Updates on 2025 Federal Research Policy Changes 

Updated as of 2/11/2025

Many federal agencies are updating their policies and solicitations in response to recent Executive Orders and related federal agency directives. We know that our community is closely following these developments and may have questions about impacts to their own research. 

The regulatory environment and agency-specific orders and requirements are changing rapidly. Harvard leadership continues to monitor these developments closely, and we will update this page frequently as we learn more.

University Communications

• 2/11/25 – John H. Shaw: Update on Monday’s Actions
• 2/9/25 – Alan M. Garber: Indirect Costs and Their Impact on Our Research Mission
• 2/9/25 – John H. Shaw: IDC Updates (PDF)
• 2/4/25 – John H. Shaw: Federal Funding: Updates (PDF)
• 1/29/25 – John H. Shaw: Federal Funding: Updates and Two New Actions (PDF)
• 1/28/25- Alan M. Garber, John F. Manning, Meredith Weenick: Emerging regulations and legislation
• 1/24/25 – John H. Shaw: Agency Announcements (PDF)

Recent Updates

Several executive orders (EOs) have been issued that address federally funded research.  Copies of EOs are posted on the White House’s News page. 

The January 27 funding freeze, Memorandum for Heads of Executive Departments and Agencies to Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs has been temporarily halted in court pending litigation and rescinded. Litigation continues with respect to the Memorandum. 

On February 7, NIH issued Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates, announcing its new policy of imposing a 15% indirect cost rate cap for all new and current grants after February 10, 2025. On February 10, the Massachusetts Attorney General, in conjunction with 21 other states, filed suit in federal court to block implementation of the recent guidance from the National Institutes of Health (NIH) targeting a reduction in indirect cost recovery rate (IDC). Separately, the Association of American Medical Colleges (AAMC) and several co-plaintiffs (PDF), as well as the American Council on Education (ACE), the Association of American Universities (AAU), and the Association of Public and Land-grant Universities (APLU), along with named research universities (PDF), also filed suit to stop implementation of the guidance. As part of the ACE lawsuit, Harvard University, alongside other affected institutions, filed a declaration (PDF) outlining the impact that the proposed change would have on research. On the evening of February 10, the U.S. District Court issued temporary restraining orders (TROs) for the Commonwealth of Massachusetts et al. and AAMC et al. cases blocking for now the implementation of the proposed changes, with further consideration of the legal issues at hearings in the coming days and weeks.

Agency Guidance

Please find agency guidance and communications related to recent White House Executive Orders:

• U.S. Department of Agriculture (USDA)
  • 1/23/2025: NIFA Notice: Funding Opportunities Under Review
  • 1/21/2025: Memorandum: Hiring, Regulatory and Obligation of Funding Moratoriums (PDF)
    
    
• Centers for Disease Control and Prevention (CDC)
  • 1/31/2025: Memorandum: Cease Gender Ideology Activities on CDC Awards (PDF)
  • 1/29/2025: Cease DEI Activities on CDC Awards (PDF)
    
    
• Department of Defense (DOD)
  • 1/28/2025: Notice: Department of Defense Statement Clarifying Defense Contracting
    
    
• Department of Education (ED)
  • 1/23/2025: News Release: U.S. Department of Education Takes Action to Eliminate DEI
    
    
• Department of Energy (DOE)
  • 1/31/2025: Letter: Final SC DEI CBP.PIER J40 Suspension Letter MN 1.31.25 (PDF)
  • 1/28/2025: Memorandum: Executive Order Update to PIER Plan Requirement
  • 1/27/25: Memorandum to Cease all activities associated with DEI and CBP (PDF)
  • 1/20/2025: Agency-wide Review of Program and Administrative Activities (PDF)
    
    
• Department of Health and Human Services (DHHS)
  • 1/21/2025: Letter: Immediate Pause on Issuing Documents and Public Communication-ACTION (PDF)
    
    
• Department of Justice (DOJ)
  • No information available
    
    
• Department of Labor (DOL)
  • 1/22/2025: Immediate Implementation of Executive Orders (PDF)
    
    
• U.S. Government Services Administration (GSA)
  • 1/24/2025: Acquisition Pause (PDF)
  • 1/22/2025: Contractor Notice re Implementation of Executive Order (PDF)
    
    
• National Aeronautics and Space Administration (NASA)
  • 2/6/2025: Initial Guidance Regarding Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government Executive Order (PDF)
  • 1/23/2025: Memorandum: Initial Guidance Regarding Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders (PDF)
  • 1/6/2025: Message to the NASA Grantee Community
  • NASA Amendment 109: Removing DEIA Requirements from ROSES 2024
    
    
• National Institutes of Health (NIH)
  • 2/7/2025: Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (see Recent Updates section for more information) 
    
    
• National Science Foundation (NSF)
  • 1/28/25: NSF Implementation of Recent Executive Orders
    
    
• United States Agency for International Development (USAID)
  • 1/24/2025: Notice on Implementation of Executive Order on Reevaluating and Realigning United States Foreign Aid (PDF)
    
    
• Other Resources
  • Council on Governmental Relations (COGR): 2025 Administration Transition Information & Resources page 
  • 10/24/2017: Harvard Medical School video: The NIH and the Need for Funding Facilities and Administration Costs 
  • Association of American Medical Colleges:  
    • Facilities & Administrative Costs 
    • Facilities & Administrative (F&A) Costs of Research Fact Sheet