Interim Guidance on Support for Research
Northwestern has experienced significant interruptions in federal funding due to a federal freeze on major portions of our research portfolio. The University, with support from the Board of Trustees, will support research affected by the freeze on an interim basis. While the overall impact and duration of the reported freeze is unclear, the University will support research activities that are affected. This document sets forth the guidance on providing this interim support. The intent is to allow research to continue during a period of federal funding uncertainty, while managing financial exposure to Northwestern. Questions may be directed to SponsoredResearch@northwestern.edu.
If allowable, all expenses incurred during this interim funding period will be billed to the federal awards after the freeze is lifted.
Guidance Procedures
1. Qualifying Projects
This guidance applies to the following federally funded projects that have not passed their end date:
- Grants that are under a stop-work order
- Grants that are pending a notice of award for subsequent year funding (non-competitive renewal)
- Grants for which federal reimbursements have not been received. Currently, this includes all awards from the National Institutes of Health (NIH).
This action is intended as a “bridge” to keep research going during this interim period of uncertainty while we seek further information and use it to develop longer-term plans. Projects that have received terminations are not eligible, nor are those managed by faculty who have left the University. This support may also be available under select conditions when there is clear evidence that a new award will be given, and funds are critical for maintaining existing personnel. Further details are below.
Project Investigators (PIs) may have multiple awards supported by interim funds. The intent is to continue active federal awards subject to stop-work orders or delayed continuations.
2. Accessing Interim Support
No special requests are needed for awards that qualify. PIs may continue to post charges to existing chart strings until further notice. See below for allowable expenses.
3. Processing Interim Support
Existing grant chart strings subject to stop-work orders or with a delayed continuation are modified by central administration to ensure expenses are not billed to the sponsor. This designation is retroactive to the date work was stopped.
No change is made to the chart strings of active awards that cannot currently be reimbursed; in the absence of a formal notice to stop work, we are operating under the assumption that PIs are obligated to complete the work for which funding has been approved.
4. Allowable Expenses
The annual spending rate is limited to that in the current year of the anticipated award budget. Costs should be managed below that amount per the following guidelines. Expenditures for all projects are monitored monthly to determine overall exposure to the University and to allow decisions about financial sustainability. PIs should minimize expenses to extend the duration that interim support is available.
Expenses that are allowed include:
- Personnel Salary – continued payment of existing personnel who are necessary for the project, only up to the amount budgeted in the grant and consistent with previous spending. This includes students, postdocs, technicians, research faculty and other staff. Faculty salary is permitted up to the amount budgeted in the grant and consistent with previous spending. For faculty with nine-month appointments, only summer salary is allowed, up to the amount budgeted and consistent with previous spending.
- Supplies – essential supplies necessary to continue the research.
- Equipment – under $5K for items that are critical to conduct the research.
- Travel – only if critical to conduct research at an offsite location and budgeted in the award.
- Tuition – as budgeted on the grant award
- Core Facility Charges – if necessary for the project
- Animal Charges
5. Unallowable Expenses
The following expenses are not allowed during the interim support period. For rare exceptions, please consult with your school’s Associate Dean for Research.
- Academic year salary for faculty with nine-month appointments
- New Personnel – support is intended for existing personnel only
- Travel for speaking engagements, presentations, training, conferences, etc.
- Equipment over $5K
- Subawards – not allowed for grants under a stop-work order or pending a notice of award for subsequent year funding. Implementation guidance coming soon for active NIH awards.
6. Duration of Support
University leadership will partner with the Board of Trustees to monitor expenses regularly and assess financial risk. As the University gains more information about the scope and impact of the federal funding freeze, this information will be used to determine the scale and duration of support. We aim to provide at least one month’s notice of any significant changes to the current support plan.
7. New Awards That May be Eligible for Support
New awards delayed by the federal transition may be considered for interim support under the following conditions. All assessments will be made on a case-by-case basis.
- Documentation about the intent to fund is available from the funding agency.
- Funds are necessary for maintaining existing research programs and staff; no new hires will be allowed.
- Other funds are not available to bridge the research program.
8. Exceptions
These interim guidelines are intended to provide guidance regarding the support of research impacted by stop-work orders, delays or NIH awards that are currently not receiving reimbursement. School leadership’s input is expected when circumstances arise that are beyond what is outlined in these guidelines. We recognize that each project is unique and will consider necessary exceptions supported by school leadership though it is expected that exceptions will be granted rarely. Exception requests should be sent to the school’s Associate Dean for Research.