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Update: NIH Subcontracts, Continuations, and Interim Guidance Amid Funding Freeze

As the federal funding freeze continues to impact Northwestern, Sponsored Research has several updates to share with the research community.

NIH Subcontracts Under a Stop-Work Order

Sponsored Research will send a communication this week to those subsites that received a stop-work order in June, confirming that a pause on subaward reimbursements will remain in place until further notice. The email will explain the June stop-work order was issued to ensure subawardees understood that Northwestern had not received reimbursement from the National Institutes of Health (NIH) since March 2025, and that while these conditions continued, Northwestern would not be able to reimburse subawardees for expenses incurred after June 20, 2025. The email will further clarify that institutions may continue to perform work at their own risk and in accordance with their own policies and procedures. Northwestern will not reimburse costs incurred beyond June 20, 2025, unless and until NIH fully reimburses Northwestern for those expenses, which is not guaranteed. Principal Investigators were informed on Monday, August 25, that the pause on NIH subawardee reimbursements remains in effect.

NIH Subcontracts Granted an Exception

Subsites granted an exception by their school dean’s office will remain exempt from the stop-work order and will continue to be reimbursed by Northwestern. These subaward exceptions will be processed through the issuance of a federal subcontract, following standard procedures, once the notice of award is received.

Delayed Continuations

As NIH has resumed issuing notices of award, we anticipate that most if not all delayed continuations will be received. Sponsored Research is currently extending the end dates for these continuations from August 31, 2025, to October 31, 2025. This process is expected to be completed by early September and is subject to change.

Interim Guidance

While NIH continues to withhold reimbursements to Northwestern, the interim guidance issued by the Vice President for Research and Chief Financial Officer remains in effect. Please note that some schools have implemented additional restrictions. Be sure to consult any school-specific guidance that may apply to your sponsored awards.

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