  • Deliverables, including progress reports, should be submitted as scheduled. Technical reports submitted through electronic portals are time-stamped. Overdue reports jeopardize future funding to NC State and our collaborators.
  • Agency portals for prior approvals continue to function. Please continue to request modifications in a timely manner via the Project Modification Request (PMR) system. 
  • Continuation awards and prior approvals that require sponsor staff review may be delayed.
  • Compliance requirements and assurances for sponsored programs might change. Please forward any new assurance requests, including certifications, questionnaires or data requests, to SPARCS at SPS@ncsu.edu and your College Research Office.
  • Researchers should expect limited communication from their federal program and grant management officers during this transition period.
  • Project budgets and burn rates should be closely monitored. Deficits should be avoided. Spending against future funds should be limited as future obligations may be delayed. In extreme cases, expenditures against future funding may not be reimbursed.

Project- and Program-Specific

  • PIs do not need to take action in response to the NIH Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rate or the DOE press release limiting financial support of “indirect cost” to Higher Education. Central offices will adjust F&A rates appropriately if it becomes necessary.
  • As always, please consult your College Research Office for specific proposal and award needs. 
  • Researchers and Program Directors receiving a directive or guidance directly from their sponsoring federal agency are encouraged to notify the Office of Research and Innovation at researchadministration@ncsu.edu so we can monitor how agencies are responding to these changes and support you in determining appropriate responses. 
  • The use of pre-award project IDs and at-risk spending should be limited to only those projects where progress is at significant risk.

Projects with DEI Supplements, Segments or Activities

  • Under the Executive Order issued on Jan. 20, 2025, federal agencies are instructed to eliminate DEI considerations from their processes. This directive affects current and future Notices of Funding Opportunities and award terms and conditions.
  • Programs with specific diversity, equity and inclusion initiatives should be reviewed for compliance with any specific agency requirements or University guidance. Other project activities should continue.
  • Funds allocated for DEI activities on federal awards should not be re-budgeted, nor used for other purposes unless directed by the federal sponsor.

Stop Work Orders

NC State has received both Stop Work Orders for all project activities on specific awards and orders to cease certain activities related to the Executive Orders (e.g., DEI, Community Benefit Plans).

Project Stop Work Orders

  • For temporary Stop Work Orders, the issuing agency will likely thereafter complete a review resulting in either a resumption of the award (possibly following revisions to the Statement of Work and/or an award modification) or award termination.
  • Stop Work Orders should be promptly forwarded to your College Research Office, SPS@ncsu.edu and researchadministration@ncsu.edu.
  • Stop Work Orders will be processed in RED to effect a temporary pause in spending on any associated ledger-5 account.

Directives to Cease Certain Types of Activities (DEI, Community Benefits Plans, etc.)

  • The activities described must be discontinued.
  • Reviewing the associated federal funding announcement, proposal and award can help identify related activities.
  • Continue your non-DEI or other project activity (including travel) unless you receive a project Stop Work Order.

FAQs

  • What does a Stop Work Order mean?
    • While a Stop Work Order is in effect, NC State personnel should not be conducting sponsored project activities or incurring new operational costs. Please be sure all project personnel, including subrecipients, are informed.
  • Must I cancel future travel planned/prepaid before the Stop Work Order was received?
    • It’s recommended to postpone project activities scheduled over the next several weeks where financial loss from doing so is minimal. Decisions on later travel will likely be dictated by the funding agency’s disposition of the Stop Work Order.
  • What options do I have if my project is terminated?
    • The next steps in the event of a project termination are dependent on the specific agency, nature of the work, and terms and conditions included in the terminated award. Please work with your College Research Office and SPARCS to discuss possible next steps.
  • Does the university maintain records relating to prior and current awards?
    • NC State maintains copies of documentation relevant to all of our funding agency awards in our internal systems (RED, PMR, etc.) and will continue to have access to those records in the event of an extended outage or loss of access externally.

Media Inquiries

Media inquiries should be forwarded to newstips@ncsu.edu and researchadministration@ncsu.edu and responded to with the following:
Thank you for your email. All inquiries regarding NC State research are directed to newstips@ncsu.edu. Your message has been forwarded.