Faculty Resources
Guidance and News Related to Recent Executive Orders and Federal Actions
Updated: March 6, 2025
General Guidance from the VPR
January 30, 2025
As we continue to monitor and assess the directives and communications coming down from federal officials and funding agencies, here is my general advice to those of you carrying out grant-funded projects:
- Until and unless you are notified by the funder or by an OSU official to do otherwise, continue with business as usual.
- If you receive communications from the funder related to these matters, immediately pass those communications to your college Sponsored Programs Office.
- If instructed by the funder or by OSU officials to pause or cease any activities,
work with your college Sponsored Programs Office to:
- comply with those instructions as precisely as possible.
- document any quantifiable damages to OSU faculty, staff, students, or units that are directly caused by the directive and/or our compliance with it (this is to aid us in keeping our elected officials apprised of the impacts).
- Stay tuned in to communications from my office (including this webpage) and your college Sponsored Programs Office as we learn more about—and share with you—how best to navigate these challenging waters.
Kenneth W. Sewell
Vice President for Research
Internal Communication and Guidance for OSU Faculty
As it is distributed, internal communication will be posted here.
- February 25, 2025, Memo from VPR Sewell to OSU community
Dear Colleague,
This message is meant for the entire OSU research community as a follow-up to the message I sent out a few weeks ago (located here). These are difficult times in the world of university research, and my heart goes out to all of you who are feeling the stress.
I know that a few of you have had your on-going grant projects directly impacted by the recent actions at the federal level; those impacts have taken the form of Stop Work Orders, or instructions to limit spending due to reimbursement freezes. Thankfully, there have been relatively few such disruptions across OSU—but that is little comfort to those of you involved in the impacted projects. As I know you are already doing, please continue working with your college sponsored programs office and your ADR to ensure that you are complying with the directives while also minimizing the negative effects on students and staff.
In addition to the few highly- and directly-impacted situations mentioned above, I know that many more of you have encountered disruptions and problematic unclarity in communications with and from federal funding agencies: canceled/delayed study sections, mixed messages, withdrawal of entire FOAs with imminent or recent deadlines (with or without assurance that it will be revised and reposted with a later deadline); non-responsive program officers; notification that your program officer is no longer with the agency; …the list goes on and on. And even if your own current or planned projects have not been disrupted, it is understandable that you might feel a sense of anxiety over the possibilities. As natural as it is to be frustrated or worried in the face of these events, I implore you to take courage by focusing on the eventual ways your research will benefit society and on the immediate ways your work is transforming and elevating the lives of your students—both those who might be working directly with you on research, but also those in the classroom who are privileged to have a world-class scholar as their professor.
I want to get into the weeds a bit on a couple of particular actions that have dominated recent headlines: the attempt to cap F&A cost recovery at 15% on NIH grants; and the executive order related to DEI programs.
The attempted cap on NIH F&A cost recovery has sparked a concern that, if this cap is enacted and made permanent, other federal agencies might follow suit. First of all, a federal judge has extended the restraining order that blocks implementation of this attempt until she can decide if a full injunction will be imposed while several lawsuits on the matter run their course. But I do want to address the “what if” just a bit. Here are some of the questions I have heard posed: What if this cap (or caps from other agencies) is imposed? Will this disrupt my research project? Will this have a devastating effect on OSU? Will OSU cease to be a research university?” Although how research universities recover their costs from funding agencies is a matter of critical importance, I am confident in saying the following related to these “What if” scenarios:
- No on-going research project at OSU would be stopped or substantially disrupted if an F&A cost recovery cap were to be imposed during the grant’s period of performance.
- Although OSU would be financially affected by any immediately-imposed F&A cost recovery cap, that impact would be modest. It might change the ways we invest in research facilities into the future, but the immediate impact would be largely unnoticed by current researchers.
- OSU is a research university because it is integral to our mission. We will continue to partner with federal, state, and private entities who wish to access OSU researchers’ expertise to solve problems that matter.
None of this is intended to imply that the arguments over F&A cost recovery are trivial, or that the matter can be easily resolved. I merely intend to put your mind at ease if you were concerned that this particular issue was existential for the OSU research enterprise.
The executive order related to DEI programs has also prompted legal challenges. This past Friday (2/21), a federal court temporarily blocked the ban, stating that the executive order’s lack of definition for the DEI construct was so vague as to make it constitutionally problematic. I will continue to monitor if and how government officials and agencies define the parameters of programs they wish to prohibit, so we can understand and mitigate any negative effects to OSU research.
I stated at the outset of this message that my heart goes out to you as you cope with the litany of stressors that seem to be bombarding us daily. But more important than heart-felt sympathies, I offer my commitment to continue working with the entirety of the OSU administration, APLU’s Council on Research, and our federal partners—within the agencies and within our elected delegation—to ensure that decisions at all levels are at least informed by and hopefully centered on how those decisions affect the communities we serve. I will continue to deliver the message that those communities all rely on us (OSU and other research universities) to produce the breakthroughs that improve the health of our citizens as well as the health of our economy, and in-so-doing prepare our students to be at the vanguard of innovation for generations to come.
As always, thank you for all you do to make OSU an even greater R1 (newly reaffirmed by Carnegie) research university!
Go Pokes!
**************************************
Kenneth W. Sewell, Ph.D.
Vice President for Research
405-744-7076
- January 28, 2025, Memo from VPR Sewell to OSU Principal Investigators with active
grants
OSU Colleagues,
I’m sure most of you are aware of various actions at the federal level (presidential executive orders, memos from the Office of Management and Budget, etc.) that direct agencies to pause and/or cease certain types of grant funding while those programs are reviewed for alignment with the current administration’s policies. Understandably, questions abound among researchers at OSU (and those at universities all across the country) as everyone attempts to understand whether and/or how these actions could affect planned and ongoing grant-funded projects.
Perhaps the most important thing to know at this point is that NO ONE yet knows the answers to the vast majority of questions these actions have provoked. Most of the federal agencies themselves are scrambling to understand how they will comply with these directives; as an example, we’ve been informed that NSF is holding meetings today with the goal of issuing some initial guidance by day’s end.
As we continue to monitor and assess the situation, here is the best advice I can offer at this juncture to those of you carrying out grant-funded projects:
- Until and unless you are notified by the funder or by an OSU official to do otherwise, continue with business as usual.
- If you receive communications from the funder related to these matters, immediately pass those communications to your college Sponsored Programs Office.
- If instructed by the funder or by OSU officials to pause or cease any activities,
work with your college Sponsored Programs Office to:
- comply with those instructions as precisely as possible.
- document any quantifiable damages to OSU faculty, staff, students, or units that are directly caused by the directive and/or our compliance with it (this is to aid us in our efforts with elected officials to ameliorate this situation).
- Stay tuned in to communications from my office and your college Sponsored Programs Office as we learn more about—and share with you—how best to navigate these challenging waters.
As always, I end with an expression of my gratitude for all you do to make OSU an even greater research university. Even in these times of stress and uncertainty, you amaze me with your passion and resilient commitment to our shared mission.
In close touch,
Kenneth
____________________________
Kenneth W. Sewell, Ph.D.
Vice President for Research
Oklahoma State University
- January 28, 2025, Memo from GCFA Director Bob Dixon to OSU sponsored programs staff
All,
Several agency notices have been hitting our email, and each email seems a little different since each agency has different interpretations on what may happen.
The latest email is from OMB dated yesterday. Addressed to agency heads, OMB states that a “temporary pause related to obligation or disbursement of ALL federal assistance” is in effect as of 5 PM January 28. The memo also states that agencies must provide detailed information to OMB by February 10 on their plans to meet the new administration’s priorities on grants, loans, etc.
For past activities/expenditures—
As a point of caution for incurred costs, we are treating this pause like a government shutdown and taking the same course of action we would use during a shutdown. As such, OSU will draw any and all expenditures available/approved as of today prior to the 5 PM pause. Additionally, for the Department of Education expenditures, we are estimating potential expenditures through mid-February and including that estimation in today’s draw. We are hopeful that by mid-February, all federal payment systems will return to normal operations.
For proposals and pending awards—
OSU will continue business as usual to process/submit proposals and awards received. Please continue and submit proposals and process awards as normal. However, agencies may not move forward until things become clearer in Washington, and your points of contact may not have the answers you need. They are also unsure what will happen. Be patient. This appears as more of a short-term challenge.
For new awards and incremental funding—
The agencies have paused new awards and incremental funding agreements for the short term. Consider this before incurring costs in case the agency reduces expected funding.
Related Internal Communication—
From Dr. Sewell’s email this afternoon
“As we continue to monitor and assess the situation, here is the best advice I can offer at this juncture to those of you carrying out grant-funded projects:
Until and unless you are notified by the funder or by an OSU official to do otherwise, continue with business as usual.
If you receive communications from the funder related to these matters, immediately pass those communications to your college Sponsored Programs Office.
If instructed by the funder or by OSU officials to pause or cease any activities, work with your college Sponsored Programs Office to:
comply with those instructions as precisely as possible.
document any quantifiable damages to OSU faculty, staff, students, or units that are directly caused by the directive and/or our compliance with it (this is to aid us in our efforts with elected officials to ameliorate this situation).
Stay tuned in to communications from my office and your college Sponsored Programs Office as we learn more about—and share with you—how best to navigate these challenging waters.”Question, let me know.
Bob
Robert E. Dixon, Ed.D.
Director, Grants and Contracts Financial Administration
Oklahoma State University
401 Whitehurst
Stillwater, OK 74078
(405) 744-6512
robert.dixon@okstate.edu
Investigators with NSF funding
If you have questions about the NSF implementation of recent executive orders, you are encouraged to use the NSF online portal.
Information and Resources from the Council on Government Relations (COGR)
The Council on Government Relations (COGR), of which OSU is a member, has created a helpful resource website with all available agency memos on the presidential transition.
COGR's Links to Executive Orders and Related Resources
COGR's Summary Tracker of Executive Orders (Excel)
COGR's List of Federal Sponsor Agencies' Directives and Memoranda
COGR's Links to Relevant News Articles
COGR's Links to Other Universities' Communications on Federal Funding Updates
Information and Resources from the APLU Council on Research (COR)
The APLU's Council on Research (COR) has distributed memo to member institutions. OSU's Vice President for Research, Dr. Kenneth Sewell, is a member of COR's Executive Committee.
NIH 15% Cap on Indirect Cost Reimbursement - Information & Resources
- March 6, 2025, Memo to APLU Members: Update on NIH Litigation
Dear APLU Members,
I am pleased to share an update regarding the lawsuit in which APLU, AAU, and ACE, et. al. are plaintiffs against the National Institutes of Health (NIH) and the U.S. Department of Health and Human Services (HHS). Judge Angel Kelley of the United States District Court for the District of Massachusetts yesterday issued a preliminary injunction halting the implementation, application, or enforcement of the NIH’s February 7 supplemental guidance imposing a cap of 15% on F&A costs. The injunction applies to all institutions nationwide.
As the judge's ruling noted, "This (Rate Change) Notice impacts thousands of existing grants, totaling billions of dollars across all 50 states – a unilateral change over a weekend, without regard for on-going research and clinical trials. The imminent risk of halting life-saving clinical trials, disrupting the development of innovative medical research and treatment, and shuttering of research facilities, without regard for current patient care, warranted the issuance of a nationwide temporary restraining order to maintain the status quo, until the matter could be fully addressed before the Court."
The preliminary injunction applies in the three related cases, which are now consolidated, filed by 22 state attorneys general, the Association of American Medical Colleges, and the presidential higher education associations.
The Court found we are likely to succeed on the legal merits and that plaintiffs demonstrated irreparable harm for NIH’s action. The Court also reasoned that the balance of the equities and public interest warranted the relief it granted.
NIH and HHS may appeal the judge’s decision to the First Circuit, U.S. Court of Appeals.
We will keep you apprised of other significant developments in this case as they arise.
Mark Becker,
APLU President - February 10, 2025, Memo to APLU Members: Important APLU Action
Dear APLU Members,
As you know, on Friday, the administration declared it would cut funding for life-saving medical research effective today, February 10, 2025. Its announcement that it would limit Facilities and Administrative (F&A) reimbursements to a 15% rate for NIH research grants has an immediate and dire impact on critical biomedical and health research nationwide. It also presents an immediate and significant financial challenge for APLU’s members who rely on these promised reimbursements to carry out research on behalf of the American people.
Following NIH’s announcement, APLU quickly released a statement on Friday night explaining the consequences of this action. We have been deeply engaged with policymakers, partner associations, the media, and member institutions following the release.
Given the gravity of the situation to both the nation and our member institutions, APLU consulted with the executive committee of the Board of Directors over the weekend on this matter. After very careful consideration, APLU decided to join with the Association of American Universities (AAU) and the American Council on Education (ACE) as plaintiffs in a lawsuit challenging the action which we strongly believe to be both against the national interest and unlawful.
The complaint was just filed in the U.S. District Court of Massachusetts to seek an immediate temporary restraining order on the administration’s cut to F&A reimbursements and ultimately more permanent relief. Separate from our filing, attorneys general from 22 states filed a lawsuit earlier today in the same federal court. A judge has already granted a temporary restraining order in that case, but the relief is limited to plaintiff states. In accordance with the advice of counsel, we believe the action filed by the associations makes unique and important contributions to the legal challenges. Of note, APLU’s membership extends to all 50 states and six U.S. territories, not just the 22 states in the other complaint.
This is the first time in APLU’s history that it has served as a plaintiff in a case, let alone one against the federal government. As I am sure you can appreciate, we did not reach this decision lightly. It was only after careful consideration of how significant an impact NIH’s action is having on the nation’s medical research enterprise and APLU’s members that we felt compelled to act in partnership with peer associations.
Mark Becker,
APLU President
cc: all APLU Members
- January 29, 2025, Memo to COR Members: Rescission of OMB Memo Freezing Federal Grants
COR Community,
The Office of Management and Budget (OMB) has rescinded M-25-13, the original OMB memo from Jan 27th that called for a blanket temporary pause of federal agency grants. This rescission does not rescind any other memo or executive order, so agencies will still be reviewing existing grants for compliance with other EOs. Additionally, any previously announced agency communication pauses are still in place. We will continue to monitor the situation and provide updates as they are available.
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Kevin C. Cooke, Ph.D.
Director, Research Policy
Association of Public and Land-grant Universities (APLU)
1220 L Street NW, Suite 1000 | Washington, DC 20005
- January 28, 2025, Memo to COR Members: NSF Message to PI Community
COR Community,
NSF just shared this message (including a link to a webform) linked and copied below.
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NSF Implementation of Recent Executive Orders | NSF - National Science Foundation
Message to the NSF PI Community
Jan. 28, 2025
Office of Management and Budget (OMB) Memorandum M-25-13, issued on January 27, 2025, directs all Federal agencies to conduct a comprehensive review of their financial assistance programs to determine programs, projects, and activities that may be implicated by the recent Executive Orders. Therefore, all review panels, new awards, and all payments of funds under open awards will be paused as the agency conducts the required reviews and analysis. NSF has created an executive order implementation webpage to ensure the widest dissemination of information and updates. We will continue to communicate with you as we receive additional guidance.
All NSF grantees must comply with these Executive Orders, and any other relevant Executive Orders issued, by ceasing all non-compliant grant and award activities. Executive Orders are posted at whitehouse.gov/presidential-actions. In particular, this may include, but is not limited to conferences, trainings, workshops, considerations for staffing and participant selection, and any other grant activity that uses or promotes the use of DEIA principles and frameworks or violates Federal anti-discrimination laws. Please work with your institutional research office to assist you in complying with the Executive Orders. You can also direct your questions through this webform.
Thank you for your work advancing science, engineering, technology and innovation for our nation.
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Deborah Altenburg
Vice President, Research Policy & Advocacy
Association of Public and Land-grant Universities (APLU)
1220 L Street NW, Suite 1000 | Washington, DC 20005
- January 28, 2025, Memo to COR Members: APLU Statement on Pause on Federal Grants
COR Community,
As many of you are aware, the Office of Management and Budget (OMB) released a memo yesterday outlining a temporary pause of agency grant, loan, and other financial assistance programs. APLU's President Mark Becker has released a public statement linked and copied below.
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APLU Statement on Pause on Federal Grants - APLU
Washington, DC – APLU President Mark Becker today released the following statement on the White House Office of Management and Budget’s memo directing federal agencies to pause federal grants.
“The Office of Management and Budget memorandum ordering a temporary pause of federal grants is an overly broad mandate that is unnecessary and damaging. While we understand the Trump administration wants to review programs to ensure consistency with its priorities, it is imperative that the reviews not interfere with American innovation and competitiveness.
“This action will sideline world-leading American scientists who are working toward cures for cancer, developing breakthroughs in AI and quantum computing, driving progress in advanced manufacturing, and supporting American farmers. It will have far-reaching impacts in every corner of the country and hamper American innovation at a moment when it’s being fiercely challenged on a global stage. OMB’s action has unnecessarily injected an enormous amount of confusion and uncertainty across the nation. We urge the Trump administration to reverse this sweeping order.”
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Kevin C. Cooke, Ph.D.
Director, Research Policy
Association of Public and Land-grant Universities (APLU)
1220 L Street NW, Suite 1000 | Washington, DC 20005
- January 28, 2025, Memo to COR Members: OMB Directive Freezing Programs and Loans
COR Community,
Late yesterday, OMB released a directive to federal agencies directing a “temporary pause [on] all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders…” The freeze is effective tomorrow at 5pm ET. The freeze includes a pause on all activities “associated with open NOFOs, such as conducting merit review panels.” Agencies are further instructed to among other actions, cancel awards already awarded that are in conflict with Administration priorities. During the “temporary pause,” agencies are instructed to complete a comprehensive analysis of their programs and identify those that maybe be implicated by President Trump’s executive orders, reporting such to OMB by February 10. The directive does not apply to federal assistance provided directly to individuals.
In short, as described in this Washington Post headline, “White House pauses all federal grants, sparking confusion.”
White House pauses all federal grants, sparking confusion - The Washington PostI have heard that many agencies are having meetings this morning about the OMB memo and we are hopeful that further guidance on the treatment of existing grants will be forthcoming. We will share information as it becomes available.
Also as a community resource if anyone has not seen this – COGR has put together a good resource with all available agency memos on the presidential transition. https://www.cogr.edu/2025-administration-transition-information-resources
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Deborah Altenburg
Vice President, Research Policy & Advocacy
Association of Public and Land-grant Universities (APLU)
1220 L Street NW, Suite 1000 | Washington, DC 20005