2025 Federal Administration Transition Guidance

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Guidance on Federally Funded Projects during Administration Transition

04/02/25: Communication from Senior Vice Provost, Research, Economic Engagement and Outreach. 

Frequently Asked Questions

GUIDANCE

Proposals

  • Submission: Proposal submissions will continue as long as federal agency systems remain operational.
  • Review Timelines: Expect potential delays in sponsor proposal reviews as federal agencies address pauses in federal assistance funding for certain areas.
  • At-Risk Accounts: Activation of not-fully executed (NFE) accounts for pending federal awards is not recommended.
  • Action Items:
    • Reconfirm proposal deadlines to account for potential changes.
    • Verify that funding announcements have not been revised or postponed.
    • Sign up for agency or sponsor alerts when possible.

Awards

  • Terms and Conditions: Executed award terms remain enforceable while active, including invoicing and reimbursements.      We anticipate updates to award Research Compliance requirements. These changes could either be implemented directly by a federal agency or sponsor or may require an amendment on a project-by-project basis. We will share any information we receive with you, though you may also receive instructions directly from your Program Officer. It is crucial to act swiftly to ensure compliance with any new requirements, as failure to do so could jeopardize funding. 
  • Research Compliance Updates: Anticipate updates to compliance requirements, possibly necessitating project-specific amendments. Swift compliance is critical to maintain funding.
    • For Export Control Matters and Foreign Travel/Collaboration Considerations Contact Victor Sosa at Victor.Sosa@unh.edu
    • For Human Subject, Animal Research, Conflict in Interest in Research and Responsible Conduct in Research Matters: Contact Julie Simpson at Julie.simpson@unh.edu
  • Reporting Requirements: Updates may occur, requiring swift adaptation to avoid jeopardizing funding. If you need assistance, please contact your STAR GCA.
  • Funding Adjustments:
    • Programs may experience restructuring, delays, or potential defunding.
    • Further guidance will be provided when available.
    • Avoid extending At-Risk status unless the project’s objectives are in significant jeopardy.

Action Items:

  1. Evaluate your grant activities to ensure compliance with the executive orders.
  2. If you are unclear about whether your funded activities conflict with the executive orders, consult with your program office.
  3. Be conservative about large expenditures but continue activities necessary to meet contractual obligations.
  4. Monitor budget balances to avoid deficits while awaiting future funding obligations.
  5. Maintain communication with program officers for updates.
  6. Submit any overdue technical reports or deliverables promptly.
  7. Monitor agency announcements for funding or compliance updates.

Events/Meetings:

  • If an event has been scheduled and can no longer take place, quickly inform all stakeholders — including participants, speakers, and organizers—about the cancellation or postponement.

Procurement Guidance

When conducting procurement for federally funded projects, consider the following:

  • Funding Confirmation: If federal funds have not been obligated, consider delaying or canceling procurement.
  • Agreement Terms: Review current agreements for cancellation clauses and payment milestones. For questions, contact SPA awards at spa.awards@unh.edu.
  • Quotes: Obtain quotes with the country of origin and a validity period to ensure stable pricing.
  • Obligated Funds: Procure equipment or materials using currently available funds.
  • Policy Awareness: Verify funding availability and monitor policy changes impacting projects.

Subaward Guidance

When an award is signed, the federal agency designates a portion of the total approved budget as obligated funds. UNH, as the recipient, is authorized to incur expenses up to the obligated amount, and these expenses will be reimbursed. Any expenses that fall within the scope of the award and are covered by obligated funds will be reimbursed. However, any future expenses exceeding the current obligation will not be reimbursed.

The same principles apply to subawards. When an award is signed, the federal agency allocates a portion of the total approved budget as obligated funds. UNH, as the recipient, may authorize subawardees to incur expenses up to the obligated amount, which will be reimbursed.

Any expenses incurred by subawardees that fall within the scope of the subaward and are covered by obligated funds will be reimbursed.

Subawards will be modified by SPA as required by our federal sponsor.  Questions may be directed to Jeff Cosier at Jeffrey.cosier@unh.edu

Stop Work Order

A Stop Work Order is an official directive from the federal government to temporarily or permanently cease all activities related to a grant.

This is distinct from agency-specific notices, memos, or modifications tied to presidential executive orders. Such notices may require recipients to halt DEI-related activities (or other specified changes) by modifying the terms and conditions of the award while permitting other project activities to proceed.

These notices necessitate a thorough review of project activities and personnel funded by the grant. The Principal Investigator (PI), department, Dean’s office, SPA, and other stakeholders must collaborate to evaluate the impact on any project impacted.

Executive Actions and Federal Agency Guidance

  • Presidential Actions:
    • Executive Orders carry the force of law for government operations.
    • Proclamations are formal, often symbolic statements.
    • Memorandums provide policy guidance, less formal than Executive Orders.

As federal agencies issue official guidance and updates, additional sections will be added below.

COGR Communications & Resources

Executive Orders & Related Resources

Executive Order Overview & Tracker (Akin Gump)  

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