Research Funding Updates

Executive Orders and Federal Guidance

The University of Maine is actively monitoring new executive orders (EOs) and federal agency guidance that may impact the university external funding. Federal directives are being issued at a rapid pace, and their guidance can evolve quickly. The UMaine’s Office of Vice President for Research and Graduate Studies is committed to keeping researchers informed of these developments and ensuring compliance with any new requirements. Faculty, staff and administrators are encouraged to stay updated and reach out with questions as needed​. This is not intended to be legal advice nor is it an exhaustive list of all federal actions and legal developments. If you do not see a topic that is pertinent to your grant, please reach out to ORA for further guidance.

Recent Updates

Topical Developments

The University of Maine is actively monitoring these topics and how they affect federally funded research. Please check back here frequently for updates.

Executive Orders 14151 (Federal Register Link) and 14173 (Federal Register Link) mandate federal agencies to discontinue funding for Diversity, Equity, and Inclusion (DEI) initiatives. In response, agencies such as the U.S. Department of Energy (DOE), NASA, and the National Science Foundation (NSF) have issued directives requiring institutions, including the University of Maine, to immediately cease all DEI-related activities funded under federal grants and contracts.

  • Ongoing Submissions: UMaine will continue submitting proposals as long as federal agency submission systems remain operational.
  • Review Timelines: Sponsor proposal review timelines may be extended as agencies adjust to new directives.
  • Organizational Prior Approval System (OPAS) Forms: OPAS requests for pending proposals are not recommended at this time. These requests will be evaluated cautiously, considering evolving federal guidance and funding priorities.

Legal Developments

On March 14, 2025, the Fourth Circuit Court of Appeals granted a stay of an injunction that was previously granted by the U.S. District Court for the District of Maryland in National Association of Diversity Officers in Higher Education et al. v. Trump et al., Case No. 1:25-cv-00333-ABA. The injunction had  blocked key provisions of Executive Orders 14151 and 14173. 

  • NASA Guidance: NASA issued a memorandum on January 23, 2025, instructing all contractors and grantees to immediately stop all DEIA-related activities required under federal agreements. The agency warned that failure to comply could result in stop-work orders or contract modifications. (NASA Memorandum – See attached)​.
  • US Department of Energy (DOE): On January 27, 2025, the DOE issued a memorandum directing all funding recipients to cease activities related to DEI programs, Community Benefits Plans (CBP), and Justice40 initiatives. The memo specifies that costs incurred for these activities after the issuance date will not be reimbursed and that recipients must communicate this directive to all subrecipients and contractors.  The US Department of Energy released a letter on March 11, 2025 rescinding this memorandum.
  • NSF Guidance: The NSF notified all grantees on January 28, 2025, that funding reviews, new awards, and payments under open awards would be paused while the agency evaluates compliance with the new Executive Orders. The guidance states that activities involving conferences, training, staffing considerations, and any other work that incorporates DEIA principles must cease immediately. (NSF Message – See attached)​.

The Appeals Court interpreted the EOs’ directives as being limited to illegal DEI/DEIA which would violate non-discrimination laws. This case is currently pending appeal, and the University of Maine will monitor developments closely to determine how this may impact ongoing and future federally funded research.

Department of Education Guidance

On February 28, 2025, the U.S. Department of Education released an FAQ document, About Racial Preferences and Stereotypes Under Title VI of the Civil Rights Act, clarifying compliance expectations under the new executive orders relating to Title VI, which prohibits discrimination based on race, ethnicity, or national origin. Researchers and grant administrators should review this document to understand its implications for federal awards. (Department of Education FAQ). Note, the FAQs do not address any other applicable nondiscrimination law or regulation or other protected classes or characteristics.

Next Steps for UMaine Researchers

  • Review agency communications: If you have an active federal award, carefully examine any new guidance from your funding agency.
  • DEI related activities: If your federally funded project includes DEI-related components, email ora@maine.edu to determine next steps.
  • Monitor legal updates: The court case challenging EOs 14151 and 14173 may lead to further legal rulings that could impact compliance requirements.

For further questions or assistance, please contact UMaine’s Office of Research Administration (ORA) at ora@maine.edu.

In January 2025, the Office of Management and Budget (OMB) and various federal agencies initiated actions to pause funding for Diversity, Equity, and Inclusion (DEI) programs, leading to significant impacts across multiple sectors.​

Office of Management and Budget (OMB) Funding Pause

  • January 29, 2025: Under M-25-14, the OMB withdrew memorandum M-25-13.
  • January 28, 2025: The memo’s implementation was stayed by U.S. District Judge Loren AliKhan, citing potential overreach of executive authority. Despite the stay, the initial directive caused widespread confusion and disruptions across various federally funded programs. ​
  • January 27, 2025: The OMB issued memorandum M-25-13, directing a temporary pause on all activities related to the obligation or disbursement of federal financial assistance, particularly targeting programs associated with foreign aid, nongovernmental organizations, DEI, gender ideology, and environmental initiatives.

Although OMB Memorandum M-25-13 has been rescinded, the University of Maine continues to experience funding pauses and restricted access to funds through federal agency payment systems. These disruptions may affect the timing of new awards, payments under existing awards, and processing of financial transactions with federal sponsors.

We are actively monitoring these developments and will notify Principal Investigators (PIs) and administrative units if their award is affected. 

UMaine remains engaged with federal agencies to track updates, assess potential impacts, and advocate for the timely disbursement of research funding. We will provide additional information as it becomes available.

Legal Challenges and Developments

  • February 1, 2025: U.S. District Judge John J. McConnell Jr. issued a temporary restraining order blocking the implementation of the funding freeze in 22 states and the District of Columbia.
  • February 10, 2025: Judge McConnell extended the injunction, ordering the immediate restoration of previously frozen funds, emphasizing the significant harm caused by the funding disruptions. ​

We are actively monitoring these developments and will notify Principal Investigators (PIs) and administrative units if their award is affected.

UMaine remains engaged with federal agencies to track updates, assess potential impacts, and advocate for the timely disbursement of research funding. We will provide additional information as it becomes available.

Executive Orders 14168 and 14187 direct federal agencies to restrict funding for gender-affirming medical care, including programs that support treatment for transgender minors. 

Legal Developments

  • On February 14, 2025, the U.S. District Court for the District of Maryland issued a temporary restraining order in PFLAG v. Trump, Case No. 25-337-BAH. The order temporarily blocks enforcement of certain provisions in Executive Orders 14168 and 14187, preventing federal agencies from withholding funding from healthcare providers and institutions offering gender-affirming care to transgender minors. The ruling does not address whether agencies may make funding decisions related to gender-focused research.

On March 4, 2025, Judge Brendan A. Hurson issued a preliminary injunction extending the previous temporary restraining order, preventing federal agencies from enforcing funding restrictions on gender-affirming care for transgender minors while the case proceeds.

Next Steps for UMaine Researchers

  • Review Agency Communications: If you hold a federal grant, check for new guidance from your funding agency.
  • Assess Gender-Related Project Components: If your project includes gender-focused activities, email ora@maine.edu for compliance guidance.
  • Monitor Legal Developments: Further rulings on EOs 14168 and 14187 may influence federal research funding.

For assistance, please contact the University of Maine Office of Research Administration (ORA) at ora@maine.edu.

The National Institutes of Health (NIH) issued Notice Number: NOT-OD-25-068 on February 7, 2025, announcing a standardized 15% Facilities & Administrative (F&A) cost rate for all NIH grants. This policy replaces previously negotiated F&A rates and applies to both new and existing grants, effective immediately upon issuance.

Key Provisions of the NIH Notice

  • Standardized F&A Cost Rate: All NIH grants are now subject to a uniform 15% F&A cost rate, superseding prior negotiated rates.
  • Scope of Application: The 15% rate applies to all new grants and existing grants to Institutions of Higher Education (IHEs) from February 10, 2025, onward.​
  • Justification: The NIH aims to align its F&A cost rates with those of private foundations and ensure that a greater proportion of funds are directed toward direct scientific research.​

Impact on Research at the University of Maine

The implementation of this cap has significant financial implications for research institutions:​

  • Reduced Funding for Facilities and Administrative operations: Institutions with previously higher negotiated rates may face substantial decreases in funding for facilities and administrative expenses.
  • Operational Challenges: The reduction in F&A cost recovery could affect the sustainability of research infrastructure and administrative support services.​

Legal Challenges and Current Status

The policy has been met with legal opposition:​

  • Lawsuits Filed: On February 10, 2025, a coalition of 22 state attorneys general filed a lawsuit challenging the NIH’s authority to impose the cap, arguing it threatens critical research funding.
  • Temporary Restraining Order (TRO): A federal judge issued a nationwide TRO on February 10, 2025, temporarily halting the enforcement of the 15% cap pending further legal proceedings.

Current Status

The NIH is currently prohibited from implementing the 15% F&A cost cap. Research institutions continue to operate under their previously negotiated F&A cost rates. The legal proceedings are ongoing, and the final outcome will determine whether the NIH can enforce the proposed cap.​

Next Steps for UMaine Researchers

No action is required at this time. Researchers may continue to submit NIH proposals and manage existing awards under their current negotiated F&A rate.

Please note that the situation is evolving, and it is essential to stay updated on legal proceedings and NIH communications regarding the F&A cost rate policy.

Resources

General guidance and FAQ

Proposals

Proposal submissions

  • Ongoing Submissions: UMaine will continue submitting proposals as long as federal agency submission systems remain operational.
  • Review Timelines: Sponsor proposal review timelines may be extended as agencies adjust to new directives.
  • Organizational Prior Approval System (OPAS) Forms: OPAS requests for pending proposals are not recommended at this time. These requests will be evaluated cautiously, considering evolving federal guidance and funding priorities.

Recommended Actions:

  • Verify Deadlines: Confirm that proposal deadlines have not changed.
  • Stay Informed: Ensure that funding announcements are current. Consider subscribing to alerts from relevant federal agencies or sponsors.

FAQ:

Should I delay proposal submission during a federal agency funding pause?

No, unless otherwise directed by the agency. Submitting proposals on time ensures they are in the review queue when funding resumes. Stay informed about agency updates and deadlines.

If my proposal is approved but funding is delayed, can I request advance funding to start the project?

Advance funding may be available through an OPAS (Organizational Prior Approval System) request. However, given funding uncertainties, OPAS requests will be evaluated cautiously. Contact ORA to discuss feasibility.

What FAQ’s are missing from your perspective?

Please send your questions to ora@maine.edu.

Award management

Current awards:

  • The terms and conditions of active awards remain in effect.
  • Standard operations, including invoicing and reimbursement, should continue as usual.
  • Any changes to an award will be communicated via official amendments.

Compliance updates:

  • Research compliance requirements may change due to new federal directives or project-specific amendments.
  • Timely action is required to maintain compliance and secure funding.
  • For compliance-related inquiries, contact:
  • Animal Care, Biosafety, or Human Subjects: umric@maine.edu
  • Export Control: um.export@maine.edu

Reporting requirements:

  • Federal agencies may update award reporting obligations.
  • Any changes will be communicated directly or via award amendments.
  • Timely compliance is necessary to prevent funding risks.
  • For reporting support, contact: ora@maine.edu.

Program changes:

  • If federal agencies terminate or restructure programs, accessing funds or meeting new criteria may become challenging.
  • Agencies will provide specific guidance if such changes occur.

Funding pauses

Any expenses incurred during the pause are at risk of not being reimbursed by the sponsor and must be covered by the project’s closing account or other allowable account. Given this risk, it is recommended to work with research center and college leadership to identify short-term funding solutions for personnel during the pause.

We recommend providing subawardees with an early heads-up. ORA will send formal communication.

Work with unit, HR and college leadership on messaging. Stick to the language used in shared communications to ensure consistency.

Reallocating funds to cover personnel costs depends on the award terms and conditions. In some cases, re-budgeting may be allowable with prior approval from the sponsor. Contact ORA for guidance before making any adjustments.

The reinstatement of funding depends on federal agency decisions. Some programs may resume at full funding levels, while others may be subject to reductions or cancellations. Stay in close communication with ORA for updates.

Work may continue at the department’s or institution’s risk. Expenses incurred during the pause may not be reimbursed. It is advised to consult ORA and unit leadership before continuing project-related activities.

Keep detailed records of how the pause affects your research timeline, personnel, and expenditures. This documentation may be useful when communicating the effects.

Procurement considerations

  • Recent executive orders and future directives, such as those affecting tariffs, may impact procurement processes for federally funded projects.
  • Stay updated on these developments and incorporate them into planning to maintain compliance and minimize disruptions.

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