Updates on Federally Sponsored Programs – May 8, 2025
NIH NCEs Processed as Prior Approvals
Per National Institutes of Health (NIH) Notice NOT-OD-25-110, the No Cost Extension (NCE) request link is unavailable in eRA Commons. At this time, all requests for NCEs must be submitted as a prior approval request in eRA Commons, for NIH review and approval.
As a reminder, prior approval NCEs should be submitted according to established internal processes and prior to the project end dates. Campus should download and complete the OSP Prior Approval Request form to request prior approval NCEs as soon as possible. This will allow OSP time to review and confirm processing of the NCE.
NIH Foreign Subawards Update
NIH has released guidance on Notice NOT-OD-25-104, which updated NIH policies and practices utilizing foreign subawards.
Effective May 1, 2025, NIH will:
- Not issue awards to entities with foreign subawards.
- Notapprove requests to add new foreign components/subawards on existing awards
- Renegotiate awards to remove foreign subawards or rebudget funds when the work can be performed domestically.
- Negotiate bilateral termination if the project is unviable without the foreign subaward.
This will be a temporary pause for foreign subawards while NIH finalizes the implementation of the new award structure (expected no later than September 30, 2025). Beginning with the next award cycle, NIH-funded research involving foreign subawards must be structured as subprojects directly linked to the prime award. Foreign subawards may not be nested under the parent grant.
Indirect Cost Rate Reminder
Proposal Submissions
All proposals, regardless of the sponsor, will be submitted in accordance with UNC-CH’s active negotiated indirect (F&A) cost rate agreement. Funding decorative imageopportunities that prohibit the application of institutional negotiated F&A rates should be brought to the attention of the Proposal Specialist in OSP or the School of Medicine Sponsored Programs Office (SOMSPO), reviewing the RAMSeS internal processing form (IPF). Proposals for programs such as fellowships and training grants will continue to be submitted in accordance with the rates established for those programs.
New Awards
The expectation is that all new awards, regardless of the sponsor, should be received at the appropriate rate based on UNC-CH’s active indirect rate agreement or program-specific policy. If new awards are received with rates other than those proposed, OSP will contact the sponsors to make the necessary corrections.
Existing Awards
Departments and Principal Investigators (Dept/PIs) should continue project activities and incur associated expenses on active awards.
Stop-Work, Termination, and Appeal Reminders
If Dept/PIs receive notices for actions such as stop work, pause, or terminations on active awards, they should provide the communication to SponsoredPrograms@unc.edu. OSP will review the notice and provide instructions to the research team and subrecipients. It is crucial that all correspondence and documentation related to a stop-work, or termination be sent to OSP immediately to ensure timely review and action.
- For guidance on appealing a termination, please refer to the OSP Appeal Process for Award Terminations.
- OSP Stop-Work & Termination Guidance webpage is coming soon.
OVCR Resources
The Office of the Vice Chancellor for Research (OVCR) offers resources to stay updated with the swiftly changing Federal guidelines and requirements.