Office of the President

On May 16, 2025, the NSF delayed Implementation of Standard 15% Indirect Cost Rate until 6/13/2025. The original NSF policy notice to implement a standard 15% indirect cost rate (released 5/2/2025) stated, “The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.” This delay in implementation is in response to a deferment request until after 5/23 hearing. 

On May 14, 2025, the Department of Defense issued a statement outlining the pursuit of implementing a 15% Indirect Cost Cap on Assistance Awards to Institutions of Higher Education. The policy states the DoD “will pursue a lower cap on indirect cost rates for all new financial assistance awards to institutions of higher education, consistent with federal regulation.” This F&A rate will apply to new financial assistance awards, in accordance with the policy guidance that is forthcoming from the DOD (expected June 4, 2025).  In addition, DOD Components are directed to renegotiate existing awards to incorporate the 15% rate within 6 months.

As with other instances of policy changes during the past several months, we are examining this  potential impact on the VCU research enterprise. 

Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. If PIs received a request from DoD to renegotiate the F&A rate on an existing award, you should reach out to your sponsored program team in the OVPRI (find your team here) for guidance. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement.

As we learn more about this new DOD F&A rate and other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.

Thank you,

Tina Cunningham, J.D.
Associate vice president for research administration

The following message was sent to VCU/VCU Health research faculty and staff:

Dear colleagues,

Earlier today, the NIH issued an Updated NIH Processes for No-Cost Extensions. The notice states that the agency has temporarily disabled the No-Cost Extension functionality in eRA Commons. NIH staff have been directed to “review all existing grants and cooperative agreements to ensure that NIH awards do not fund off-mission activities or projects.” Disabling the NCE functionality allows for a more in-depth review of each extension request. 

NCE’s must now be submitted as a prior approval request in eRA Commons. 

Researchers will need to create an administrative action (AA) in the RAMS-SPOT award record for all NCE requests. Please review our Admin Action Get Started Guide for what should be included in a prior approval NCE.

Researchers who are planning on submitting an NCE for their NIH award are advised to do so well in advance of their anniversary date. 

Please direct any questions to the sponsored program team in the OVPRI (find your team here).

You can find more information about federal research issues here. Information about other federal issues can be found here. 

Thank you,

Tina Cunningham, J.D.
Associate vice president for research administration

The NIH has released an Updated NIH Policy on Foreign Subawards. The updated policy states, in part, that the NIH "will not issue awards to domestic or foreign entities that include a subaward to a foreign entity.” This applies to new, renewal and non-competing continuation awards, effective immediately. VCU investigators with affected awards should discuss options like renegotiation or deferral with their program officers as upcoming NOAs are expected to reflect defunding of foreign subawards.

The following message was sent to VCU/VCU Health research faculty and staff:

Dear colleagues,

Over the past few weeks, the federal government and its research-funding agencies have issued several new and updated directives. While we continue to provide timely updates on our federal funding page, I would like to share more in-depth information for several of them.

NSF 15% F&A rate limit implementation

On Friday, May 2, the NSF announced the Implementation of Standard 15% Indirect Cost Rate policy. The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.” 

The implementation of this policy is effective for all new grants beginning today, May 5, 2025. Current grants are not impacted by this new policy. 

Principal investigators do not need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement. Should you receive direct communication from the NSF regarding updating award budgets, please immediately forward them to your sponsored program team in the OVPRI (find your team here).

The federal government’s long standing recognition and payment of F&A costs has helped U.S. colleges and universities like VCU build, support and maintain the required research infrastructure that has made the American research enterprise the best in the world. At a national level, 10 organizations (including the APLU, COGR and AAMC) are convening a Joint Associations Group on Indirect Costs taskforce to examine the F&A system. VCU will remain engaged in this process - both at the federal and state level. 

NIH Notice of Civil Rights Term and Condition of Award

On April 22, the NIH issued a Notice of Civil Rights Term and Condition of Award. The notice requires that institutions certify that they:

• do not, and will not…operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of federal anti-discrimination laws; and
• do not engage in and will not…engage in, a discriminatory prohibited boycott.
  

These terms and conditions are accepted when we draw down funds from the federal financial system. The university is currently reviewing its policies to ensure that we are in compliance with all federal and statewide DEI guidelines and policies. Thus, until this due diligence is completed, the university is implementing a temporary hold on the drawing down of funds on new, renewal, supplement and continuation awards from NIH/DHHS. 

Although we are unable to immediately be reimbursed for these research activities, it is crucial that faculty are able to continue to conduct their important and impactful research. For current awards, faculty can continue to charge expenses to their existing award indexes. For new awards, full award setup will not be completed until the university can certify this notice requirement. However, faculty can begin work on their new awards by submitting an Advanced Index Request Form to establish their new index. Contact your school or unit research administrator with any questions regarding this process. 

Resolving this is a high priority for the university and we will inform you as soon as this is finalized. It is our hope that this process will be expedient and resolved in a timely manner. 

While these past four months have been filled with uncertainty and concern, it is important that we do not let it stop us from conducting the groundbreaking research that has made VCU a national research powerhouse. My team in the OVPRI and research administrators across the university have been working as hard as possible to ensure that researchers have every level of support we can provide.

As we continue through these challenging times, please do not hesitate to reach out should there be anything we can help with. Researchers who are immediately impacted by either of these temporary holds can reach out to rescomply@vcu.edu for additional information and support. 

Thank you for your continued dedication to VCU's research mission,

P. Srirama Rao, Ph.D.
Vice president for research and innovation

The university is closely monitoring the implementation of the new policy announced by the U.S. National Science Foundation: Implementation of Standard 15% Indirect Cost Rate. The policy statement shares, in part, that the “NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.” 

This F&A rate maximum applies only to new awards beginning on May 5, 2025 and does not apply retroactively to existing awards. 

As with other instances of policy changes during the past several months, we are examining this  potential impact on the VCU research enterprise. 

Principal investigators do not, and will not, need to change rates on current or future projects; the Division of Sponsored Programs and/or Grants and Contracts Accounting will adjust F&A rates, as necessary. For clarity, all proposals should be submitted in accordance with our existing negotiated rate agreement.

As we learn more about this new NSF F&A rate and other federal policies, we will continue to provide timely updates and guidance through email communication and on our federal funding updates webpage.

The OVPRI is aware of yesterday’s notice (NOT-OD-25-090) from the NIH,  which, in part, requires recipients of NIH funds to certify that they: 

• do not, and will not…operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws; and
• do not engage in and will not…engage in, a discriminatory prohibited boycott.

As are research universities around the country, VCU is examining any immediate implications of this notice. 

Currently, there are no changes to the operations of existing grants and funding - please continue to work and charge expenses to your projects in a prudent manner and according to sponsor-approved budgets.

As soon as possible, we will provide additional guidance.