On June 12, the DOD issued a new 15% F&A cap for institutions of higher education. The American Association of Universities (AAU), along with the Association of Public and Land Grant Universities (APLU), the American Council on Education (ACE), and 11 AAU members have filed suit in the U.S. District Court for the District of Massachusetts to stop the policy. The University has submitted a legal declaration in support of the lawsuit. On July 18, the MA District Court issued a preliminary injunction prohibiting the DOD from implementing the rate cut.

More details on this policy change and guidance from Sponsored Programs can be found here.

On April 14, the AAU, ACE, APLU, and nine universities filed a lawsuit in the United States District Court for the District of Massachusetts seeking to block the DOE rate cut. The University submitted a strongly worded written statement in federal court supporting the lawsuit. On June 30, the MA District Court vacated the DOE rate cap, preventing the DOE from unilaterally implementing the F&A rate cuts. The cap is not in place, pending an appeal by the government.

More details on this policy change and guidance from Sponsored Programs can be found here.

On Monday, February 10, three separate lawsuits were filed in the US District Court in Boston challenging the NIH’s February 7 notice. On April 4, the court granted a nationwide permanent injunction preventing NIH’s implementation of the 15 percent F&A cost rate across the United States, and shortly thereafter, the Trump Administration filed an appeal in the United States Court of Appeals for the First Circuit. As a result, the rate cut is currently on hold.

More details on this policy change and guidance from Sponsored Programs can be found here.

On May 5, the American Association of Universities (AAU), along with the Association of Public and Land Grant Universities (APLU), the American Council on Education (ACE), and 13 AAU members filed suit in the U.S. District Court for the District of Massachusetts to challenge the NSF’s new 15% F&A policy. The University has submitted a legal declaration in support of the lawsuit. On June 20, the MA District Court granted the plaintiff’s motion for summary judgment, ruling in their favor on all claims on its merits and finding the NSF 15% F&A cap policy to be unlawful. As a result, the rate cut is currently on hold.

• Summary of Executive Orders via the Council on Governmental Relations (COGR)
• Pending Lawsuits Related to the Freeze on Payments for Grants & Contracts (COGR)
• Agency Responses to Recent Executive Orders (Lewis-Burke Associates LLC; Kerberos log-in required) (download)
• Federal Outlook Webinar (2.12.25; Kerberos log-in required) (download)

• Updates on NSF Priorities (Updated 7.30.25)

Previous agency notices are available here in the Archive of Notices from Federal Agencies and Departments. For agency notices issued in the current month, please see the applicable sections above.

If you have questions about how any notice applies to your specific award, reach out to Sponsored Programs at ospera@bu.edu.

On June 12, NIH issued a Notice of Rescission of Civil Rights Terms and Conditions of Award, withdrawing its April 21 modification of the terms and conditions for NIH grants and agreements related to diversity, equity and inclusion and related concepts and discriminatory boycotts. On May 19, NSF updated its General Grant Conditions.

No action is needed from you at this time. Please continue to work on your federally-funded projects and submit grant proposals in coordination with Sponsored Programs. The University is reviewing and assessing the updates to understand any potential impact to the BU research community.

The University will continue to monitor the latest developments and share information relevant to researchers. Sponsored Programs (ospera@bu.edu) remains the best point of contact for award-specific questions.

The evening of Friday, February 7, the NIH announced a new policy setting a flat 15 percent F&A rate for all existing and new awards at all institutions, effective Monday, February 10, 2025. This new rate would replace previously negotiated institutional rates, including ours.

On Monday, February 10, three separate lawsuits were filed in the US District Court in Boston challenging the NIH’s February 7 notice. On March 5, the court granted a nationwide preliminary injunction preventing NIH’s implementation of the 15 percent F&A cost rate across the United States. As a result, the rate cut is currently on hold.

As with other recent federal research program changes, we are committed to keeping our community informed as this situation continues to develop.

Researchers should continue doing their work and advancing their scholarship, research, and expertise. They should continue submitting grants and thinking strategically about how to position their research to ensure that they can continue pursuing the topics they care about. No preemptive action is required unless you are explicitly notified otherwise by a program officer or through an agency announcement. The University is following federal actions closely and will continue to provide regular updates. 

Unless the sponsor has issued a grant-specific stop-work order, BU research teams should continue conducting research on federal grants. If a termination order is sent to the University from a sponsor, Sponsored Programs would forward it to any affected BU investigators. Faculty should always follow the latest guidance provided by the funding agency and reach out to their program officers for more information as needed.

A stop work order or termination notice may be sent to the PI, a Sponsored Programs grant administrator, or to the institution’s mailbox. If all parties are not copied on the communication, the notice should be sent to the following parties:

• The PI
• Sponsored Programs (ospera@bu.edu)
• The primary department administrator for the project
• Department chair/center director
• The school’s associate dean of research

Please refer to the early grant termination guidelines for next steps.

The Uniform Guidance allows federal funding agencies to terminate awards if the grantee institution has failed to comply with the terms and conditions of the award, including project milestones, or if the award no longer effectuates the program goals or agency priorities. Following the University’s early grant termination guidelines, please consult with Sponsored Programs and the Office of the General Counsel to determine the appropriate course of action.

In accordance with the Uniform Guidance, agencies are required to provide written notice of the termination to the federal award recipient. The notice must include the reason for termination, the effective date, and the specific portion of the federal award being terminated. Each agency has its own procedures for appealing a termination decision. Additionally, the grant or cooperative agreement, or the funding agency’s grant policy statements, may outline agency-specific procedures the recipient must follow to dispute a termination.

Following the University’s early grant termination guidelines, please consult with Sponsored Programs and the Office of the General Counsel to determine the appropriate course of action.

Faculty should continue submitting applications for active federal award solicitations. We encourage investigators to complete applications using the latest posted guidance, including for any components that may conflict with executive orders, to ensure applications are accepted in the system.

As of now, research should continue as planned. As always, stay proactive about managing grant funds to ensure long-term sustainability, but no preemptive changes are required unless you’ve received a written stop-work order.

According to the National Institutes of Health (NIH) Grants Policy Statement, the NIH is required to provide a 30-day written notice before terminating an award, unless there are exceptional circumstances. Reasons for termination may include failure to comply with terms and conditions of the award, lack of progress on the project, scientific misconduct or fraud, or if the NIH determines that termination is in the best interest of the federal government. NIH may terminate an award immediately if the recipient’s actions pose a serious risk (e.g., fraud, safety concerns, legal violations). In some cases, recipients may appeal or request reconsideration.

We understand that many researchers have award-specific concerns. Please send your questions to Sponsored Programs at ospera@bu.edu, and our team will compile them, provide responses, and add to these FAQs around common issues.