Research-related Updates (August 2025)
[Message to WFU Research Google Group]
Dear Reynolda Campus Research Community,
I hope that you’ve all had a rejuvenating and productive summer!
As you may know, there has been a lot of news about federal changes to research policy over the summer. The outcomes of many of those proposed changes are still either in litigation or negotiation, and I will continue to keep you apprised if there are finalized changes that impact our community.
To begin, you are likely aware that there are a number of changes that are affecting our graduate students and some of our undergraduates related to VISA issues. Please contact ISS with any questions.
In addition, there is one substantive change that will have an immediate impact on new NSF grant funding accounting and all the activities that IDC supports for our faculty, departments, library, and ORSP, amongst others. As you know, there have been ongoing efforts to reduce the federal indirect cost rate (IDC) to 15%. These efforts have been halted by the courts, and the issue of IDC is now being addressed in the federal appropriations process. However, starting in mid-June, new language appeared in the NSF notice of award (pasted below and linked here) that indicates that they will claw back a large proportion of IDC from the start of the award if a court decision permits the currently vacated 15% IDC policy. Because we cannot return funds to NSF after they are spent, the Research Administration and Finance teams have developed a process to move the at-risk IDC into a contingency fund for the duration of the award (or until this stipulation is rescinded). Currently, this contingency fund allocation will be applied only to new NSF awards with the new award language. IDC funds will continue to be distributed on a proportional basis as in the past, but the total amount of IDC funds distributed will be much lower for new NSF awards (only up to the 15% level that is not at-risk of clawback). If the court decisions are ultimately favorable to universities, these funds will be moved out of contingency and distributed as usual.
We do hope there is a resolution soon regarding how indirect costs will be reimbursed in the future. As soon as we have information, we will let you know and move as quickly as possible to distribute the contingency funds accordingly. In the meantime, we will continue to identify ways to support faculty research and scholarship to the best of our ability despite these federal changes.
Rebecca Alexander and I will be visiting many of your departmental faculty meetings this fall, and can field questions about this new policy at that time. If you have a grant that is affected (there is only one at this time), or are unclear whether your grant is affected, please don’t hesitate to reach out to either Lori Gabriel or me.
Best wishes,
Kim
Relevant text copied from NSF NOAs:
Recipient is hereby notified of proceedings and resulting stay in Case No. 1:25-cv-11231 in the United States District Court for the District of Massachusetts. In accordance with the court’s order dated May 19, 2025, NSF is temporarily staying effectuation of Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034). If a court decision permits application of the policy, NSF may unilaterally modify the terms and conditions of this award to impose the Award Specific FATC set forth below, which shall be applicable to the entire duration of the award. NSF may take such unilateral action by notifying the recipient via email or other written communication. In no event shall NSF unilaterally modify this award to impose an indirect cost rate limitation of less than 15 percent of the modified total direct cost base (MTDC). If a court decision permits application of the policy, in accordance with Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034), reimbursement of indirect costs for this award must not exceed 15 percent of the modified total direct cost base (MTDC), regardless of whether the recipient has a current Federal negotiated indirect cost rate. The recipient must use a rate no greater than 15 percent of MTDC, as defined in 2 CFR § 200.1, for the life of the award, including the award period prior to notification of the application of this term. Excess indirect costs charged to an NSF grant due to use of an incorrect rate will be disallowed. This term and condition supersedes any previously submitted and/or approved budget.
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A. Kimberley McAllister, Ph.D.
Vice Provost for Research, Scholarly Inquiry and Creative Activity