News & Analysis as of

Regulatory Requirements Grants Federal Funding

Ropes & Gray LLP

Closeout Requirements During Appeals of Terminations of NIH Research Grants

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On July 7, 2025, the National Institutes of Health (NIH) Office of Policy for Extramural Research issued NOT-OD-25-128, titled “Guidance on Enforcement of Closeout Requirements During the Appeals Process” (the Notice). The...more

Sheppard Mullin Richter & Hampton LLP

HRSA Announces New Requirements for FQHCs to Provide Insulin and Epinephrine at or below 340B Price

On June 24, HRSA announced that it had issued new grant award terms to its HRSA-funded health centers to provide insulin and injectable epinephrine at or below the 340B price paid by the health center for the drugs. HRSA...more

Holland & Knight LLP

NIH Announces Significant Changes to Federal Grant Terms, Conditions on Civil Rights

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The National Institutes of Health (NIH) announced on April 21, 2025, a significant change to the terms and conditions governing federal funding (the Notice) applicable to all NIH grants, cooperative agreements and other...more

Brownstein Hyatt Farber Schreck

CDFIs Under Threat in New Executive Order

On March 14, President Trump issued an executive order (EO) titled “Continuing the Reduction of the Federal Bureaucracy,” which limits the Community Development Financial Institutions (CDFI) Fund to the minimum statutory...more

Cozen O'Connor

Democratic AGs Block NIH Grant Cuts

Cozen O'Connor on

A coalition of 22 Democratic AGs obtained a preliminary injunction blocking the implementation of the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (Rate Change Notice), which would have...more

Arnall Golden Gregory LLP

U.S. Department of Health and Human Services Rescinds "Richardson Waiver" Policy

On March 3, 2025, the U.S. Department of Health and Human Services (“HHS”) announced a new policy to reverse course on certain public notice and comment procedures. This marks a significant change to a process in place for...more

McDermott Will & Emery

NIH’s Mandatory 15% Indirect Rate – Next Steps Following Preliminary Injunction

On March 5, 2025, a US district court in Massachusetts issued a preliminary injunction blocking the National Institutes of Health (NIH) from implementing a February 7, 2025, “Supplemental Guidance” notice that would establish...more

Morgan Lewis

HHS Rescinds Policy Extending Notice and Comment Rulemaking Procedures to Rules for Grants, Public Benefits, and Contracts

Morgan Lewis on

Effective March 3, 2025, the US Department of Health and Human Services (HHS) rescinded its long-standing policy that had waived a statutory exemption under the Administrative Procedure Act (APA) from notice and comment...more

Wiley Rein LLP

President Trump Issues New EO to Improve “Cost Efficiency” of Government Contracts and Grants

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On February 26, 2025, the Trump Administration issued a new Executive Order (EO) that will significantly impact existing and new government contracts and grants. The stated purpose of the EO, titled “Implementing the...more

Venable LLP

Another Change, Did You See NIH's Near-Immediate Change to Your Indirect Cost Rate?

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Over the past few weeks, the Trump administration has introduced sweeping changes across the federal government that have impacted the federal grantee and contractor community. Adding to these changes, the National Institutes...more

Bass, Berry & Sims PLC

Can the NIH Cap Indirect Cost Rates at 15%?

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Note: This post was updated with new information on February 13, 2025. On February 7, the National Institutes of Health (NIH) issued Supplemental Guidance to its 2024 NIH Grants Policy Statement, Indirect Cost Rates,...more

Epstein Becker & Green

The NIH IDC – Where Are We Now

Epstein Becker & Green on

On February 7, the National Institutes of Health (“NIH”) issued a Notice (NOT-OD-25-068) entitled “Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates” (the “Notice”), though which NIH announced...more

Davis Wright Tremaine LLP

New Administration Outlook: How Your Organization Can Adapt to Federal Grant Uncertainty

This past week, the Trump Administration issued and then rescinded its January 27, 2025, OMB memorandum that temporarily paused federal agency grants, loans, and other financial assistance programs. In the supplemental...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs/White House Office of Management and Budget...

A Blog post on January 30, 2025, described the White House Office of Management and Budget (“OMB”) issuance of a January 27th Memorandum for heads of executive departments and agencies addressing: Temporary Pause of...more

Husch Blackwell LLP

Federal Government Freezes Grant/Loan Disbursements – What It Means for Nonprofits

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On January 27, 2025, the United States Office of Management and Budget (OMB) issued a pause, set to go into effect at 5 p.m. on January 28, to all “federal financial assistance programs and supporting activities.” The order...more

Foley & Lardner LLP

State of Play: Temporary Pause of Agency Grants, Cooperative Agreements, Loans, and Other Financial Assistance Programs

Foley & Lardner LLP on

UPDATE: As of 5:00 PM EST on January 28, a federal judge has temporarily blocked the Trump administration from enforcing the freeze detailed below.  This situation is ongoing and clients should still prepare accordingly....more

Husch Blackwell LLP

Understanding the Implications of the Temporary Pause on Federal Financial Assistance

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OMB Memorandum (M-25-13) advises federal agencies that they must temporarily pause all activities and disbursements of federal financial assistance that may be implicated by any of President Trump’s recent Executive Orders at...more

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