We are closely monitoring potential changes to how federal awards may be awarded, amended and/or discontinued. Information and guidance is being updated on a near daily basis.

Contents

Updated 3/18/2025

Introduction

The President’s recently issued Executive Orders resulted in federal agency notifications to pause work, either entirely, or in part. There have been several challenges to these Executive Orders, resulting in Temporary Restraining Orders (TROs). In particular, a Temporary Restraining Order (TRO) was issued directing Federal grant-making agencies not to pause or terminate awards and obligations on the basis of the Executive Orders. On February 10th, the Court granted a Motion to Enforce in full. An appeal to the TRO was denied.

As a result of the TROs, agencies are responding by lifting earlier restrictions, usually through broad agency memo, rather than specific to any one award.
While the TROs are in effect, researchers can continue working on their federal awards but there are exceptions for federal contracts and some subawards, as described further under Scope Revisions. PIs will be notified when their award is approved to resume, if it received an earlier stop-work order.

Any PIs receiving agency communications related to specific award changes should create an OSP &GCA Award Modification in SAGE, and then forward these to the Office of Sponsored Programs (OSP), emailing osp@uw.edu, along with the MOD#.

Proposals

All federal agency submission systems are operational at this time. Check your funding announcement for any revisions or updates, including the opportunity expiration date. Consider signing up for alerts from federal agencies or sponsors.

Please use UW’s federally negotiated indirect cost rates until further notice.

If the Notice of Funding Opportunity (NOFO) requires compliance with recent federal executive orders:

  • Make sure to include all attachments that are required for successful submission (e.g. passes validations)
  • If there is a recent court decision blocking an executive order, it is okay to include a statement in a cover letter or budget justification document, such as “The University recognizes this program falls under recently issued Preliminary Injunctions. In order to meet the submission deadline, the University submits this application with required components and reserves the right to amend it consistent with current Court rulings”.

Please use UW’s federally negotiated indirect cost rates until further notice.

Post Submission

Various federal agencies are assessing funding priorities and making adjustments in operations in response to executive orders and directives. We are aware that NIH study sections should have resumed but are held up because NIH needs to list upcoming meetings in the Federal Register and there are no new notices at this time. We are aware of other agency funding decisions that have been delayed.

If a federal agency emails a PI with the option to revise recent proposals to remove or change sections within the proposal, the change may be minor and acceptable to PIs or it may raise concerns. If the PI wants to evaluate if such request is consistent with current legal proceedings, please contact the Office of Sponsored Programs at osp@uw.edu. Your question will be fielded with the AG’s office assistance If a revised proposal will be submitted, or a response to a sponsor submitted, please follow the processes for these action:

Advance Spend

There are three scenarios where PIs may have worktags that allow spending in advance of official notification of award from a sponsor:

  • New awards that are either anticipated or under review/processing.
  • Mid-project spend ahead of the next year’s funding, when that funding is delayed.
  • End of project spend ahead of a formal no-cost extension approval.

With the increasing uncertainty about federal funding, normal processes for advance spending on research cannot be sustained. At this time, the University is introducing limits on advance spending on federal and federal flow-through awards, as follows.

New Advance Spend Requests

New Advance Spend requests will only be approved in the following limited cases:

  • For new awards, an Advance Award may be approved when a formal agreement is in place, if needed due to delays in award setup.
  • For non-competing renewals and no-cost extensions, a Renewal Advance or a Temporary Internal Extension may be set up for 30 days from the current end date of the award. At the end of this period, if formal sponsor approval has not been received, departments should identify alternate funding or initiate temporary HR actions.

Advance Award Already in Place

For cases where an Advance Award is already in place:

  • If a formal agreement is in place, OSP and GCA will prioritize the award setup.
  • If no Notice of Award has been received, timing of a pause on expenditures will depend on the Advance spending start date:
    • If the start date is before 2/1/2025, there must be a pause in expenditures immediately.
    • If the start date is in February, PIs should minimize spending and work with their HR consultant to determine when to pause spending, aiming for 3/31/2025 at the latest.
    • If the start date is 3/1/2025 or later and formal sponsor approval has not been received after 30 days, spending must pause.

When the Advance Award is paused, departments must identify alternate funding or initiate temporary HR actions. For guidance, work with your HR consultant and see HR Support Resources for Federal Policy Impact.

All other non-federal Advance Spend may continue to be requested but may receive increased scrutiny.

Awards

Reports

Stay on top of timely submissions per standard instructions in your award.

Scope Revisions

Some PIs are receiving notices to cease award activities that have become noncompliant with the new Executive Orders, either specific to a particular project or via a broad message from the agency. However, with the Motion to Enforce the TRO, we are hopeful that these will abate. If you do receive a request for scope changes that requires you to send in a revised Statement of Work (SOW), then the revision must be submitted through OSP using the SAGE (MOD) process.

Please create an OSP & GCA MOD, select “Other Changes” tab, and the subcategory of “Executive Branch Directive Change”. OSP is ensuring there is review of such requests prior to submission, in light of the TRO and Motion to Enforce. This information is also being shared with the AG’s office.

If an agency sends a request for changes through a broad directive there is no need to send changes through OSP on an Award Modification. You may continue to send any broad agency communications to osp@uw.edu, for awareness.

Questions about specific activities on your project should be directed to your program manager. Please document any communications that you have with your program manager associated with scope changes.

Terms or Award Changes

We anticipate changes to sponsor requirements for compliance, certifications made by the UW as a grantee/contractor, and award reporting.

Changes may come from a sponsor as a blanket change, by memo, or newly implemented policy. Others may be through individual award amendment. They may be imposing or lifting restrictions. You may also receive informal instructions directly from your Program Officer. If you receive any individual amendment or other specific award change instructions, please submit them as an OSP & GCA Award Modification (MOD) in SAGE select “Other Changes” tab, and the subcategory of “Executive Branch Directive Change”.

Stop or Suspend Work Orders

A stop or suspend/pause work order may come to the PI or the PI’s department, or it may come to OSP or GCA. Irrespective of whether the change order is dated before or after the TRO went into place, these guidelines must be followed to ensure proper consideration. Please note that action should be taken as soon as possible – and within 24 hours.

  • If GCA receives a stop/pause work order, they should forward it immediately to osp@uw.edu.
  • When OSP receives a stop/pause work order, an Award Modification will be created and routed to the PI within 24 hours for awareness and additional information. If the change order appears inconsistent with the TRO, OSP will confirm with the sponsor before processing the Award Modification.
  • If a PI or their department receive a stop/pause work order, the PI must create the OSP & GCA Award Modification within 24 hours of being notified. Choose “Other Changes”, and the subcategory of “Stop work Order” in creating the MOD. Include the sponsor communication along with any required documents, identify the sponsor deadline, and route to OSP. Please also email osp@uw.edu with the MOD #.

Within 24 hours of being notified, the PI must contact their department administration, dean’s office and central HR consultant to initiate processes for expenditure management. Please review UW Human Resources information.

Resuming Work

Direct grants and cooperative agreement awards made to UW that were paused prior to the TRO, and any associated subrecipients, have been authorized to resume. For federal contracts and pass-through funding, we need formal notification to resume work.

If you directly receive a specific resumption notice for your award, please submit it as an OSP & GCA Award Modification in SAGE, choosing “Other Changes” as the Category, and “Resume Work Order” as the subcategory. Be sure to attach the specific award notice to the MOD. Please let osp@uw.edu know the MOD#.

Early Termination

In some instances, we are seeing early termination of active federal and federal flow-through awards. If received, please submit as an OSP & GCA Award Modification in SAGE, choosing “Schedule Change” and the subcategory of “Early Termination”. Please let osp@uw.edu know the MOD #. Please review UW Human Resources information.

Appeals

Some termination notices include clauses that allow the PI to appeal. PIs must work with their department and school/college leadership to review the information provided in the termination notice to determine whether to appeal. OSP is responsible for submitting the appeal. OSP will work with the PI in developing the justification. Note that all charges to the project must be suspended during the appeal process.

Contact Carol Rhodes, OSP Director at carhodes@uw.edu if you are considering an appeal.

Spending & Expenditure Management

Unless you have received a stop work or change order, please consider it business as usual for activity on your federal awards. Any specific change that impacts spending should be processed as an Award Modification in SAGE.

For stop/pause work orders and some scope changes, there will be impacts on employee salary support. If there are insufficient other funding sources to cover salary for an employee, the department must initiate a furlough or layoff. Please work with your Department and School when making these decisions.

Any expenditures benefiting the project incurred after the effective date of the stop/pause work order must be charged to an alternative spending source. Projects with a stop or pause work order will also have a hiring freeze.

Temporary Internal Extension

Please review updated guidance before making Temporary Internal Extension Requests for federal and federal flow-through.

Travel

There may be delays in conferences, on site activity, and presentations.

Subawards

Subawards will continue to be processed as usual. Additional terms and conditions may apply.

OSP will be actively monitoring change orders for outgoing subawards and will consider broad agency announcements in issuing subawards.

These guidelines are applicable to all subawards, whether or not the subrecipient is foreign or domestic.

Subaward: Assurance Letters

During this period of uncertainty, OSP will no longer be issuing assurance letters to subrecipients on federal funding prior to subaward set-up.

Subawards: Stop work/Suspension Orders

When there is a stop or suspend work order for a specific project:

  • OSP will issue suspension letters to active subrecipients & intended subrecipients consistent with the direction of the sponsor. The UW PI and SAGE Subaward Preparer will be copied on the email to the Subrecipient PI and contact.
  • You do not need to send a subaward request to suspend a subaward. Subawards that have not been processed yet will continue to be processed to cover activity up to the stop work date.

Subawards: Change of Scope

When there is no stop work order, but the agency has issued an amendment ceasing activities associated with categories of recent Executive Orders (e.g. DEIA, gender identity), and this impacts the subaward:

  • Submit a request to modify the Subaward in the SAGE Subawards Module.
    • Indicate the need for a subaward scope and/or budget change.
  • Include any relevant attachments & information from the sponsor.

Subaward: Early Terminations

When a federal agency issues an early termination for a project and there are subawards:

  • Follow guidance on requesting an Early Termination MOD in SAGE
  • Submit a request to modify the Subaward in the SAGE Subawards Module
    • Indicate the new end date
    • Include any budget changes
    • Include all relevant attachments & communications with the sponsor

If you have questions about a subaward change order, please email ospsubs@uw.edu.