Federal Transition Update (Feb. 13)
Dear research colleagues,
As you know, the situation regarding federal research guidelines is rapidly changing. I want to assure you that we are committed to keeping our research enterprise moving forward and to supporting you through this challenging time.
On Monday, a U.S. District Court Judge in Massachusetts issued a temporary restraining order (TRO) blocking the implementation of the new National Institutes of Health (NIH) policy that caps indirect costs (IDCs or F&A) at 15%. The policy was released only late last Friday. As a result, Northwestern is currently submitting proposals and reimbursements using our existing negotiated indirect cost rate.
While this process plays out, these policies will be in place:
Proposal submissions: Northwestern will continue to submit proposals using our negotiated (full) indirect cost rate. Proposals may not be submitted at a reduced rate. Exceptions, such as training grants, should continue following previous guidance.
Budget justifications: While this TRO is in effect, we recommend that any budget submissions to NIH, including cases where Northwestern is a subawardee, include this statement in the budget justification:
At the date of budget preparation, the NIH Supplemental Guidance (NOT-OD-25-068) issued on February 7, 2025, limiting indirect cost recovery to a 15% rate has been temporarily enjoined. Therefore, our budget was prepared using Northwestern's indirect cost rate under its Negotiated Indirect Cost Rate Agreement with DHHS.
New awards: Northwestern is not currently accepting NIH awards with a 15% indirect cost rate. If we receive new NIH awards, or flow-through awards from other institutions, that reference the 15% indirect cost rate, they will be placed on hold until this issue is resolved. For this reason, pre-spending on NIH awards will also be paused until this situation is resolved.
No-cost extensions (NCEs): The automatic NCE function in eRA Commons was recently deactivated without an official explanation from NIH. PIs should not assume that a no-cost extension request will be approved. If you are approaching the end of your award period and believe an extension may be necessary, please submit a NCE request through CERES to the Sponsored Research office as soon as possible.
We understand that this evolving situation creates uncertainty, and we sincerely appreciate your patience and perseverance. Please know that Northwestern is actively advocating for its research community and will keep you informed as new information becomes available. Regular guidance will continue to be posted on the Office for Research website. If you have specific concerns or questions about proposal submissions or award management, please contact Cathy Barrera, Assistant Vice President for Sponsored Research.
I appreciate your commitment to research excellence and for all that you do to advance discovery, innovation, and impact.
Eric J. Perreault
Vice President for Research