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Research and Sponsored Programs

Federal Funding Updates

From your CSU Office of Federal Relations team on the ground in DC, supporting our CSU community in federal legislative and executive actions affecting higher education.

In the final days before Congress adjourned for its annual summer recess, legislative activity intensified in Washington. House and Senate Republicans reached agreement on a reconciliation bill and approved a rescissions package that withdraws $9 billion in Fiscal Year 2025 federal funding, primarily affecting U.S. foreign aid programs and the Corporation for Public Broadcasting. This action, along with continued discussions of additional rescissions and potential funding freezes across federal agencies, raises significant concerns about Congress’s ability to achieve a bipartisan funding agreement for Fiscal Year 2026, which must be finalized by the end of September. The Office of Federal Relations remains actively engaged in advocating for sustained and robust federal support for all CSU priorities and will provide a comprehensive update in early September. Read the complete update online.

Updates to NSF Research Security Policies: The U.S. National Science Foundation (NSF) is committed to supporting the research community in safeguarding U.S. science and engineering through clear, actionable research security policies. In alignment with the CHIPS and Science Act of 2022 (P.L. 117-167) and National Security Presidential Memorandum-33 (NSPM-33), NSF has established a series of requirements to strengthen transparency and accountability across NSF-funded projects. In close partnership with NSF awardee organizations, these efforts are bearing fruit, with increased awareness of the risks, improved understanding of expectations, and a strengthened sense of shared responsibility, to name a few. But our work is not done. I request your continued partnership as NSF redoubles its efforts to advance research security.

In our ongoing work to ensure NSF-funded projects are free of malign foreign interference and misappropriation, NSF is taking the following steps. These policy updates were developed pursuant to Congressional mandates and Executive Orders and have been refined with extensive stakeholder input.

1. Research Security Assessment and Required Recipient Documentation – Effective October 10, 2025
NSF reserves the right to perform risk assessments, using analytical tools, of proposals and awards submitted to the Foundation to assess nondisclosures of required information from senior/key personnel, and establish other policies and procedures for identifying, communicating, and addressing security risks that may threaten the integrity of Foundation-supported research and development.

NSF proposers and recipients are required to maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior/key personnel that must be available to NSF upon request. Proposers and recipients are expected to review requested supporting documentation for compliance with NSF award terms and conditions.


2. Research Security Training – Effective October 10, 2025
NSF requires research security training certifications from proposers and individuals identified as senior/key personnel by the proposer. Proposers may utilize any training that addresses cybersecurity, international collaboration, foreign interference, and rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest.1 NSF, in partnership with the National Institutes of Health (NIH), the Department of Energy (DOE) and the Department of Defense (DOD), have provided four online research security training (RST) modules as a resource to awardee organizations. Subsequently, the SECURE Center developed an updated and condensed version of the four modules. The condensed RST module is designed to meet the government-wide RST requirement in Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234). To that end, NSF, NIH, DOE, and DOD all recognize completion of the condensed module as compliant with their respective RST requirements.

Research Security Training Requirement for Federal Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), each individual identified as a senior/key person must certify that they have completed the requisite research security training that meets the requirements specified in Item 2 of Important Notice No. 149 within 12 months prior to proposal submission.

Certification Regarding Research Security Training for Federal Research Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), the Authorized Organizational Representative (AOR) must certify that all individuals identified as senior/key personnel have completed the requisite research security training that meets the requirements specified in Item 2 of Important Notice No. 149 within 12 months prior to proposal submission.
Certification Regarding Responsible and Ethical Conduct of Research (RECR) (Applies to Institutions of Higher Education Only): The AOR is required to complete a certification that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, postdoctoral scholars, faculty, and other senior/key personnel who will be supported by NSF to conduct research and that such training addresses mentor training and mentorship, training to raise awareness of potential research security threats, and Federal export control, disclosure, and reporting requirements.


3. Malign Foreign Talent Recruitment Program Prohibition – In Effect
Individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after May 20, 2024.


4. Malign Foreign Talent Recruitment Program Certification – In Effect
NSF requires MFTRP certifications from proposers and individuals identified as senior/key personnel.

Pre-Award Certifications:In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), the AOR must certify that all individuals identified as senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.
In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), each individual identified as a senior/key person must certify that they are not a party to a malign foreign talent recruitment program.
Post-award Certification: 

Individuals serving as a Principal Investigator (PI) or co-PI on an active NSF award made on or after May 20, 2024, must certify annually via Research.gov to their participation or non-participation in an MFTRP.2 Additional information regarding the annual certification process can be found at nsf.gov/research-security.

5. Foreign Financial Disclosure Reporting (FFDR) – In Effect
In accordance with Section 10339B, Foreign Financial Support, of the CHIPS and Science Act of 2022 (42 U.S.C. § 19040) each “recipient institution of higher education” must annually report all “current financial support, the value of which is $50,000 or more3, including gifts4 and contracts5, received directly or indirectly from a foreign source” which is “associated with a foreign country of concern.”6

Applicability: This requirement applies only to direct recipients of NSF funding. The determination of a direct recipient of NSF funding is based on the entity receiving NSF awards through its own Unique Entity Identifier (UEI). Satellite, branch or regional campuses that are not direct recipients of NSF funding must report any financial support via the main campus of the institution of higher education (IHE). This does not include entities that receive subawards or individuals that are the beneficiaries of the award.

Per Section 10339B(a) (42 U.S.C. § 19040(a)), the report also must include financial support received by “a foundation of the institution, and related entities such as any educational, cultural, or language entity.”7 Also, financial support received from or contracts with an “agent” of a foreign source associated with a foreign country of concern are reportable. NSF is aware that the stated purpose and/or function of some legal entities (for example, as articulated in articles of incorporation) is to serve as an intermediary8 for foreign source gifts to or contracts with an institution. Allowing foreign sources and institutions to avoid disclosure by using intermediaries to transfer funds and benefit would be contrary to the plain statutory language, context, and purpose of 42 U.S.C. § 19040. Therefore, foreign source financial support comprised of gifts to or contracts with an intermediary that benefit an institution is reportable.

Financial support is attributable to the country of citizenship, or if unknown, the principal residence for a foreign source who is a natural person, and the country of incorporation/establishment, or if unknown, the principal place of business, for a foreign source which is a legal entity.

Tuition: Tuition payments for a specific student(s) are excluded from the reporting requirement (e.g., parent payment for child/children or other relatives). However, if tuition payment is received from a foreign source in the form of a grant, scholarship, or other form of financial aid, the payment is reportable when the cumulative threshold is $50,000 or more per foreign source.
Reporting Period and Record Retention Requirements: The report will cover the reporting period from July 1, 2024, through June 30, 2025. To provide sufficient time for finalization and submission of the requisite information, the FFDR reporting portal on Research.gov will open for report submissions September 1, 2025, and the report must be submitted by October 31, 2025.

Subsequent years’ reporting periods will run from July 1 of the previous year to June 30 of the reporting year. Negative reports are required to be submitted. The institution must maintain a copy of the relevant records subject to the disclosure requirement until the latest of–the date that is four years after the gift or contract agreement;
the date on which the gift or contract agreement terminates; or
the last day of any period that applicable State public record law requires a copy of such gift or contract agreement to be maintained.

Copies of Contracts, Agreements, or Documentation: Upon review of a submitted disclosure, NSF may request that copies be submitted of any contracts, agreements, or documentation of financial transactions associated with disclosures submitted under this section.

Award Term: Each NSF award includes as part of the award general terms and conditions a term and condition that implements the annual reporting requirement specified in Item 5 of NSF Important Notice No. 149.
Public Release of FFDR Disclosures: While it is NSF’s intention to make public the information provided or collected in the FFDR disclosures, certain data elements will be treated as confidential to the extent required or permitted under applicable Federal law. A listing of the updated data elements for the 2024-2025 reporting period may be found here.

6. Certification Regarding IHEs Hosting or Supporting Confucius Institutes9, 10 – Effective October 10, 2025
In accordance with Section 10339A of the CHIPS and Science Act of 2022 (42 U.S.C. § 19039), no NSF funds may be awarded to an IHE that maintains a contract or agreement between the institution and a Confucius Institute. The NSF Director, after consultation with the National Academies, may issue a waiver for an IHE that maintains such a contract or agreement between the institution and a Confucius Institute if such contract or agreement includes clear provisions that:

  • protect academic freedom at the institution;
  • prohibit the application of any foreign law on any campus of the institution;
  • grant full managerial authority of the Confucius Institute to the institution including full control over what is being taught, the activities carried out, the research awards that are made, and who is employed at the Confucius Institute; and
  • prohibit co-location with the institution's Chinese language, history, and cultural programs and require separate promotional materials.

  • Waiver: An IHE may submit a request for a waiver or a waiver renewal that includes a description of the Confucius Institute, including at a minimum how the contract or agreement provisions satisfy each of the four criteria above. Waiver requests must be sent to NSF at researchsecurity@nsf.gov.

NSF encourages consideration of the following reports by the National Academies in preparing waiver requests: Confucius Institutes at U.S. Institutions of Higher Education: Waiver Criteria for the Department of Defense and Foreign-Funded Language and Culture Institutes at U.S. Institutions of Higher Education: Practices to Assess and Mitigate Risk. An IHE not granted a waiver will be provided a written explanation of the reason(s) for the denial.

Certification Regarding IHEs Hosting or Supporting Confucius Institutes: In compliance with Section 10339A of the CHIPS and Science Act of 2022 (42 U.S.C. § 19039), the AOR must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.

NSF cannot achieve its mission without the contributions and world-class talent of the U.S. research community. Science holds enormous promise for solving our most pressing challenges and it is through this lens that the importance of safeguarding research comes into focus.

As stewards of precious public funding, we must ensure it is the American people who benefit from their investments and trust in us. I thank you for your leadership in this effort.

Brian Stone
Chief of Staff, Performing the duties of the NSF Director

From the CSU Office of Federal Relations team on the ground in DC, supporting our CSU community in federal legislative and executive actions affecting higher education:

Congress passed President Trump's signature legislative request, "One Big Beautiful Bill", which included additional funding for the Departments of Homeland Security and Defense with massive cuts to Medicaid and social safety-net programs like the Supplemental Nutrition Assistance Program (SNAP). While the bill was not as detrimental to the California State University (CSU) as the House-passed version, there are a few provisions that will impact our students and their families and the CSU. The bill also raised the U.S. debt limit for two years, filled the Pell Grant shortfall, and revokes climate change focused tax credits. Read the complete update online.

From the CSU Office of Federal Relations team on the ground in DC, supporting our CSU community in federal legislative and executive actions affecting higher education:

Over the past two weeks, the CSU and higher education across the country has faced a continual wave of significant federal developments. The Trump administration proposed deep cuts to student aid, including reductions to Pell Grants, TRIO, and Federal Work-Study, sparking concern about college affordability. Congress took additional steps towards reconciliation and rescinding appropriations from the current fiscal year. Additionally, legal action was filed by the state of Tennessee challenging federal grants for Hispanic-Serving Institutions. Immigration policy changes, including renewed travel bans and visa restrictions, continue to raise alarms about declining international student enrollment and imperiling our nation's position as the global leader in higher education, research, and scholarship. Read the complete update online.

Dear Colleagues,

We want to make you aware of a significant development affecting our research community. Unfortunately, we received notices today of four NSF grant terminations. These are part of a broader trend across U.S. institutions.

The CSU Chancellor’s Office (CO) and campus Chief Research Officers (CROs) are coordinating a systemwide response in collaboration with the Office of General Counsel (OGC) and Government Relations. Below is a summary of how the CSU system is responding and how you can help.

1. State-Level Legal Action

  • The State of California, not individual CSU campuses or research foundations, is pursuing legal action in response to certain terminations (e.g., from NIH).
  • The CSU is supporting the Attorney General's efforts by collecting termination data from all CSU and UC campuses.
    We are not pursuing separate legal filings, as this could interfere with coordinated strategies at the state level.

Faculty Action Needed:
If you receive a termination notice or any related communication, please forward it immediately to: orsp@mail.fresnostate.edu or jbush@mail.fresnostate.edu

We are compiling program details into a shared CSU/UC tracker that supports the Attorney General’s case. You may be asked to provide brief statements about your program’s success and the impact of termination—this information is typically found in your annual reports or evaluations.

2. Administrative Appeals to NSF

In addition to legal channels, Principal Investigators (PIs) can submit administrative appeals directly to the funding agency.

  • The OGC has provided a template for these appeals.
  • Appeals must be submitted within 30 days of the termination notice.
  • These are fact-based statements focusing on:
  • Program importance
  • Student and community benefit
  • Harm caused by termination

Please avoid politicized or inflammatory language in these appeals. The focus should remain on program outcomes and positive impact.

3. New NSF Indirect Cost Policy

We have also been notified that a 15% indirect cost cap will apply to all new NSF awards made on or after May 5, 2025. We anticipate a legal challenge from state attorneys general in response.We recognize how disruptive these developments are and are committed to supporting you through them. Our office will continue to share updates and guidance as we receive them.

If you have questions or need assistance preparing documentation or appeals, please don’t hesitate to reach out.

Sincerely,
Office of Research and Sponsored Programs

CSU Federal Updates Webpage: During a time marked by significant changes to existing federal policies, the California State University is working diligently to assess the impacts to the institution and its students, employees and programs.

Although the federal policy landscape continues to evolve, the CSU remains committed to fulfilling its core mission: bringing the life-changing benefits of a Cal State degree to students from all backgrounds and walks of life, and ensuring the safety and well-being of all of its students and employees.

​The latest resources and updates on a variety of federal issues that impact the CSU -- including information on "Protecting Research Funding" -- can be found online. ​

Dear Fresno State Research Community,

We're sharing some important updates on funding freezes coming from various sources. 

1. NIH Research cuts: https://www.reuters.com/business/healthcare-pharmaceuticals/us-judge-bars-trump-administration-cutting-nih-research-funding-2025-03-05/

2. Bringing to your attention that California Attorney General Rob Bonta today secured a decision by the U.S. District Court for the District of Rhode Island preventing the Trump Administration from implementing a sweeping federal funding freeze while litigation continues. Attorney General Bonta led a coalition of 23 attorneys general in filing a lawsuit to block the funding freeze last month. A copy of the preliminary injunction is available here.

Attorney General Bonta Secures Preliminary Injunction Against Trump Administration Blocking Harmful Federal Funding Freeze

If allowed to go into effect, the federal funding freeze would have threatened hundreds of billions of dollars in California annually, including vital public safety, healthcare, childcare, and infrastructure funding, and other essential services

California Attorney General Rob Bonta today secured a decision by the U.S. District Court for the District of Rhode Island preventing the Trump Administration from implementing a sweeping federal funding freeze while litigation continues. The Court finds that the states are likely to succeed in their claims that the Trump Administration violated the Administrative Procedure Act by freezing funds in contravention of underlying appropriations statutes and that their actions were arbitrary and capricious. The Court specifically notes that the Trump Administration has failed to rebut the harms that the states have presented, including to the states’ most vulnerable residents. These include the potential impacts to services that increase workplace health and safety, water quality, critical transportation infrastructure, and law enforcement and public safety, as well as programs such as Head Start, education services for students with disabilities, and research projects at state universities. Attorney General Bonta led a coalition of 23 attorneys general in filing a lawsuit to block the funding freeze last month. 

“Last month, the Trump Administration chaotically implemented a sweeping federal funding freeze, halting access to billions of dollars in funds lawfully appropriated by Congress. In doing so, it willfully ignored the immediate devastation a freeze would have on the health, safety, and wellbeing of communities and businesses across the country,” said Attorney General Bonta. “Staff in my office worked overnight to ready a lawsuit challenging this illegal freeze and have continued to fight for these critical funds. Today’s decision is an important victory for the rule of law and for the many programs throughout our state that rely on federal funding to carry out their mission. But the fight is not over, and we will continue to work to secure a permanent decision blocking this radical freeze.”

BACKGROUND 

Last month, a coalition of 23 attorneys general, led by the attorneys general of California, New York, Rhode Island, Illinois, and Massachusetts, sued the Trump Administration over its attempt to freeze up to $3 trillion in vital federal funding. The U.S. District Court for the District of Rhode Island quickly granted the attorneys general’s request for a temporary restraining order, blocking the freeze’s implementation until further order from the court. Soon after, the attorneys general filed motions for enforcement and a preliminary injunction to stop the illegal freeze and preserve federal funding that families, communities, and states rely on. The court granted the motion for enforcement, ordering the Administration to immediately comply with the temporary restraining order and stop unlawfully freezing federal funds. 

In just this fiscal year, California is expected to receive $168 billion in federal funding – 34% of the state’s budget – not including funding for the state’s public college and university system. This includes $107.5 billion in funding for California’s Medicaid programs, which serve approximately 14.5 million Californians, including 5 million children and 2.3 million seniors and people with disabilities. Additionally, over 9,000 full-time equivalent state employee positions are federally funded.

Attorney General Bonta is joined by the attorneys general of Arizona, Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, North Carolina, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington, and Wisconsin in securing the preliminary injunction.   

3. Separately, other sources indicate continuing anti-DEI preparations at NIH,  https://www.nature.com/articles/d41586-025-00703-1

We understand that sharing this information may confound clarity, but we believe that transparency allows us to better prepare and provide guidance based on best practices, aligning with the approach taken by most institutions in our system and state.

Recent events have created uncertainty and concern regarding federal grant and contract activities. We are working closely with our Chancellor’s Office colleagues, including leadership in the Office of Federal Relations, Office of General Counsel and Business and Finance to receive information about executive action impacting federal grant and contract activities, assess and understand the scope of these actions, and develop appropriate response strategies.

Several universities continue to report funding freezes and grant cancellations. We anticipate that this number will climb as a result of Executive Order “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative” released on Wednesday, February 26, 2025.  The order states in relevant part:

(b)  Review of Covered Contracts and Grants.  Each Agency Head, in consultation with the agency’s DOGE Team Lead, shall review all existing covered contracts and grants and, where appropriate and consistent with applicable law, terminate or modify (including through renegotiation) such covered contracts and grants to reduce overall Federal spending or reallocate spending to promote efficiency and advance the policies of my Administration.  This process shall commence immediately and shall prioritize the review of funds disbursed under covered contracts and grants to educational institutions and foreign entities for waste, fraud, and abuse.  Each Agency Head shall complete this review within 30 days of the date of this order.”

As we prepare for increased scrutiny and cancellation of federal grants and contracts, we offer the following guidance.

General Guidance:

If you have not received specific communication from your sponsoring agency, please continue your research project in accordance with the grant or contract terms and consistent with EOs released to date. For new proposal writing and submissions, follow the latest guidance outlined in the corresponding calls for proposals or program announcements.

Federal Grant and Contract Proposals:

Continue to submit federal grant and contract proposals to available federal funding opportunities as long as federal submission systems remain operational. Federal agency proposal review timelines may be delayed due to agency-specific implementation plans and funding guidelines. Check program websites and funding opportunities regularly for changes in deadline dates. Review new versions of funding opportunities carefully to ensure that your proposal is compliant. While funding opportunities often make explicit the changes that occur with reissue, not all changes in the wording may be highlighted. Sign up for federal agency alerts, if available, especially for the agencies to which you apply.

Active Grant and Contract Awards:

Performance on active awards can continue if obligated funds are available AND a stop-work or termination order has not been issued by the agency. Monitor fund balances to avoid deficits while waiting for continuation funding. Anticipated future funding is always subject to the availability of funds and should not be considered guaranteed. Notices of new, continuing, or supplemental funding may be delayed. Awards currently under negotiation may be placed on hold until further notice by the funding agency. Stay in contact with your program officers, if possible. However, note that some agencies have put a temporary hold on communications as EO implementation plans are established. Monitor updates from federal agencies, for updates on funding or compliance requirements.

If Principal Investigators (PIs) or department administrators receive any award notifications or other agency communications, including "Stop-Work" or "Termination" Orders, please forward all relevant documents to your Campus Chief Research Officer, Dr. Jason A. Bush, Interim AVP, Research and Sponsored Programs, at jbush@csufresno.edu.

Important Considerations:

We understand these are uncertain times, and we sincerely thank you for your continued dedication to our research and sponsored programs mission, which remains as vital as ever. We understand that these actions are increasing anxiety levels across the CSU system and that many of you have important questions. There is limited information at this point regarding how these actions will specifically impact the research enterprise. However, we are committed to keeping you informed about federal activities and advocating in support of CSU’s research priorities. We will continue to update the university community as we move forward.

Thank you for your understanding and cooperation.

Earlier this week, federal judges in Rhode Island and Washington D.C. issued temporary restraining orders (TROs) preventing federal agencies from terminating existing research activities impacted by recent executive orders or the OMB memo. The Department of Justice has clarified that federal agencies cannot pause, freeze, block, cancel, or terminate awards based on these directives. However, these TROs are temporary, and agencies must still review grants for compliance with federal law. This means that some agencies may still pause, modify, or terminate specific activities in the future. Especially federal agencies that have issued notices requiring an immediate halt to all specific DEIA (Diversity, Equity, Inclusion, and Accessibility) activities.

Yesterday afternoon (02/07/2025) NIH announced a 15% indirect cost rate will now apply to all new and existing grants. This is another negative impact to biomedical research.

At this time, we advise faculty to continue all grant-funded research activities unless specifically notified of a suspension (cease & desist) or termination by agency personnel (e.g., a program officer). We encourage you to continue writing and submitting federal grants.

Guidance for Faculty:
●    Review your grants & budgets – Ensure timely spending of awarded funds and confirm expenditures align with approved budgets.

●    Exercise caution in making new financial commitments—funded awards could be affected by shifting federal priorities.

●    Prioritize essential spending – Avoid unnecessary delays in purchasing approved research materials, hiring personnel, or conducting project activities.

●    Communicate with program officers – If you anticipate delays in spending or project milestones, contact your program officer for guidance on modifications or extensions.

●    Monitor agency guidance – Stay informed through official funding agency announcements and websites. If you receive specific communications from federal sponsors, please forward to Dr. Jason Bush, Interim Associate Vice President for Research and Sponsored Programs (jbush@csufresno.edu).

We are working closely with the Chancellor’s Office (Government Relations & General Counsel) and the campus research leadership network to monitor developments. We will continue to provide updates as more information becomes available. If you have questions or need assistance, please reach out to our office.