CASRAI Dictionary

Author: MCP Service

  • Grants Functional Standard: What UK Funders and Institutions Need to Know

    What Is the Grants Functional Standard (GovS 015)?

    The Grants Functional Standard — Government Functional Standard GovS 015: Grants — is the Cabinet Office document that sets mandatory expectations for how UK central government departments and their arm’s-length bodies (ALBs) design, award, monitor and close out grants. First published in December 2016 and periodically updated since, it applies to any organisation administering grants wholly or partly using Exchequer funding, which in practice includes many universities, research charities, learned societies and sector bodies that receive or pass through public grant money.

    The standard operates on a “comply or explain” basis: bodies within scope must either meet the ten Minimum Requirements or record a documented justification for departing from them. It sits alongside the wider suite of UK government functional standards (covering areas such as finance, commercial and project delivery), which exist to give civil servants and delivery partners a consistent, shared language for governance and assurance.

    The Ten Minimum Requirements

    GovS 015 is operationalised through ten numbered Minimum Requirements, each with its own supporting guidance document published by the Government Grants Management Function (GGMF). Together they cover the full grant lifecycle, from senior accountability through to reconciliation and training.

    Minimum Requirement Focus area
    1. Senior Officer Responsible for a Grant Named senior accountability for each grant scheme
    2. Governance, Approvals & Data Capture Sign-off routes and central grant-data recording
    3. Complex Grants Advice Panel (CGAP) Mandatory referral for high-risk or priority schemes
    4. Business Case Development Rationale, options appraisal and value for money
    5. Competition for Funding Fair, open, proportionate award processes
    6. Grant Agreements Terms, conditions and use of the Model Grant Agreement
    7. Risk, Controls and Assurance Fraud risk, security risk and internal controls
    8. Performance and Monitoring In-year tracking of delivery against milestones
    9. Annual Review and Reconciliation Year-end financial and delivery reconciliation
    10. Training Competency requirements for grant-making staff

    Minimum Requirement 7 — Risk, Controls and Assurance — is the section research administrators should watch most closely, because it is the one most recently amended.

    What Changed in the 21 May 2026 Update

    On 21 May 2026, the Cabinet Office published a revised version of Minimum Requirement 7: Risk, Controls and Assurance. Two substantive changes were made:

    • The language governing Fraud Risk Assessments was strengthened, tightening the expectation that grant-making bodies produce and evidence a documented fraud risk assessment as part of the standard’s risk-management requirements.
    • A new paragraph (paragraph 23) was added to provide further guidance on security risk, extending the section’s scope beyond financial and delivery risk to explicitly cover security considerations in grant-funded activity.

    This update did not change the ten-requirement structure of GovS 015 itself; it refined the assurance expectations sitting underneath Minimum Requirement 7. It follows a pattern of incremental, dated revisions the GGMF has made to individual Minimum Requirement documents over recent years — CGAP referral criteria and the Grant Agreements guidance have both been revised on a similar rolling basis. For any body already running a Grants Continuous Improvement Assessment against the standard, the May 2026 wording is the version that self-assessment evidence should now reference.

    Grant Administration, Grant Management and the Centre of Excellence

    GovS 015 sits inside a broader UK government grants ecosystem, and the terminology is often used loosely. It is worth distinguishing the parts precisely, since institutions applying the standard need to know which body owns which function.

    • Grant administration refers to the operational, transactional tasks of running a grant scheme — issuing agreements, processing claims, recording data and reconciling payments.
    • Grant management is the broader discipline: strategic design of a scheme, risk appraisal, performance oversight and continuous improvement, of which administration is one component.
    • The Government Grants Management Function (GGMF) is the cross-government function, hosted by the Cabinet Office, responsible for GovS 015 itself and for coordinating grant-making practice across departments and ALBs.
    • The Grants Centre of Excellence is the operational and advisory capability that supports departments in applying the standard consistently — providing guidance, training and shared services rather than setting the standard itself.

    What is the functional standard for grants?

    It is Government Functional Standard GovS 015, the Cabinet Office document setting mandatory requirements for how UK departments and arm’s-length bodies administer grants funded wholly or partly through the Exchequer. It exists to ensure consistency, regularity and propriety in grant-making and to promote value for money in publicly funded grant schemes.

    What are UK government functional standards?

    Functional standards are Cabinet Office-issued documents that set mandatory (“shall”) and advisory (“should”) expectations for specific government functions — finance, commercial, project delivery and grants among them. They use a shared glossary so departments and their delivery partners work to a common, auditable set of definitions and controls.

    What is the difference between grant administration and grant management?

    Grant administration is the transactional layer — agreements, claims, payments and record-keeping. Grant management is the wider strategic discipline covering scheme design, risk assessment, performance monitoring and continuous improvement, within which administration operates as one supporting activity, not a synonym for the whole function.

    What is the Grants Centre of Excellence?

    It is the cross-government advisory and capability-building resource that helps departments and arm’s-length bodies apply GovS 015 in practice, through guidance, training and shared tools. It supports implementation of the standard; it does not itself author or amend the Minimum Requirements, which remain the responsibility of the Government Grants Management Function.

    Implications for Research-Funded Institutions

    Universities, research charities and sector bodies that receive Exchequer-funded grants — directly from departments or via an ALB — sit within scope of GovS 015 even when they are not themselves a government department. The May 2026 changes to Minimum Requirement 7 have practical consequences for research administration teams:

    • Grant applications and renewals may face closer scrutiny of documented fraud risk assessments, particularly for schemes flagged as complex or high-value.
    • Institutions handling sensitive research areas — dual-use technology, critical infrastructure, or international collaboration — should expect funders to reference the new security-risk paragraph when setting due-diligence conditions.
    • Research offices that already map their processes against Minimum Requirements 1–10 for continuous-improvement self-assessment should update their MR7 evidence base to the 21 May 2026 wording.
    • Grant agreement templates and internal risk registers referencing MR7 should be checked against the current guidance rather than an earlier cached version, since the GGMF revises individual Minimum Requirement documents on a rolling basis rather than reissuing the whole standard.

    None of this changes the fundamentals of good research administration practice — due diligence, documented risk assessment and clear accountability were already core expectations. What changes is the explicitness with which fraud and security risk must now be evidenced under MR7.

    Looking Ahead

    GovS 015 has been revised incrementally rather than replaced outright since 2016, and the pattern is likely to continue: individual Minimum Requirement documents updated as risks evolve, rather than a full standard rewrite. Institutions that treat the standard as a living compliance baseline — checking dated guidance documents against their internal risk frameworks at each award cycle — will be better placed than those that rely on a static PDF saved years ago. For research administrators, the practical takeaway from the 21 May 2026 update is straightforward: fraud risk assessment and security-risk screening are no longer implicit good practice under GovS 015 — they are explicit, documented expectations under Minimum Requirement 7.

  • Research Funding Cuts in the UK: How Exposed Are Institutions to US Policy Shifts?

    British universities have spent 2026 absorbing two funding shocks at once. At home, UK Research and Innovation (UKRI) is mid-way through the biggest restructuring of its funding model since the body was created in 2017. Abroad, the US administration’s proposed reductions to federal science budgets have destabilised grant pipelines that many UK research groups quietly depend on. Research funding cuts in the UK are no longer a purely domestic story — they are increasingly a function of decisions taken in Washington, and institutions that have not mapped their transatlantic exposure are flying blind into 2027 planning cycles.

    The transatlantic funding shock: what changed in 2026

    On the UK side, the Department for Science, Innovation and Technology and UKRI confirmed in late 2025 how £38.6 billion of public R&D funding would be distributed over the following four years. The overall UKRI budget is set to rise towards £10 billion a year by 2030, but the distribution model has shifted to three “funding buckets”: curiosity-driven research, strategic government and societal priorities, and support for innovative companies — each intended to represent roughly half, a quarter and a quarter of spend respectively.

    That restructuring has not been smooth. In early 2026, three research councils — the Medical Research Council, the Biotechnology and Biological Sciences Research Council, and the Engineering and Physical Sciences Research Council — paused active grant routes. The Science and Technology Facilities Council separately confirmed it must find £162 million in cost reductions by 2029–30, driven by rising energy costs and unfavourable currency exchange rates, forcing project leaders to model cuts of 20%, 40% and even 60% to national facilities, particle physics and astronomy programmes. The House of Commons Science, Innovation and Technology Committee has since pressed UKRI’s chief executive for clearer, comparable data on the allocation changes.

    On the US side, the picture is starker still. The Association of American Universities has tracked administration proposals to cut federal research funding by 22% overall and basic research by 34% in a single fiscal year, with the Brennan Center for Justice estimating Congress was asked to strip an additional $44 billion from scientific research. The Center for American Progress estimates that National Institutes of Health (NIH) and National Science Foundation (NSF) cuts alone could cost the US economy $10–16 billion annually. Grant holds affecting Harvard and other institutions persisted well into 2026, with the NSF only lifting some holds in late May after sustained press scrutiny.

    How exposed are UK institutions to US funding shifts?

    The US is the UK’s single largest research collaborator by volume of co-authored output, and that collaboration runs through several distinct funding channels — each with a different risk profile. Institutions that treat “US exposure” as a single number miss where the real fragility sits.

    Exposure channel What is at risk 2026 signal UK mitigation lever
    Direct US federal co-funding Joint grants and sub-awards linked to NIH/NSF cycles NSF grant holds affecting Harvard and peer institutions persisted into May 2026 UKRI’s bucket reform reduces reliance on any single funding stream
    US philanthropic and foundation funding Foundation grants sensitive to the wider US fiscal and political climate US philanthropic sector under pressure to backfill federal shortfalls UK trusts, Horizon Europe association, and international co-funding
    Industry and corporate R&D partnerships Private R&D spend that tracks federal grant cycles US firms reassessing R&D allocation amid budget uncertainty UK government talent and relocation schemes attracting redirected private investment
    Talent pipeline Researchers on US-funded fellowships or joint appointments Early-career researchers facing contract non-renewal in the US UK schemes offering relocation funding for research teams

    Institutions with heavy involvement in biomedical, physics or environmental science co-funding arrangements are typically the most exposed, since these fields have historically carried the largest NIH and NSF footprints in joint UK-US work. Smaller specialist units embedded in a single US-funded programme carry proportionally more risk than large, diversified research portfolios — a distinction that should inform any institutional risk register.

    Answer-first: what researchers and administrators are asking

    Did research funding get cut?

    Yes, on both sides of the Atlantic. The UK’s Science and Technology Facilities Council confirmed £162 million in cost reductions by 2029–30, and three UKRI councils paused grant routes in early 2026. In the US, the administration proposed cutting overall federal research funding by 22% and basic research by 34% in a single fiscal year.

    Are universities getting less funding?

    Universities UK estimates that government policy decisions will reduce funding to English higher education providers by roughly £3.7 billion between 2024–25 and 2029–30. Combined with flat UKRI settlements and paused grant schemes, most English research-intensive institutions face a genuinely tighter funding environment than in the previous spending review period.

    Which UK universities are in financial trouble in 2026?

    The Office for Students has repeatedly flagged a growing minority of English providers running operating deficits, driven by falling international student income, domestic fee stagnation, and rising costs. This is a distinct pressure from research-specific council cuts, but the two compound: institutions under financial strain have less capacity to cushion research funding shocks internally.

    Why did Harvard get funding cut?

    Harvard University was among several US institutions to have NIH and NSF grants held or paused amid federal disputes over campus policy compliance. The NSF lifted some of these holds in May 2026 following media inquiries, but the episode illustrates how US federal research funding can be withdrawn on non-scientific grounds — a governance risk UK partners inherit indirectly through joint grants.

    UKRI’s own reforms as a partial buffer

    UKRI’s shift to a three-bucket funding model is contested — the Campaign for Science and Engineering has pushed UKRI for clearer year-on-year comparability, and the reform has coincided with disruptive grant pauses. But structurally, it offers UK institutions something the pre-2025 model did not: an explicit, published split between curiosity-driven research, strategic priorities, and innovation support, rather than allocation by historical research-council silos alone.

    • A published macro-level split (roughly 50% curiosity-led, 25% strategic priorities, 25% innovative companies) gives institutions a clearer basis for forecasting than opaque, council-by-council settlements.
    • UKRI has committed to providing high-level historical mapping so institutions can benchmark the new buckets against prior allocations.
    • The overall UKRI budget trajectory — rising toward £10 billion a year by 2030 — provides a growing (if unevenly distributed) domestic base that partially offsets US-side volatility, provided institutions position themselves across more than one bucket.

    None of this eliminates the pain of near-term grant pauses. But a funding architecture built around explicit strategic categories is inherently easier to diversify across than one built purely on discipline-specific council budgets — which is precisely the structural weakness that has made STFC-funded physics and astronomy groups disproportionately exposed to the current cuts.

    The case for diversification

    The practical lesson for institutional leaders is not to retreat from US collaboration — the scientific and reputational value of transatlantic partnerships remains real — but to stop treating single-source dependency as a manageable risk. UK government initiatives, including relocation-funded schemes aimed at researchers whose US positions have become uncertain, are a useful signal of where institutional and national strategy are converging, but they do not substitute for individual institutions actively rebalancing their own portfolios.

    • Map grant portfolios by funding channel (federal co-funding, philanthropic, industry, talent) rather than by discipline alone, so exposure is visible at the funding-source level, not just the subject level.
    • Treat Horizon Europe association and other multilateral schemes as genuine substitutes for at-risk US federal streams, not merely as supplementary income.
    • Build philanthropic and industry diversification into research strategy documents explicitly — the approach several research-intensive universities, including Cambridge, have already formalised.
    • Use grants management functions to track funder-level concentration risk as a standing item in institutional risk registers, not an ad hoc exercise triggered only after a funding shock.

    What this means for research administrators

    For research administration teams, the near-term task is unglamorous but essential: build an accurate, funder-level map of institutional exposure before the next funding cycle, not after it. That means treating grants management as a strategic function that sits alongside — not beneath — research strategy, with clear visibility into which grants, fellowships and facility partnerships sit on which side of the Atlantic.

    Longer term, the institutions that weather 2026’s funding turbulence best will likely be those that used UKRI’s bucket reform as an opportunity to rebalance rather than a bureaucratic inconvenience to endure. Diversification is not a hedge against any single government’s budget decisions — it is increasingly the baseline condition for research resilience.

    CASRAI’s work on the research administration function, including standards for describing contributor roles and institutional research infrastructure, sits alongside this diversification agenda — see the research administration resources, and browse funding and grants terminology in the CASRAI Dictionary.

  • University Research Funding Cuts: What the Court Cases Mean for Grant Recipients

    University research funding cuts have moved from budget-line disputes into federal courtrooms. Since April 2025, Harvard, Columbia and coalitions of state attorneys general have filed parallel legal challenges against the National Institutes of Health (NIH) and National Science Foundation (NSF) over grant terminations, funding freezes and new indirect-cost caps. The cases differ in posture — one produced a court ruling, one produced a settlement, others remain active — but together they are setting the procedural rules that will govern how frozen, denied or withdrawn grants get reviewed for years to come.

    For research offices, the practical question is no longer whether litigation is happening but what it is actually requiring agencies and institutions to do while cases proceed. This analysis sets out the pattern, compares the major tracks, and lists what sponsored-programs and general counsel offices should be monitoring now.

    The pattern: why universities are suing over federal funding

    Beginning in early 2025, the administration froze, terminated or delayed thousands of federal research awards to universities, citing diversity, equity and inclusion (DEI) content, alleged civil-rights failures, or new indirect-cost policy. According to a mapping analysis by the Center for American Progress, more than 4,000 grants across over 600 institutions were targeted for termination, with claimed award values between roughly $6.9 billion and $8.2 billion.

    Universities and state attorneys general responded with a consistent legal theory: that agencies violated the Administrative Procedure Act (APA) by acting in an “arbitrary and capricious” manner, skipping required notice-and-comment procedures, or exceeding authority Congress had granted them. In several cases, plaintiffs also raised First Amendment retaliation claims, arguing that funding was cut in response to institutional speech or governance decisions rather than for programmatic reasons.

    • Institutional suits — Harvard sued the federal government directly over a frozen $2.2 billion in grants and contracts.
    • Negotiated settlements — Columbia resolved its dispute through a financial and compliance agreement rather than litigating to judgment.
    • Multi-state actions — coalitions of state attorneys general sued NIH and NSF separately, challenging both DEI-related terminations and the NSF’s 15% indirect-cost cap.

    Harvard, Columbia and the multi-state track record

    The three tracks have produced different outcomes, which matters for institutions trying to predict what a given legal strategy is likely to achieve.

    Track Funding at stake Legal basis Outcome so far
    Harvard v. federal government ~$2.2 billion frozen (April 2025) APA “arbitrary and capricious”; First Amendment retaliation District court ruled the cuts unlawful (September 2025); the Department of Justice subsequently sued Harvard (March 2026) seeking to recoup funds and contest the ruling
    Columbia University ~$400 million cut (March 2025) Civil-rights compliance dispute; no APA suit litigated to judgment Settled for $221 million (July 2025) — $200 million civil-rights, $21 million employment claims; ~$400 million in research funding reinstated; increased federal oversight and reporting requirements
    Multi-state AGs v. NIH Hundreds of grants (DEI, transgender health, vaccine-hesitancy research) APA violations; exceeded statutory authority Settlement committed NIH to its “usual process” for grant review; a court separately ruled roughly 900 terminated grants unlawful and ordered reinstatement, though the administration has appealed
    Multi-state AGs (16 states) v. NSF STEM diversity programmes; 15% indirect-cost cap APA and constitutional claims regarding congressional intent Litigation ongoing; plaintiffs are seeking to block the indirect-cost cap and reverse related terminations

    Harvard’s case is the clearest judicial precedent to date: a U.S. District Court in Boston found the government’s cancellation unlawful and ordered funding restored, only for the Department of Justice to open a separate recoupment suit months later — a reminder that a favourable ruling does not end the underlying dispute. Columbia’s settlement, by contrast, traded a fixed financial payment and expanded oversight for the reinstatement of frozen funds without a court ruling on the merits.

    What the settlements and court orders have required so far

    Three concrete procedural requirements have emerged from this litigation, and they matter more to research administrators than the headline dollar figures:

    • NIH’s court-ordered grant review. Following the ruling that roughly 900 terminated grants were unlawfully cancelled, NIH was ordered to reinstate them and, in a related settlement, committed to returning to its “usual process” for reviewing applications rather than applying ad hoc political criteria.
    • Reinstatement is not automatic. Reporting has repeatedly noted that court-ordered reinstatements are not occurring uniformly across all affected grants or states, and that the administration has filed appeals that keep some awards in limbo even after a favourable ruling.
    • Settlements bundle funding with oversight. Columbia’s agreement did not simply restore money; it added federal reporting obligations on admissions and international-student data and required adoption of the IHRA definition of antisemitism — a template that later negotiations may echo.

    None of this activity has produced a single, uniform national standard. Each institution’s relief depends on its specific docket, its circuit, and whether it litigated to judgment or settled.

    Frequently asked questions

    Why did Harvard get its research funding cut?

    The administration froze roughly $2.2 billion in Harvard grants and contracts in April 2025, citing the university’s response to campus antisemitism concerns and its refusal to comply with a set of governance demands. Harvard sued, arguing the freeze violated the Administrative Procedure Act and the First Amendment.

    Why is Columbia University losing funding?

    Columbia had roughly $400 million in federal grants terminated in March 2025 over alleged civil-rights compliance failures related to campus antisemitism. Rather than litigate, Columbia negotiated a $221 million settlement in July 2025 that restored most of the frozen research funding in exchange for expanded federal oversight.

    Was terminated NIH research funding actually reinstated?

    Partially. A court ordered roughly 900 NIH grants reinstated after finding their termination unlawful, but subsequent reporting found reinstatement was inconsistent across institutions and states, and the administration has appealed the underlying ruling, leaving some awards unresolved.

    What should a research office track during active litigation?

    Research offices should track award status changes, agency guidance updates, court docket entries affecting their sponsors, and internal expenditure and indirect-cost documentation — the same records needed both for compliance and for supporting institutional legal counsel if a grant is challenged.

    What research offices should track while litigation is pending

    Regardless of whether an institution is a named party, sponsored-programs and research-administration offices with active NIH or NSF awards should maintain contemporaneous records across five areas:

    • Correspondence with program officers — emails, termination or stop-work notices, and summaries of calls, since these documents establish the factual record if an award is later challenged.
    • Award terms and modifications — particularly termination, suspension and indirect-cost clauses, which vary by grant vintage and mechanism.
    • Expenditure and indirect-cost documentation — detailed enough to substantiate negotiated facilities-and-administrative rates if a cap or clawback is contested.
    • Docket activity relevant to the sponsoring agency — court orders, appeals and settlement terms that could reinstate, further freeze, or attach new conditions to an award.
    • Contingency and bridge-funding plans — since even a favourable ruling can take months to translate into disbursed funds, as Harvard and NIH grantees have both experienced.

    Institutions should also coordinate closely with general counsel before responding to any new agency demand tied to a settlement template, since Columbia’s agreement shows that funding restoration can come bundled with reporting and governance conditions extending well beyond the original grants at issue.

    Implications and what comes next

    The litigation pattern suggests two durable lessons for institutional research offices. First, a court ruling in an institution’s favour does not guarantee funds will flow on the original schedule — reinstatement has proven uneven, and follow-on actions such as the Department of Justice’s suit against Harvard show that disputes can continue well after an initial win. Second, settlement and litigation are not mutually exclusive strategies within a single funding relationship: an institution can win a ruling on one set of terminated NIH awards while separately negotiating conditions with another agency, or facing new litigation over the same funds.

    For offices managing sponsored research and research administration more broadly, the operational takeaway is procedural discipline rather than prediction. Consult the CASRAI Dictionary for definitions of the compliance and funding terms surfacing in this litigation, and treat every termination notice, court order and settlement condition as part of a single evidentiary record — because in this funding environment, that record is what any given grant’s outcome will ultimately turn on.

  • mRNA Research Funding Cuts: Tracking the Institutional Fallout

    The 2026 research-funding landscape has a new, narrower fault line: mRNA research funding cuts tied specifically to the messenger-RNA vaccine platform, distinct from the broader reductions affecting cancer and biomedical research generally. On 5 August 2025, the US Department of Health and Human Services (HHS), under Secretary Robert F. Kennedy Jr., announced it was winding down mRNA vaccine development activities administered through the Biomedical Advanced Research and Development Authority (BARDA), terminating or restructuring 22 contracts worth nearly $500 million. Nearly a year on, the institutional fallout is now measurable, and research offices are adjusting their portfolios in response.

    What changed: HHS and BARDA’s mRNA wind-down

    The August 2025 announcement marked a deliberate shift in federal biomedical strategy: HHS stated it would move BARDA’s pandemic-preparedness investment away from mRNA platforms for respiratory viruses and toward what officials described as “safer, broader vaccine platforms.” The decision followed an earlier, separate cancellation of a roughly $600 million Moderna contract for a pandemic influenza mRNA vaccine in May 2025 — a move HHS and Moderna both describe as distinct from the August action, though the two together set the tone for the year’s mRNA-specific retrenchment.

    The August wind-down did not apply uniformly. According to contract-level reporting from HHS and trade press, the 22 affected awards fell into four categories:

    • Terminated contracts — awards cancelled outright, ending federal support for the specific project.
    • De-scoped work — existing contracts kept alive but with mRNA-specific tasks removed or reduced.
    • Rejected or withdrawn solicitations — proposals for new mRNA work that were declined before an award was made.
    • Restructured collaborations — joint projects renegotiated to change or remove the RNA component.

    Nature’s editorial board called the cancellations “the highest irresponsibility,” noting that a related executive order gives political appointees expanded authority over federal research-grant decisions — a governance change research offices should track independently of the funding total itself, since it affects how future awards in adjacent fields may be reviewed.

    Which institutions and companies have reported losses

    Public reporting to date identifies a specific set of universities, biotechs and pharmaceutical partners affected by the BARDA wind-down, each experiencing a different type of impact:

    Organisation Type of impact Project area
    Emory University Contract terminated Inhaled dry-powder mRNA antiviral platform
    Tiba Biotech Contract terminated RNA interference (RNAi) therapeutic — company disputes classification as an mRNA vaccine project
    Luminary Labs, ModeX, Seqirus Scope reduced mRNA-related tasks removed from existing BARDA agreements
    Pfizer, Sanofi Pasteur, CSL Seqirus, Gritstone Proposal rejected New mRNA-related solicitations declined pre-award
    AAHI, AstraZeneca, HDT Bio, Moderna/UTMB Collaboration restructured Nucleic-acid vaccine partnerships renegotiated

    Emory’s public statement was measured — a spokesperson said the university would “adjust as needed to pursue our research goals and ambitions” — but a lead researcher on the inhaled-platform project told local press the cuts risk signalling that mRNA is no longer a viable federal research priority, a concern echoed across the affected cohort.

    The scale of what is at stake extends well beyond the 22 terminated awards. A cross-sectional study published in JAMA Network Open, led by a team including researchers at Northwestern University and the University of Virginia, catalogued 178 active NIH grants related to RNA vaccines awarded between 1997 and 2025, representing $1.65 billion in cumulative federal investment. Those grants produced 2,342 publications and nearly 150,000 citations; 35% were cited in clinical trials or practice guidelines, and 18 were awarded through the Small Business Innovation Research and Small Business Technology Transfer programmes — the mechanism many university spinouts rely on to commercialise federally funded research. An accompanying commentary from researchers at the University of Calgary and University of Saskatchewan warned that excising RNA vaccine research from the NIH portfolio “is antithetical to current goals of making America healthy,” and separately noted that current-season flu vaccines are poorly matched to circulating strains — an argument for, not against, continued RNA platform investment.

    A Yale School of Public Health report has separately warned of downstream health consequences from the funding cancellation, and the American Lung Association and Harvard T.H. Chan School of Public Health have both published concern statements specifically about the loss of mRNA vaccine development capacity for respiratory disease.

    Common questions on the mRNA funding rollback

    Is the Moderna contract cancelled?

    Two separate Moderna contracts were affected. HHS cancelled a roughly $600 million bird-flu mRNA vaccine contract in May 2025, and Moderna’s collaboration with the University of Texas Medical Branch was restructured — not fully terminated — as part of the August 2025 BARDA wind-down.

    Why did the FDA reject Moderna’s mRNA flu vaccine application?

    The FDA said it refused to review Moderna’s mRNA flu vaccine filing because the company had not tested the product against a CDC-recommended comparator vaccine in a head-to-head clinical trial, as agency guidance issued in 2024 required — a regulatory, not funding, decision that compounds the platform’s commercial headwinds.

    How research offices are hedging portfolio risk

    Institutional research offices with active or pending mRNA-related awards are responding in broadly consistent ways, even where individual contract outcomes differ:

    • Diversifying platform exposure — reframing single-platform mRNA proposals as multi-modal nucleic-acid or protein-subunit programmes to reduce reliance on one federal funding line.
    • Pursuing non-federal co-funding — several affected groups, including Tiba Biotech, have publicly stated intent to pursue philanthropic, state-level, or industry funding to continue work federal contracts previously covered.
    • Auditing award language for termination clauses — sponsored-programmes offices are reviewing existing BARDA and NIH awards for early-termination-for-convenience language, which was the operative mechanism in several August 2025 cancellations.
    • Separating cancer-mRNA and infectious-disease-mRNA portfolios — because the HHS wind-down targeted respiratory-virus vaccine platforms specifically, institutions with mRNA cancer-vaccine work are treating that portfolio as distinct in risk profile, even though it uses overlapping delivery technology.

    For research administration offices, this is a live case study in sponsor-concentration risk — the same principle that underpins diversified grant portfolios more broadly. Institutions tracking these developments alongside broader shifts in research administration practice are better positioned to model exposure across single-sponsor dependencies before the next policy shift, rather than after.

    Outlook: what research administrators should track next

    The mRNA-specific rollback is narrower than the broader federal research-funding contraction affecting NIH and cancer research overall, but its concentration in a single platform and a single agency relationship (HHS/BARDA) makes it a useful, contained case study in how quickly a funding line can be repriced on policy grounds rather than scientific merit. Three signals are worth monitoring going into the next budget cycle: whether the executive order expanding political appointee authority over grant decisions is applied beyond mRNA to other platforms; whether the $1.65 billion NIH RNA-vaccine grant base identified in the JAMA Network Open study sees further reductions at renewal; and whether affected institutions successfully replace lost BARDA funding with non-federal sources, which would signal a durable shift in how pandemic-preparedness research is financed. Research offices with mRNA-adjacent portfolios should treat this episode as a template for stress-testing single-sponsor concentration risk across all federally funded platforms, not just this one.

  • Cancer Research Funding Cuts: What the 2026 NIH Data Shows

    Search interest in cancer research funding cuts has spiked through the first half of 2026, tracking a wave of NIH award terminations, a proposed 37% cut to the National Cancer Institute’s budget, and a roughly $500 million rollback of federal mRNA vaccine research contracts. For research administrators, the practical question is no longer whether the funding landscape has shifted — it clearly has — but how exposed a given portfolio is, and what a grants office can do about it before the next termination notice arrives.

    What the 2026 NIH Funding-Cut Data Shows

    HHS reporting released in April 2026 puts the cumulative tally of terminated National Institutes of Health awards at 1,392, with $539 million in unliquidated obligations still outstanding — funds that were committed but not yet disbursed when the terminations took effect. That figure sits alongside an earlier, broader accounting: a PubMed Central analysis found that by June 2025, roughly 2,300 NIH grants worth nearly $3.8 billion had already been cancelled agency-wide, including more than 160 cancer-related clinical trials.

    The cuts are not evenly distributed across the calendar. A May 2025 US Senate HELP Committee Minority Staff report found the administration cut approximately $2.7 billion in NIH funding during the first three months of 2025 alone, with cancer-specific research funding down 31% for that quarter compared with the same period in 2024. On the budget side, the National Cancer Institute’s own FY2026 congressional justification requested $4.53 billion — a $2.69 billion, or 37.3%, reduction from its FY2025 level of $7.22 billion.

    • Indirect cost cap: facilities-and-administrative (F&A) reimbursement rates on NIH grants have been capped at 15%, cutting into the overhead that funds shared cores, compliance staff, and research infrastructure at host institutions.
    • mRNA-specific rollback: HHS cancelled roughly $500 million in mRNA vaccine and therapeutics research contracts during 2025, with direct knock-on effects for mRNA-based cancer immunotherapy pipelines.
    • Review bottlenecks: reporting in early 2026 described new layers of administrative review delaying disbursement of already-approved grants, with some applications flagged for specific terminology before release.

    Which Disease Areas and Grant Types Are Most Exposed

    Exposure is not uniform across tumour types. A 2025 analysis of NIH and Congressionally Directed Medical Research Programs (CDMRP) funding from 2013 to 2022, presented at the Journal of Clinical Oncology, found that funding levels correlate strongly with disease incidence (Pearson coefficient 0.85) but only weakly with mortality (Pearson coefficient 0.36) — meaning historically under-funded, high-mortality cancers have the least financial cushion to absorb further cuts.

    Cancer type Combined NIH + CDMRP funding, 2013–2022 Relative funding position
    Breast $8.36 billion Highest-funded
    Lung $3.83 billion Well-funded
    Prostate $3.61 billion Well-funded
    Hepatobiliary $1.13 billion Under-funded vs. mortality burden
    Cervical $1.12 billion Under-funded vs. mortality burden
    Uterine $435 million Lowest-funded

    Grant type matters as much as disease area. Early-stage-investigator R01s, K-series career development awards, and T32 institutional training grants have been disproportionately represented among terminations, largely because diversity, equity, and inclusion-linked language in aims or personnel sections triggered policy-based review flags. Multi-year, non-competing renewals and diversity supplement awards have also recurred repeatedly in termination letters reviewed by health-policy reporters. Large P30 cancer-centre support grants are separately exposed through the F&A cap, since their budgets rely heavily on indirect-cost recovery to fund shared facilities.

    Answer-First Q&A: Cancer Research Funding Cuts

    Why is NIH cutting cancer research funding?

    The terminations stem from a mix of executive-branch policy priorities — including the rollback of diversity, equity, and inclusion-linked research — and proposed budget reductions for FY2026 and FY2027. Congress has historically restored some NIH funding after similar proposals, but administrative terminations of already-awarded grants have proceeded independently of the appropriations process.

    How much cancer research funding has been cut?

    By April 2026, HHS reporting recorded 1,392 terminated NIH awards with $539 million in unliquidated obligations. Separately, cancer-specific funding fell 31% in the first quarter of 2025 versus the prior year, and the National Cancer Institute’s FY2026 budget request represents a 37.3% reduction from its FY2025 level.

    Which cancer types are most affected by funding cuts?

    Historically under-funded cancers with high mortality — including uterine, cervical, and hepatobiliary cancers — have the least buffer to absorb cuts, since funding has tracked incidence rather than mortality. Early-career researchers and training-grant recipients across all disease areas are also disproportionately exposed.

    What Grants Offices Can Do Now

    None of this is speculative risk anymore — it is portfolio management. Institutions with active NIH-funded cancer research should treat funding volatility as a standing operational condition rather than a one-off shock, and research administration offices should build response capacity accordingly.

    • Bridge funding: establish or expand an internal bridge-fund mechanism, paired with external bridge grants from bodies such as the American Association for Cancer Research and the American Cancer Society, to keep terminated projects and personnel intact for six to twelve months while alternative funding is secured.
    • Appeals and documentation: maintain a standing file of scientific-merit documentation for every active award so a formal reconsideration request — or, where warranted, legal challenge — can be filed quickly; several 2025 terminations were reversed after litigation established that cancellations lacked adequate scientific justification.
    • Diversified funder mix: reduce single-funder concentration risk by cultivating relationships with disease-specific foundations (for example, the V Foundation and Damon Runyon Cancer Research Foundation), state-level programmes such as Texas’s CPRIT, and international co-funding arrangements, rather than relying on NIH as the sole primary sponsor for a given research line.
    • F&A exposure modelling: run budget scenarios against the 15% indirect-cost cap now, before it applies at renewal, so cancer-centre and core-facility budgets are not caught unprepared.
    • Track funding-notice guidance: assign a named staff member to monitor NIH Notice of Funding Opportunity and Guide Notices for terminology or eligibility changes that could flag active or pending applications for review.

    Professional associations — including ARMA, NCURA, and INORMS — have begun circulating shared templates and peer intelligence on termination response, and grants offices that pool this knowledge across institutions are responding faster than those working in isolation. As the FY2027 budget cycle approaches, with a further proposed reduction to overall NIH funding under discussion in Congress, the institutions best placed to protect their cancer research portfolios will be those that treated 2025’s cuts as a stress test rather than a one-time event — and built the bridge-funding, appeals, and diversification infrastructure needed to withstand the next round.

  • Peer Review of Grant Proposals Under Political Pressure: The Case for Independence

    A funding notice should be a statement of scientific priority, not a political signal. Yet across 2025 and into 2026, the machinery that has historically separated the two — peer review grant proposals through panels of independent subject-matter experts — has come under direct pressure from proposals that would let political appointees override merit-based funding recommendations. This is an argument, not a survey: politicised screening of grant notices does not just change who gets funded, it erodes the evidentiary basis on which the public is asked to trust science at all.

    Why Independent Peer Review Underpins Public Trust

    Grant peer review exists to answer one narrow question: is this proposal, on scientific merit, worth public money? Reviewers assess feasibility, methodological rigour, and the track record of the team, insulated as far as possible from who is asking or why. UK Research and Innovation’s guidance for its research councils is explicit about this insulation: proposals go to at least three independent reviewers, comments are handled in confidence, and funders are told not to substitute journal-based metrics or reputation for direct scientific judgement, in line with the San Francisco Declaration on Research Assessment (DORA).

    That model works because it is boring by design. Merit review is meant to be the least newsworthy part of the research funding cycle — a quiet, expert, reproducible filter. When it becomes contested political territory, the filter itself becomes a variable, and every downstream claim about “the best science being funded” loses its footing.

    The 2026 Pressure Points: Political Override and Funding Cuts

    Two developments in the United States illustrate the risk. First, a proposed rule from the White House Office of Management and Budget would give political appointees at federal agencies final authority over grant funding decisions, including the ability to terminate active awards that no longer align with stated “agency priorities” or the “national interest” — language broad enough to reach almost any politically contested field, from climate science to public health. Second, budget proposals affecting the National Institutes of Health and National Science Foundation, alongside a reported NIH plan to consolidate its institutes and centres and restructure study-section peer review, have combined to shrink the pool of fundable awards even as application volume holds steady or rises.

    Neither development is hypothetical process detail. Together they change what a grant notice signals: not “this call is open to the best proposal” but “this call is open to the best proposal that also survives a discretionary political filter after review.” The Association of American Universities and multiple scientific societies have flagged this combination as a structural threat to the research enterprise, not a routine administrative reform.

    The comparison with the UK’s model is instructive, not because either system is beyond criticism, but because it shows what an evidentiary firewall between political priority-setting and technical merit assessment actually looks like in practice:

    Safeguard UKRI research council practice US 2026 OMB proposal risk
    Reviewer independence Minimum three reviewers, including one nominated by the applicant Political appointees can override expert panel recommendations
    Confidentiality Proposals handled “in confidence”; reviewer identities protected until decision No published equivalent confidentiality standard cited in the proposal
    Assessment criteria DORA-aligned; journal metrics and reputation explicitly excluded Alignment with “agency priorities” or “national interest” is an added, non-scientific criterion
    Award stability Funded projects proceed on scientific timelines set at award Active awards may be terminated mid-project if priorities shift

    Common Questions on Grant Peer Review

    What are peer-reviewed grants?

    Peer-reviewed grants are awards where an independent panel of subject-matter experts assesses a proposal’s scientific merit, feasibility, and rigour before funds are released. Agencies including NIH, UKRI, and most major foundations use this process to allocate limited public or philanthropic funding to the strongest available science, rather than by administrative discretion alone.

    What is the golden rule of peer review?

    The golden rule of peer review is to judge the work on its merits, free of conflicts of interest or external pressure. Reviewers assess methodology, evidence, and feasibility rather than the identity, politics, or institutional profile of the applicant — the same principle that underlies publication peer review under bodies such as COPE and ICMJE.

    What are the key elements of grant peer review?

    Core elements include reviewer expertise, documented conflict-of-interest management, confidentiality of unpublished ideas, structured and consistent scoring criteria, and a documented decision trail. Removing any one element — for example, by inserting a discretionary political override after panel scoring — weakens the evidentiary chain the whole process is meant to produce.

    What Politicised Review Does to the Evidence Base

    Research administrators should treat this as an evidentiary problem before it is a funding problem. If a funding decision can be overridden on non-scientific grounds after expert review, the review itself stops functioning as reliable evidence of merit — for auditors, for future meta-research, and for the public record. That has knock-on effects:

    • Grant history becomes an unreliable signal for institutional research assessment and future funder due diligence.
    • Researchers in politically sensitive fields face a de facto chilling effect, shaping what gets proposed long before any panel convenes.
    • Cross-border collaborations and co-funding arrangements, for example with Horizon Europe partners, become harder to underwrite if one partner’s award pipeline is subject to discretionary termination.
    • Standardised, interoperable research-administration infrastructure — persistent identifiers, contributor role taxonomies, funder metadata — loses value if the funding decisions it documents are not reliably merit-based.

    Forward Look: How Institutions Can Preserve Merit Review

    Research offices and institutional leaders are not bystanders here. Several concrete, defensible steps can preserve the evidentiary integrity of merit review even where political pressure on funders intensifies:

    • Document review outcomes independently. Retain institutional records of panel scores and reviewer comments separate from final award notices, so a political override is auditable rather than silent.
    • Diversify funding portfolios. Reduce single-funder dependency so that one agency’s discretionary process does not determine an entire research programme’s viability.
    • Support reviewer capacity. Volunteer reviewing is already strained by rising application volumes; institutions that credit peer-review service in promotion and workload models help sustain the expert pool the whole system depends on.
    • Use standardised, verifiable metadata. Persistent identifiers and transparent contribution records make it harder to quietly substitute political criteria for merit criteria after the fact, and easier for auditors and journalists to reconstruct what actually happened.

    None of this substitutes for the underlying policy fight over whether political appointees should hold override authority at all. But it is what research administration can control while that fight plays out — and it rests on the same logic as standardised, verifiable contribution frameworks such as CRediT, which CASRAI originated in 2014 as an interoperable way to document who did what on a piece of research; the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022. Merit-based science depends on infrastructure that makes evidence, including evidence of how funding decisions were actually made, auditable rather than assumed.

  • Grant Peer Review Under OMB’s Proposed 2026 Uniform Grants Regulation

    The Office of Management and Budget (OMB) has proposed a rewrite of the federal government’s grant-making rulebook that would change how grant peer review functions across agencies including the National Institutes of Health (NIH), the National Science Foundation (NSF) and the Department of Energy. According to reporting from STAT News, Inside Higher Ed, Science and NPR, the draft rule would convert the long-standing “Uniform Guidance” (2 CFR Part 200) into a binding “Uniform Grants Regulation,” subordinating scientific merit review to a new layer of political sign-off and giving agency political appointees explicit authority to terminate awards that no longer track administration priorities.

    For research administrators, the proposal is not a routine compliance update. It touches the mechanism — independent expert review — that has underpinned federal research funding decisions for more than half a century.

    What OMB’s Proposed Grants Rule Changes

    Uniform Guidance governs financial assistance rules across virtually every federal grant-making agency, covering everything from allowable costs to audit requirements. OMB’s proposal would elevate that guidance to a binding regulation and layer several new mechanisms on top of it. The core changes reported by STAT, Inside Higher Ed, Science and NPR include:

    • A mandatory pre-issuance review of discretionary grant awards by senior political appointees before funds are released.
    • Reclassification of peer-review recommendations as advisory rather than binding or routinely deferred to.
    • An undefined “Gold Standard Science” criterion appointees may apply during sign-off.
    • Expanded termination authority for awards deemed misaligned with agency priorities, including multi-year awards already underway.
    • New pre-approval requirements for costs tied to publications, conference attendance and journal subscriptions.
    • A “domestic-first” preference framework for research and development awards.
    • Prohibitions on funding tied to diversity, equity and inclusion (DEI) activities, “gender ideology,” or research supporting disparate-impact liability theories.
    • Elimination of fixed-amount subawards.

    The public comment period is reported to close on 13 July 2026, with an anticipated effective date of 1 October 2026 if the rule is finalised largely as proposed.

    From Deference to “Advisory”: How Peer Review’s Role Shrinks

    Under current practice, agencies such as NIH route applications through scientific review groups or study sections, which score proposals on significance, approach, innovation and investigator qualifications. Program officials retain formal award authority, but in practice they defer heavily to review scores and percentile rankings to set paylines.

    The proposed rule text, as reported across multiple outlets, states that peer-review recommendations “are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding” by senior appointees. That is a structural change: a proposal that clears scientific review with a strong score could still be delayed, reprioritised or rejected at a political pre-issuance gate that sits above the merit-review process rather than alongside it.

    Research associations — including the Association of Public and Land-grant Universities (APLU), the American Association for Cancer Research (AACR) and the Computing Research Association (CRA) — have raised concerns that the change would insert non-scientific criteria into funding decisions that have historically been insulated from politics precisely to protect scientific rigour and public trust.

    Aspect Current practice Proposed rule
    Peer-review status De facto determinative for most competitive awards Explicitly advisory
    Final sign-off Program/agency officials, largely deferential to review scores Senior political appointees, mandatory pre-issuance review
    Termination grounds Non-compliance, budget, performance Adds “no longer aligned with agency priorities,” including mid-award
    Allowable costs Publications, conferences, subscriptions generally allowable Pre-approval required for these cost categories
    Subaward mechanism Fixed-amount subawards permitted Fixed-amount subawards eliminated

    Grant Peer Review: Common Questions Answered

    What is a peer-reviewed grant?

    A peer-reviewed grant is funding awarded after independent subject-matter experts assess a proposal’s scientific merit — its significance, approach, feasibility and investigator qualifications — typically through a scored study section or review panel. At NIH, review groups assign priority scores that traditionally shape funding decisions, though final award authority sits with the agency, not the reviewers.

    What is the peer review process for grant applications?

    The peer review process for grant applications routes each proposal to subject-matter reviewers, who score it against published criteria and then discuss and rank applications in a panel meeting. Agencies use these rankings to set paylines and prioritise funding. Under OMB’s proposed rule, that ranking becomes one advisory input rather than the determining factor in a funding decision.

    Do grant reviewers get paid?

    Yes. Federal agencies, including NIH, typically pay peer reviewers a daily honorarium plus travel expenses for study section service. Many reviewers describe the compensation as modest relative to the time required to read, score and discuss a full panel’s worth of competing applications ahead of each review cycle.

    Expanded Termination Authority and Award-Level Risk

    Beyond the review gate itself, the proposal reported by STAT, Science and Inside Higher Ed would broaden agencies’ authority to suspend or terminate grants — including multi-year awards already in progress — if they are deemed no longer aligned with agency priorities or the “national interest.” It would also widen risk assessment of applicants to consider an institution’s affiliation with organisations engaged in activities that “violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government,” a standard with considerable interpretive latitude.

    Paired with new pre-approval requirements for publication, conference and journal-subscription costs, and the removal of fixed-amount subawards, the combined effect is a research-funding environment where mid-project risk is materially higher than under the current framework, even for awards that passed scientific review cleanly.

    What This Means for Research Administrators

    For institutions managing portfolios that depend on merit-reviewed research funding, the proposal raises operational, not just scientific, questions. Recommended near-term actions include:

    • Model termination risk explicitly in multi-year budget and staffing plans, rather than treating a scored, funded award as a settled commitment.
    • Audit cost-approval workflows for publication, conference and subscription spending now, ahead of any pre-approval mandate taking effect.
    • Brief principal investigators on the distinction between a favourable peer-review score and a final funding decision under the proposed pre-issuance review.
    • Coordinate institutional comments through professional associations such as NCURA and ARMA before the docket closes.
    • Track subaward structures that rely on fixed-amount mechanisms, which the proposal would eliminate.

    Offices that have historically treated peer-review outcomes as the primary predictor of award stability will need a second, policy-alignment layer in their risk assessment — one that is harder to forecast because it depends on political judgement rather than published scoring criteria.

    What Happens Next

    The proposed rule remains open for public comment, with reporting placing the deadline at 13 July 2026 and a possible effective date of 1 October 2026 if OMB finalises it substantially as drafted. Scientific and higher-education associations are expected to submit extensive comments opposing the advisory reclassification of peer review, and legal challenges are plausible if the rule is finalised without significant revision, given its scope relative to existing statutory peer-review requirements at agencies such as NIH.

    Until the final text is published, research administrators should treat every provision summarised here as subject to change — but the direction of travel is unambiguous: less deference to scientific merit review, and more discretionary authority at the award-decision and award-termination stages. Institutions that update their risk models and compliance workflows now will be better placed to respond once the rule, in whatever form it takes, becomes binding.

  • OMB Uniform Guidance 2026 Overhaul: What Research Offices Should Flag Before the Comment Deadline

    OMB’s omb uniform guidance 2026 overhaul is now a formal proposed rule, not a rumour circulating through listservs. Published in the Federal Register on 29 May 2026 as document 2026-10817 (tracked under docket OMB-2026-0034), the proposal would rewrite 2 CFR Parts 200 and 300 — the framework governing the large majority of academic, non-profit and state federal awards — and rename it the “Uniform Grants Regulation.” The public comment window closes on 13 July 2026, days from now, with a targeted effective date of 1 October 2026, the start of federal fiscal year 2027. For sponsored-programmes offices, general counsel and research administrators, the compressed 45-day comment period means institutions that have not yet reviewed the text are already behind.

    OMB’s three stated objectives for the rewrite

    OMB has organised the proposal around three explicit objectives, set out in the preamble to the Federal Register notice:

    • Transparency, accountability and oversight — expanding federal agencies’ visibility into recipient risk, subaward reporting, conflicts of interest and termination decisions.
    • Regulatory clarity — converting 2 CFR Subtitle A from non-binding “guidance” into a document with regulatory effect in its own right, so future OMB amendments apply government-wide without separate agency rulemakings.
    • Reduced recipient burden — measures such as encouraging multi-year awards, mandating that funding opportunities post to Grants.gov, and using pre-application statements of interest to screen out low-probability applicants before a full proposal is required.

    Much of the substantive detail traces back to Executive Order 14332, “Improving Oversight of Federal Grantmaking” (7 August 2025), which directed OMB to build termination-for-convenience authority and mandatory senior-appointee review into the Uniform Guidance. The 2026 proposal is OMB’s formal vehicle for codifying that order, together with several 2025 executive orders addressing DEI, gender ideology and merit-based opportunity.

    What changes for award recipients

    The proposed rule touches nearly every phase of the award lifecycle. Recipients should not assume that practices considered compliant under the current text will automatically satisfy the revised one — several provisions are new law, not restatements.

    Section Current position Proposed change
    §200.205 – merit review Agency-run scientific/programmatic merit review Senior political appointee conducts “pre-issuance review” of every discretionary award; peer review recommendations are advisory only
    §200.340 – termination Termination chiefly for noncompliance Broad discretionary termination if an award “does not effectuate…the national interest as they exist at the time of termination”; new 90-day suspension authority
    §200.202(e) – R&D awards No domestic-entity restriction “Domestic-first framework” generally limits research and development awards to US-organised entities
    §200.220 (new) – foreign collaboration No equivalent provision Prohibits using federal funds, including indirect cost allocations, for collaboration with “covered foreign countries or entities”
    §200.461 – publication costs Generally allowable Unallowable unless required by statute or approved in advance by the agency
    §200.432 – conference costs Allowable Allowable only if expressly pre-approved in the award’s terms and conditions
    §200.333 – fixed-amount awards Permitted with agency approval Eliminated entirely, in favour of cost-reimbursement structures

    Other proposed changes worth flagging: mandatory E-Verify participation (§200.303(f)); a new requirement that recipients disclose employees who worked at the awarding agency within the prior two years (§200.112–.113); an expanded risk-assessment framework at §200.206(b) that lets agencies weigh an applicant’s Section 117 foreign-gift-disclosure compliance and “questionable practices” history; and a new subrecipient clause (§200.332(i)) obliging pass-through entities to ensure subrecipients do not “significantly damage the reputation” of the funding agency. Notably, OMB has explicitly declined to reopen indirect cost rate methodology in this rulemaking, though the pre-issuance review principle favouring “institutions with lower indirect cost rates” applies indirect downward pressure regardless.

    This is the third revision to the framework since its 2013 consolidation: OMB made administrative updates in August 2020, then a substantive 2024 revision (effective 1 October 2024) that raised the single-audit threshold from $750,000 to $1,000,000. The 2026 proposal is materially broader in scope than either predecessor, extending well beyond audit and cost mechanics into award termination, political review and non-discrimination policy — territory the Uniform Guidance has not previously occupied.

    Common questions about the 2026 Uniform Guidance rewrite

    What is the uniform guidance of 2 CFR 200?

    2 CFR Part 200, informally the Uniform Guidance, is the government-wide framework setting administrative requirements, cost principles and audit requirements for federal grants, cooperative agreements and other financial assistance. Consolidated from eight separate OMB circulars in 2013, it governs how universities, non-profits, states and tribal governments manage federal award funds.

    When did the uniform guidance change?

    OMB has revised the Uniform Guidance three times since 2013: minor administrative updates in August 2020; a substantive revision effective 1 October 2024 that raised the single-audit threshold to $1,000,000; and the sweeping rewrite proposed on 29 May 2026, targeting an effective date of 1 October 2026.

    What is the purpose of Subpart F of the Uniform Guidance in 2 CFR Part 200?

    Subpart F sets the audit requirements for non-federal entities, including the single audit obligation triggered once an organisation spends federal award funds above the statutory threshold. It defines auditee and auditor responsibilities, reporting deadlines and the criteria agencies use to assess an institution’s financial management and internal controls.

    What is the new uniform guidance threshold?

    The most recent confirmed threshold change raised the single-audit trigger from $750,000 to $1,000,000 in annual federal expenditure, effective for fiscal years ending on or after 30 September 2025. The 2026 proposed rewrite does not revisit this figure; it concentrates instead on oversight, termination authority and cost-principle changes.

    How institutions can still comment, and what happens next

    The comment window is short by design: OMB set a 45-day period specifically so that, in its words, “only a single set of government-wide requirements” applies to awards made during fiscal year 2027. Comments may be filed through Regulations.gov against docket OMB-2026-0034 or attached directly to the Federal Register listing for document 2026-10817. As of mid-June 2026 the docket had already drawn more than 14,800 public comments, reflecting the scale of institutional concern.

    Two procedural points matter for anyone drafting a submission before 13 July:

    • Grant-related rulemakings are generally exempt from the Administrative Procedure Act’s requirement that agencies individually respond to every “significant comment,” so OMB may group responses thematically in the final rule’s preamble rather than address each submitter.
    • An agency’s obligation to consider comments in judicial review is limited to the issues those comments actually raise — a specific, well-evidenced submission on a provision an institution intends to challenge later is more likely to preserve that argument than a general objection.

    Research-administration associations, including NCURA and ARMA, are coordinating member briefings and template comment language, and institutions weighing individual versus coalition submissions should consider filing both: a joint comment through a sector body carries collective weight, while an institution-specific comment on provisions with unique operational impact (large multi-year awards, extensive international collaboration, heavy publication or conference spend charged to awards) creates its own record.

    Whether or not the rule is finalised as drafted by 1 October 2026, institutions should not wait for that date to begin preparing. The executive orders underlying most of the proposed provisions — on grantmaking oversight, DEI, and foreign collaboration — are already in effect and already shaping agency behaviour in individual award decisions. Convening a cross-functional review involving the office of research, general counsel, sponsored programmes and research administration compliance staff now, before the final rule lands, is the practical way to avoid a scramble in early October. Given the volume of comments already filed and the litigation risk flagged by multiple legal analyses of the proposal, a modified final rule — rather than the text exactly as proposed — is a realistic outcome, but the direction of travel toward tighter political oversight and narrower allowable costs is unlikely to reverse.

  • The De Minimis Indirect Cost Rate: When the 15% Safe Harbor Works for Your Institution

    Every proposal budget has to answer one question: how will the institution recover the overhead it spends supporting a federally funded project? For organisations without the staff or history to negotiate a formal rate, the de minimis indirect cost rate is a standing, no-negotiation alternative built directly into the federal Uniform Guidance. It lets an eligible non-federal entity recover indirect costs on a federal award without submitting a full indirect cost rate proposal — but the rate itself, and the rules around electing it, changed materially in 2024, and many summaries in circulation still cite the old figure.

    What is the de minimis indirect cost rate?

    The de minimis rate is a fixed indirect cost recovery option set out in 2 CFR 200.414(f), the cost-principles section of the OMB Uniform Guidance that governs federal grants and cooperative agreements. It exists so that organisations without a current Negotiated Indirect Cost Rate Agreement (NICRA) are not forced to either forgo indirect cost recovery entirely or undertake a formal rate negotiation with a cognizant federal agency.

    Effective 1 October 2024, OMB revised 200.414(f) and raised the rate from a flat 10% to up to 15% of Modified Total Direct Costs (MTDC). This is the single most important recent change to the rule, and it altered its character: the rate is no longer automatically 10%, nor is it automatically 15%. The “up to” language means an electing organisation should be able to justify the rate it applies, particularly if its actual indirect costs run below 15% of MTDC.

    MTDC is a defined cost base, not simply total direct costs. It includes direct salaries and wages, applicable fringe benefits, materials, supplies, services, travel, and the first $50,000 of each subaward. It excludes equipment, capital expenditures, patient care charges, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of any subaward beyond $50,000.

    Who qualifies to elect it

    Eligibility is narrower than the phrase “de minimis” suggests. Under 2 CFR 200.414(f):

    • The entity must be a non-federal recipient or subrecipient — a state or local government, Indian tribe, institution of higher education, or non-profit organisation.
    • The entity must not currently hold a NICRA. An organisation that has never negotiated a rate, or whose prior agreement has expired without renewal, is generally the target user.
    • For-profit entities are not eligible. Cost principles for commercial organisations sit under FAR Subpart 31.2, not 2 CFR 200 Subpart E, so the de minimis election in 200.414(f) simply does not apply to them.
    • Once elected, the rate must be applied consistently across all of the entity’s federal awards until it either negotiates a NICRA or its circumstances otherwise change; it cannot be selectively applied to some awards and not others.

    In practice, the de minimis rate is used most often by first-time federal grantees, small non-profits, and institutions with genuinely modest indirect costs — organisations for whom the administrative cost of preparing a full rate proposal would exceed the financial benefit of a more precisely calculated rate.

    De minimis rate vs a negotiated rate (NICRA)

    Choosing between the de minimis rate and a negotiated agreement is a genuine trade-off, not a formality. A NICRA requires submitting a detailed indirect cost rate proposal to a cognizant federal agency, supported by an audited or auditable cost allocation base, and typically takes months to negotiate. The de minimis rate requires no proposal and no negotiation at all.

    Factor De minimis rate (up to 15% of MTDC) Negotiated rate (NICRA)
    Documentation to elect None required; self-certified election Formal indirect cost rate proposal with supporting cost data
    Time to establish Immediate Typically several months of negotiation
    Rate accuracy Fixed ceiling, may under-recover true indirect costs Reflects the institution’s actual cost structure
    Best suited to First-time or small-scale federal recipients with modest overhead Institutions with sustained federal funding and indirect costs above 15% of MTDC
    Flexibility once set Must be applied consistently to all federal awards Rate is fixed for the negotiated period, then renegotiated

    For institutions whose actual indirect costs genuinely sit at or below 15% of MTDC, the de minimis rate is a reasonable long-term choice — it avoids the recurring administrative burden of rate renegotiation. For research-intensive institutions with substantial facilities and administrative costs, a negotiated rate almost always recovers more, because negotiated F&A rates at research universities commonly run well above 15% of MTDC.

    Documentation and compliance requirements

    The de minimis election requires no formal proposal, but it is not a documentation-free zone. Institutions should still:

    • Retain a clear internal decision record showing the rate elected and the justification, especially where the rate applied is below the full 15% ceiling.
    • Apply the cost base correctly — errors in MTDC calculation, such as including full subaward amounts above $50,000 or capital equipment, are among the most common audit findings.
    • Maintain consistency: costs charged as indirect under the de minimis rate cannot also be charged directly to the same award, and vice versa.
    • Track award-level restrictions, since some individual federal programmes cap or exclude indirect cost recovery regardless of an entity’s general de minimis election.

    Common questions

    What is a de minimis indirect cost rate?

    The de minimis indirect cost rate is a standard rate that eligible non-federal entities without a current negotiated agreement may apply to recover indirect costs on federal awards. It is capped at 15% of Modified Total Direct Costs and requires no formal rate proposal to use.

    When did the de minimis indirect cost rate change?

    OMB revised 2 CFR 200.414(f) effective 1 October 2024, raising the de minimis rate from a flat 10% to up to 15% of MTDC for new federal awards. Awards issued before that date may still reference the earlier 10% figure.

    What is the current de minimis rate?

    As of the 2024 Uniform Guidance revision, the current ceiling is 15% of MTDC. Because the regulation uses “up to” language, an organisation should be able to support the specific rate it elects rather than assume 15% applies automatically.

    How do you use the de minimis rate?

    An eligible entity elects the rate by applying it directly to its Modified Total Direct Costs base on a federal award, with no application or negotiation required. Once elected, the entity must use it consistently across all federal awards until it negotiates a formal rate.

    Implications for research administrators

    The de minimis rate should not be confused with a separate and unresolved policy debate: proposed caps on negotiated indirect cost rates. In 2025, NIH and later other federal science agencies proposed capping F&A reimbursement at 15% even for institutions that already hold a NICRA well above that figure — a distinct move from the de minimis election, which has always applied only to entities without a negotiated rate. Those cap proposals drew legal challenges from higher-education associations and remain contested in federal court as of this writing. Research administrators should track the two issues separately: one is a stable, settled recovery option for smaller or first-time recipients; the other is a live policy dispute over whether research-intensive institutions’ existing negotiated rates can be unilaterally reduced.

    For institutions building or reviewing their research administration infrastructure, the practical takeaway is to treat the de minimis election as a genuine strategic choice rather than a default. Model the actual indirect cost recovery under both the de minimis ceiling and a hypothetical negotiated rate before committing, since the consistency requirement makes switching mid-portfolio administratively costly. As federal cost-recovery policy continues to shift, institutions that document their rate rationale clearly will be best placed to adapt.

  • Indirect Cost Rate Negotiation: A Step-by-Step NICRA Guide

    Every research administrator eventually confronts the same negotiation: how to persuade a federal cognizant agency that the true overhead cost of running a laboratory, a sponsored programme, or an entire research enterprise deserves fair reimbursement. The indirect cost rate that comes out of that negotiation — formalised in a Negotiated Indirect Cost Rate Agreement, or NICRA — determines how much of an institution’s administrative and facilities burden is actually recovered on every federal award it holds. This guide walks through the mechanics: how to choose a rate type, build a defensible proposal, and manage the negotiation itself.

    This is a process guide, not a policy explainer. For background on the funding-cap debate around indirect cost recovery under the OMB Uniform Guidance, see CASRAI’s separate coverage of that policy story. Here, the focus is what a research office actually has to do — and in what order — to walk out of a negotiation with a usable rate agreement.

    What Is a NICRA, and Who Needs One?

    A NICRA is a formal, signed agreement between an organisation and its cognizant federal agency — generally whichever agency provides the largest share of that organisation’s direct federal funding — that fixes the percentage rate used to recover indirect costs on federal awards. For most US colleges and universities, cognizance sits with either the Department of Health and Human Services’ Division of Cost Allocation or the Department of the Navy’s Office of Naval Research; nonprofits and other award recipients are typically assigned a cognizant agency by whichever federal funder they draw the most direct money from.

    Once negotiated, a NICRA is binding across all federal agencies, not just the one that negotiated it — a single rate agreement travels with the organisation to every subsequent federal award. Organisations that have never held a NICRA, or whose rate has lapsed, have a fallback: 2 CFR 200.414(f) permits use of a de minimis rate of up to 15% of modified total direct costs (MTDC) without negotiation, though that rate must then be applied consistently across every federal award until a negotiated rate is obtained.

    Preparing the Indirect Cost Rate Proposal

    Before submitting anything, the research office has two decisions to make: which rate type to request, and what documentation the proposal will need to withstand review.

    Rate type Definition Adjustable later?
    Provisional Temporary rate used for interim billing pending a final rate for the same period Yes — reconciled against actual costs
    Final Rate set once actual costs for a completed fiscal year are known No
    Predetermined Fixed rate set in advance for a future period, based on a prior representative period’s actual costs No, for that period
    Fixed with carry-forward Predetermined rate with a built-in adjustment for the gap between estimated and actual costs Adjusted in the following period

    Organisations that have never negotiated a rate should generally submit their first proposal within three months of receiving a federal award; organisations with an existing NICRA must submit an updated proposal within six months of the close of each fiscal year covered by that agreement. Missing this window can force an organisation back onto the de minimis rate until a new proposal is accepted.

    A complete indirect cost rate proposal package typically includes:

    • A cover letter stating the fiscal period, rate type requested, and allocation base
    • An organisational chart and description of each unit’s functions
    • Audited financial statements or a Single Audit Report for the fiscal year under review
    • A cost policy statement setting out which costs are charged directly versus indirectly
    • The indirect cost rate calculation itself — indirect cost pool divided by the chosen direct cost base — reconciled line-by-line to the financial statements
    • A schedule of salary and wage allocation between direct and indirect functions
    • A statement of employee fringe benefits
    • A complete listing of federal grants and contracts active during the fiscal year
    • A signed Certificate of Indirect Costs and lobbying certification

    Every unallowable cost — entertainment, alcohol, lobbying, fundraising — must be scrubbed from the indirect cost pool before submission; a proposal that includes unallowable costs, even inadvertently, is the single most common reason negotiations stall.

    Negotiating With Your Cognizant Agency

    Once a proposal is accepted for review, a negotiator or auditor at the cognizant agency is assigned to check compliance with the applicable federal cost principles — 2 CFR Part 200 (the Uniform Guidance) for nonprofits, colleges, and local governments, or FAR Part 31 for commercial organisations under agencies such as the Defense Contract Audit Agency. Expect an iterative back-and-forth: requests for supporting documentation, clarification of allocation methodologies, and questions about specific cost pool line items.

    If agreement is reached, the cognizant agency issues the NICRA for signature. If it is not — because of disputed pool expenses or a disagreement over the allocation base — the agency may instead issue a unilateral rate agreement. An organisation that disagrees with a unilateral rate typically has a defined window (30 days, under NSF’s published appeal procedures) to invoke formal appeal procedures before the unilateral rate takes effect by default.

    What is the difference between direct and indirect costs?

    Direct costs are expenses specifically identifiable with a single project — a piece of equipment, a research assistant’s salary. Indirect costs, sometimes called facilities and administrative (F&A) costs, are shared expenses — utilities, general administration, facilities maintenance — that benefit multiple projects and cannot be assigned to just one.

    How do you calculate an indirect cost rate?

    An indirect cost rate is calculated by dividing the total indirect cost pool by a chosen direct cost base, typically modified total direct costs (MTDC). The resulting percentage is applied to that base on each award to determine how much indirect cost recovery the project generates.

    What percentage should indirect costs be?

    There is no single “correct” indirect cost rate — negotiated rates vary widely by institution type, facilities intensity, and cost base. Organisations without a negotiated rate may instead use the de minimis rate of up to 15% of modified total direct costs under 2 CFR 200.414(f).

    What is an example of an indirect cost?

    Common examples include administrative salaries, building depreciation, utilities, general liability insurance, and shared IT infrastructure — costs that support the whole organisation rather than any single sponsored project.

    Implications for Research Offices and What Comes Next

    Negotiating a NICRA is resource-intensive: it typically demands sustained input from finance, sponsored programmes, and facilities staff over several months, and the resulting rate directly shapes how much overhead recovery an institution can budget against every subsequent federal award. Institutions weighing whether negotiation is worth the administrative overhead should treat the de minimis 15% MTDC rate as a genuine fallback for smaller or first-time federal recipients, not a permanent compromise — most organisations with significant sustained federal funding recover meaningfully more through a negotiated rate over time.

    Because a signed NICRA binds every federal agency, not just the one that negotiated it, getting the proposal right the first time avoids repeat renegotiation cycles. As indirect cost recovery policy continues to attract political scrutiny at the federal level, research offices that maintain clean, well-documented cost pools and submit proposals on schedule will be best placed to defend their negotiated rates regardless of how the broader policy debate resolves. Robust research administration practice — accurate cost allocation, disciplined recordkeeping, and early engagement with the cognizant agency — remains the most reliable lever an institution controls in this process.