Update on US federally funded research

The Research Support and External Relations Office is closely monitoring recent Executive Orders and memoranda from the President of the United States of America related to US federally funded research and their potential impact on research at KI. This page provides status updates and ways to contact us.

US government shut down, October 1, 2025

Due to the current US governmental shutdown, federal funding may be disrupted.

Applications can be submitted, but will not be processed/reviewed until the government reopens. More information on possible extended deadlines may only be available after the shutdown has ended.

For researchers with current projects, you may continue spending existing funds on active grants and contracts unless you receive a stop-work order. However, new awards, renewals, and supplemental funding will not be issued, and payments from federal agencies may be delayed until the shutdown ends.

This website will be updated with any new developments.

New Application and Award Structure for NIH-Funded International Collaborations (Replacing NIH Foreign Subawards) 

Effective January 25, 2026, the National Institutes of Health (NIH) will implement a new application and award structure for projects involving foreign components, replacing the current foreign subaward model.  

In summary, new applications requesting NIH funding for one or more foreign components must use a new grant type specifically designed for international collaborations. This change aims to improve transparency, financial accountability, and oversight in international research collaborations.  

Key Changes: 

  • Foreign collaborators will participate as independent subprojects under a new multi-project grant mechanism (replacing foreign subawards).
  • Each participating organization (domestic and foreign) will be assigned separate grant numbers (e.g. PF5/UF5 for domestic, RF2/UL2 for foreign).
  • The prime applicant must be a U.S.-based institution. Foreign organizations may be included as independent foreign components (sub-projects) within the application.
  • Each international organization must designate its own principal investigator (PI) and submit a letter of support confirming their role as a direct recipient.
  • Applications will be reviewed as a whole, with impact scores and specific feedback for each component.
  • Annual progress reporting will be more collaborative and streamlined to reduce redundancy across collaborators.  

Implications for KI Researchers: 

  • Although foreign organizations cannot apply directly to this new grant type, foreign organizations can be included as independent foreign components within the application of a U.S. prime.
  • Foreign organizations can continue to apply for NIH opportunities as prime (with or without a U.S. sub) using traditional application types if they meet the eligibility requirements.    
  • A new funding opportunity announcement (FOA) is expected by November 25, 2025, on Grants.gov. For a forecast of this funding opportunity, please visit:  PA-26-002.

Transition Guidelines for Foreign Subawards Through September 30, 2025 

  • Existing projects with foreign subawards may need to be restructured. Short-term solutions (e.g., administrative supplements) are currently available until September 30, 2025.
  • Applications that include foreign subawards and are received before September 25, 2025, will be reviewed as submitted. If selected for funding consideration, the relevant Institute, Center, or Office will work with the applicant to address any foreign subawards in the application as outlined in NOT-OD-25-104 and NOT-OD-25-130. If a resolution is not possible during this process, the award will not be issued.
  • Applications that include foreign subawards will not be accepted on or after September 25, 2025, and will be administratively withdrawn. 

NIH remains committed to supporting international research across all areas. The new structure is not meant to limit collaboration but to improve accountability and transparency. 

For full details, see  NIH Extramural Nexus (News) and NOT-OD-25-155, and look out for upcoming FAQs, trainings, and additional guidance. 

 

Background

A memorandum from the Office of Management and Budget (OMB) dated January 27, 2025, required US federal agencies to “identify and review all federal financial assistance programs and related activities in alignment with the President’s policies and requirements” and pause the distribution of funding during the review process. However, OMB rescinded the memorandum on January 29.  

While pauses are common when a new administration takes office, it remains uncertain how, or to which extend, this will impact our specific projects.

A court order has temporarily lifted the pause imposed by the executive order. This means that research activities and business operations at KI should proceed as usual for NIH projects. However, one USAID project at KI has been confirmed as canceled. A preliminary injunction has been filed as of March 10, 2025, which may affect these USAID projects. As information comes in, those affected will be informed.

NIH’s new policy for foreign subawards, effective 1 May 2025

On May 1, the National Institutes of Health (NIH) announced an updated Policy on Foreign Subawards, which may affect NIH-funded research at Karolinska Institutet.

Due to recent updates in NIH Policy on Foreign Subawards (and contracts) — specifically NOT-OD-25-104 — we recommend temporarily pausing activity on research projects involving NIH U.S. federal funding. 

This is a precautionary measure while we actively seek clarification from funders and partners regarding the scope and implications of the notice. Affected research groups will be contacted directly with further guidance. 

 

Supreme Court Rules on NIH Grant Cancellation 

On August 21, the U.S. Supreme Court cleared the way for the federal government to terminate more than $783 million in active research grants from the National Institutes of Health. The 5–4 decision, issued August 21, allows the Trump administration to proceed with its cancellation of thousands of grants tied to topics such as diversity, equity and inclusion (DEI), gender identity, HIV/AIDS, and COVID-19. The majority held that disputes over individual terminated grants likely must be heard in the Court of Federal Claims, not in district courts.

Contact

For inquiries related to the application stage, contact: grantsoffice@ki.se

For inquiries related to the post-award stage, contact: compliance@ki.se