COGR's F&A Cost Reimbursement Materials & Resources
Agency Notices & Communications
- Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates (NOT-OD-25-068)
- NIH Indirect Costs Policy for Research Grants: Recent Developments (Congressional Research Service)
Litigation
- Commonwealth of Massachusetts v. National Institutes of Health
- Docket No. 1:25-cv-10338
- District Ct., D. Massachusetts
- Filed Feb. 10, 2025
- See Feb. 10, 2025, Complaint alleging that 15% rate cap violates APA and seeking TRO.
- See Feb. 10, 2025, Order granting TRO applicable to plaintiff states.
- Court combined this suit with AAU and AAMC suits listed below for argument. Hearing was held Feb. 21, 2025, and court extended TRO until it makes decision re. grant of a preliminary injunction.
- See Mar. 5, 2025, Memorandum and Order granting a preliminary injunction that enjoins the defendants from “taking any steps to implement, apply, or enforce the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect costs Rates (NOT-OD-25-068) in any form with respect to institutions nationwide.
- Association of American Universities v. Department of Health & Human Services
- Docket Number 1:25-cv-10346
- District Ct., D. Massachusetts
- Filed Feb. 10, 2024
- See Feb. 10, 2025, Complaint alleging that 15% cap violates APA. [NOTE: Court did not grant TRO in this case because one was in place in AAMC case listed below. Court combined AAU, AAMC and Commonwealth of Mass. cases for argument on Feb. 21, 2025].
- Hearing was held Feb. 21, 2025, and court extended TRO until it makes decision re. grant of a preliminary injunction.
- See Mar. 5, 2025, Memorandum and Order granting a preliminary injunction that enjoins the defendants from “taking any steps to implement, apply, or enforce the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect costs Rates (NOT-OD-25-068) in any form with respect to institutions nationwide.
- Association of American Medical Colleges v. National Institutes of Health
- Docket No. 1:25-cv-10340
- District Ct., D. Massachusetts
- Filed Feb. 10, 2025
- See Feb. 10, 2025, Complaint alleging 15% cap violates APA, exceeds NIH statutory authority, violates due process and statutory and constitutional prohibitions on retroactivity.
- See Feb. 10, 2025, Order granting nationwide TRO.
- Court combined this suit with Commonwealth of Mass. and AAU suits listed above for argument. Hearing was held Feb. 21, 2025, and court extended TRO until it makes decision re. grant of a preliminary injunction.
- See Mar. 5, 2025, Memorandum and Order granting a preliminary injunction that enjoins the defendants from “taking any steps to implement, apply, or enforce the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect costs Rates (NOT-OD-25-068) in any form with respect to institutions nationwide.
Institutional Communications
- Update on NIH indirect cost rate cap (University of Michigan)
- UW–Madison responds to NIH announcement about indirect cost cap
- Information on changes to National Institutes of Health indirect cost rates: Feb. 8, 2025 (Case Western Reserve University)
- OVCR Update on Federal Funding Programs, Feb. 8 (University of North Carolina Chapel Hill)
- Recent Announcement Capping Facilities and Administration Cost Recovery from NIH (Temple University)
- NIH Update (Columbia University)
- NIH Indirect Cost Rate (University of Rochester)
- Update on NIH Funding (Northwestern University)
Articles
- How Trump’s Medical Research Cuts Would Hit Colleges and Hospitals in Every State (New York Times)
- Here’s how big a hit some universities may take if NIH slashes support for indirect research costs (STAT)
