Oct/Nov 2025 NCURA Magazine

OCT/NOV 2025

NCURA

ELECTRONIC-ONLY ISSUE VOLUME 57, NO. 5

MAGAZINE

A YEAR LATER

ALSO IN THIS ISSUE The Financial Accountability in Research (FAIR) Model Annual Meeting Recap Perils of Section 117 Foreign Gifts Reporting Published by The National Council of University Research Administrators

NCURA Magazine | Oct/Nov 2025 The opinions expressed in NCURA Magazine are those of the author and do not necessarily reflect the views of the magazine or the organization.

FEATURES Uniform Guidance in Motion: A Year of Adapting and Translating

By Javeria Kazi...................................................................... 8

36

One Year Later: The Impact of the 2024 Uniform Guidance Revisions on Departmental Research Administrators

By Jaiwan Harris and Kay Gilstrap........................................12 Staying Nimble: What the 2024 Uniform Guidance Revision Means for Predominantly Undergraduate Institutions

By Virginia D. Shaffer...........................................................17

12

Approaching Regulation Changes

By Carrie Chesbro................................................................20 Uniform Guidance Revisions: One Year Later and Under New Management

By Gil Tran..........................................................................22 Implementing Uniform Guidance 2024 Revisions: Updates from the University of Maine

By Stefania Irene Marthakis..................................................24

31

Research Administration in Europe: 2025 – The Year of the Snake?

By Ellen Thompson................................................................31 A Time for Self-Care: Reigniting Energy and Positivity in Research Administration

By Laura Rosales ..................................................................34

47

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The Financial Accountability in Research (FAIR) Model: A New Approach to the Government-Researcher Partnership for American Leadership in Research and Innovation

By Kelvin K. Droegemeier, Penny Gordon-Larsen, Jenny Lodge, Kurt Marek, and Stacey Patterson......................52 2024 Updates to Uniform Guidance: Key Changes and Terms for Pass-Through Entities and Foreign Subrecipients

By Amanda Humphrey.........................................................56 National Academies of Sciences, Engineering and Medicine Report, Simplifying Research Regulations and Policies: Optimizing American Science

By Lisa Nichols, Stacy Pritt, and Christopher Viggiani............58 Perils of Section 117: Foreign Gifts Reporting

By Jeff Seo........................................................................... 60 Shifting the Lens: Female PIs and RAs Navigating Administrative and Financial Changes in 2025

By Kathryn Callahan and Alex Domaleski.............................64 Navigating Change: What the Federal Landscape Means for Research Administration..............................66

NCURA NEWS President’s Message..........................................................3 Executive Director’s Message.......................................... 4 3rd Annual NCURA AI Symposium Recap...................... 6

Colliding Authorities: Navigating Uniform Guidance and Recent Federal Actions

By Roseann Luongo, Karen Johnson, Jeremy Forsberg, and Lisa Mosley..........................................................................36

Board Update....................................................................11

Research Administration in Africa: A Year Later— A Ugandan Institution’s Reflection on the Impact of October 2024 Uniform Guidance Revisions

By Josephine Amuron............................................................42

Research Management Review....................................... 21

Notable Practices............................................................. 13 Reimagining Community: Planning the NCURA of Tomorrow...................................................14 Annual Meeting Recap................................................... 25 NCURA Education Scholarship Fund Select Committee (ESFSC)...................................................30

Uniform Guidance One Year Later: From Policy to Implementation

By Mirayda Torres-Avila and Glorimar Colón....................... 44

2026 FRA/PRA Conferences......................................... 33

Before Burnout Settles In: A Discussion on Stress in Research Administration

By Vanessa Rook...................................................................47

Work Smart......................................................................61

How To Pivot In Your Career

By James Brooks, Jeanne Kisacky, and Christine Sislak............49

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2025 Robert C. Andresen Outstanding Achievement in Research Administration Award............................48 Training Tips.................................................................... 62 Regional Corner..............................................................68 Spotlight on Research.................................................... 72 Calendar of Events........................................ Back Cover

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NCURA MAGAZINE

VOLUME 57, NO. 5

NCURA MAGAZINE

OCT/NOV 2025

ELECTRONIC-ONLY ISSUE

VOLUME 57, NO. 5

UG – A YEAR LATER

IN THIS ISSUE: Would any of us argue if someone said that the many challenges that began in January 2025 overshadow the October 2024 release of an updated A YEAR LATER UG – the Uniform Guidance? I, for one, expected most of the articles in this issue to take that “yes, but…” approach.

That was not the case. The reason is summarized clearly in the article by Virginia D. Shaffer, “Staying Nimble: What the 2024 Uniform Guidance Revisions Means for Predominantly Undergraduate Institutions” as “the revision creates opportunities to simplify internal processes, revise policies, and refocus on what matters most: supporting faculty and student researchers.”

Stefania Irene Marthakis continues with the core theme in “Implementing Uniform Guidance 2024 Revisions: Updates from the University of Maine” including a methodology for deciding which changes need attention.

Josephine Amuron’s “A Year Later— A Ugandan Institution’s Reflection on the Impact of October 2024 Uniform Guidance Revisions” reminds us that institutions outside the US also needed to have considered responses to changes such as this.

There are many excellent “Yes, but…” articles: • Roseann Luongo, Karen Johnson, Jeremy Forsberg, and Lisa Mosley’s “Colliding Authorities: Navigating Uniform Guidance and Recent Federal Actions” supports the proposition that the UG revision, the 2025 Executive Orders, agency actions, and legal challenges “have reintroduced fragmentation and uncertainty, leaving institutions unsure which rules govern their awards and compliance obligations” for all institutions regardless.

• Kelvin K. Droegemeier, Penny Gordon-Larsen, Jenny Lodge, Kurt Marek, and Stacey Patterson’s “Financial Accountability in Research (FAIR) Model” offer a clear explanation of what indirect cost reimbursement may look like in the very near future.

• Jeff Seo shows how we have been warned about the “Perils of Section 117 Foreign Gifts Reporting” by recently expanded oversight by the US Department of Education.

NCURA members are interested in more than their compliance challenges.

See the proof in the recaps of the 3rd Annual AI Symposium and the 67th Annual Meeting, the celebration of Denise Wallen receiving the Robert Andresen Outstanding Achievement in Research Administration Award, and the updates on regional activities. N ALSO IN THIS ISSUE

The Financial Accountability in Research (FAIR) Model How to Pivot Your Career Perils of Section 117 Foreign Gifts Reporting

SENIOR EDITOR

EXECUTIVE EDITOR

CO-EDITORS

COPY EDITORS

CONTRIBUTING EDITORS

Inclusion

Lamar Ogelsby Rutgers University Robyn Remotigue UNT Health Fort Worth

Pre-Award

Tanta Myles Georgia Tech

Tolise Dailey Georgetown University School of Medicine Kathleen Halley-Octa Attain Partners Martin Williams Vaughn College of Aeronautics and Technology

Published by The National Council of University Research Administrators

Martin B. Williams is the Grant and Compliance Manager at Vaughn College of Aeronautics and Engineering. He has developed and led research administration operations in predominantly undergraduate institutions for more than 25 years. Martin is a Co-Editor of NCURA Magazine, a former member of several national and regional committees, and a former regional officer. He can be reached at Martin.Williams@vaughn.edu.

Career Development

Clinical/Medical Christina Stanger MedStar Health Research Institute

Collaborators Anthony Beckman University of Rochester Lisa Mosley Yale University

Compliance Jeff Seo Northeastern University Stacy Pritt Texas A&M University System

Contracting

Marc Schiffman NCURA

Beth Jager Claremont McKenna College Jeanne Kisacky Cornell University Paulo Loonin Duke University School of Medicine Robin Ruetenik University of Iowa

Sheleza Mohamed American Heart Association Laneika Musalini Metropolitan State University of Denver Wendy Powers University of Maine Trisha Southergill Colorado State University

Predominantly Undergraduate Institutions Magui Cardona University of Baltimore Michelle Gooding Frederick Community College

Research Development Camille Coley University of San Francisco

Self-Care

Beth Kingsley Yale University Laura Letbetter Georgia Tech

Rashonda Harris Johns Hopkins University Kim Moreland University of Wisconsin - Madison

Departmental Research Administration

Senior Administrator

Kelly Andringa University of Iowa College of Medicine Jennifer Cory Stanford University

Lisa Nichols University of Notre Dame Lindsey Spangler Duke University School of Medicine

Financial Research Administration

Spotlight on Research

Erin Bailey University at Buffalo Clinical and Translational Science Institute Brian Miller Emory University

Systems/Data/Intelligence

Global - Africa Josephine Amuron African Center for Global Health and Social Transformation

Global - Asia Pacific Lisa Kennedy University of Queensland

Global - Europe Joey Gaynor Trinity College Dublin Kirsi Reyes-Anastacio University of Helsinki

Global - Middle East Reem Younis United Arab Emirates Ministry of Education

Derek Brown Stanford University Thomas Spencer University of Texas Rio Grande Valley Dan Harmon University of Illinois Urbana-Champaign

Training Tips Helene Brazier-Mitouart Weill Cornell Medicine

Work Smart Hagan Walker Prisma Health Claire Stam Prisma Health

Young Professionals Carol Bitzinger Ohio State University Katie Gomez Freeman Southern Utah University

Global - U.S. MC Gaisbauer University of California-San Francisco Christopher Medalis School for International Training

Interested in contributing an article?

Visit www.ncura.edu/PublicationsStore/ NCURAMagazine/Submissions.aspx

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The NCURA Magazine accepts advertisements for products and services pertinent to university research administration. In addition, display advertisements (including those for position openings) will also be published. The minimum rate is $1,000.

Advertisements and articles should not be construed as official endorsements by NCURA. For additional information on advertising or changes in address, please contact: National Council of University Research Administrators 1015 18th Street, NW, Suite 901 Washington, DC 20036 www.ncura.edu

To request permission to reprint material from the NCURA Magazine, please send your inquiry to Marc Schiffman at schiffman@ncura.edu and include the issue, name of article and where you are looking to reprint it. © 2025 National Council of University Research Administrators

MESSAGE FROM YOUR PRESIDENT

By Denise Moody, NCURA President

W

elcome to our October/November issue, aptly titled UG – A Year Later. As we reflect on the landscape of research administration, it’s remarkable to consider how our community has navigated the myriad challenges and changes that have arisen, particularly with the upcoming implementation of the UG regulations in 2025. Little did we know, when this theme was chosen, just how significant the federal regulatory landscape would change in our research administration profession!

This past August, NCURA hosted a very successful Third Annual AI Symposium in Washington, DC led by program chairs, Nancy Lewis, Lori Ann Schultz, and Thomas Spencer. We welcomed over 170 attendees, including an inspiring keynote address from Neil Johnson of The George Washington University. With more than 20 outstanding presenters and a variety of engaging breakout sessions, it is clear that artificial intelligence is not merely a buzzword; it is a transformative force reshaping the entirety of the research award lifecycle. Together, we explored how AI enhances our efficiency and effectiveness in navigating the complexities of our field.

Following the Symposium, our community gathered for our 67th Annual Meeting, themed Forward Focused – Priming for Change, featured in this Magazine issue. Our chairs—Shannon Sutton, Candice Ferguson, and Katherine Durben—and their program committee put together a program with a wealth of learning opportunities, fostering a spirit of connection and collaboration. I cannot emphasize enough the importance of our community—our shared experiences, laughter, and camaraderie were palpable and invigorating. A heartfelt thank you goes out to the dedicated NCURA staff, our countless member volunteers, and our generous sponsors for making this gathering successful.

As featured in NCURA’s Executive Director article, NCURA continues to collaborate on a global level. Following the Annual Meeting, NCURA was the proud host of the International Network of Research Management Societies (INORMS) Council meeting led by INORMS Chair Dipti Pandya from the European Association of Research Managers and Administrators (EARMA). The INORMS Council (https://inorms.net/) includes leaders of our fellow societies from around the world who meet throughout the year, several of who attended our Annual Meeting (Lorna Wilson, ARMA; Dominique Michaud, CARA; Dara Little, SRAI; Dembo Bakary Kanteh, WARIMA; Jessica Moon, NORDP).

In September, we took another step forward by convening over 50 of NCURA’s emerging and established leaders, including several Young Professionals, in the Washington, DC area for a transformative summit

focused on “Reimagining Community.” I urge you to read the article written by Caitlin Crowley, Lauren Gee, and Scott Niles which captures the essence of our discussions, the “blue sky” thinking that emerged, and our commitment to enhancing membership engagement. This initiative is part of an ongoing dialogue that began under the leadership of our 2024 President, Kris Monahan, and it will continue to shape our strategic direction as we head into 2026.

As stewards of NCURA’s vision, our Board of Directors has dedicated this year to refining our strategic plan. With a forward-thinking approach, we are considering actions and initiatives that will guide us over the next three to five years. Our upcoming fall Board meeting will center on executing the action items derived from our Reimagining Community summit, developing an AI strategic plan, and establishing a new certificate program for emerging leaders in research administration. Each decision we make is rooted in our unwavering commitment to our mission and our core values: Integrity, Excellence, Service, Collegiality, Transparency, and Inclusiveness. I encourage every member to review the Board updates in each issue of the Magazine to stay informed and involved.

As we reflect on this past year—a year filled with trials and triumphs— it’s heartening to see how we have collectively risen to meet the challenges.

From deciphering executive orders and policy changes to navigating sponsor requests, the support I’ve witnessed from our network has been nothing short of extraordinary. I am profoundly grateful for each of you who provide me hope, inspiration, and moments of levity, creating an incredible community in which we can all thrive.

Thank you for your unwavering dedication to our profession and our mission. Let’s continue to innovate, connect, and support each other… together. N Most Sincerely,

Denise Moody is the 2025 NCURA President and serves as the Director of Research Operations, Systems, and Policies at The Lundquist Institute for Biomedical Innovation.

She can be reached at denise.moody@lundquist.org.

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Celebrating Research Administrators

By Kathleen Larmett, NCURA Executive Director

T

he importance of what we do is formally recognized once a year on September 25th. Yet, after ten months into a year where research itself has faced constant challenges, I believe our work deserves to be celebrated every single day.

In 2015, NCURA launched National Research Administrator Day, to celebrate the importance of what we do. As the news spread around the globe our colleagues outside the US joined in the celebration, and over time the “holiday” grew into International Research Administrator Day. On our 10th anniversary, I decided to look back at what was happening in 2015 and went to the October/November issue of NCURA Magazine.

When I saw the theme was “The Politics of Research Administration,” I was immediately struck by the Jean-Baptiste Karr quote, “The more things change, the more they stay the same.” I encourage you to revisit this issue—it is filled with excellent articles, many of which remain relevant today, including one on the “father” of research and development, Vannevar Bush, which highlights the enduring importance of research https://www.ncura.edu/Portals/0/PDF/OctNov2015_NCURA_Mag.pdf That 2015 issue of the magazine also featured contributions from colleagues around the world, reminding me how long NCURA has been sharing knowledge about US grant funding and management with our members and partners outside the US. Ten years after this issue, we are offering more continuing education opportunities for non-US colleagues than ever before. This year, delegations have traveled to Washington, DC, from countries such as

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Greece, Italy, Ethiopia, Finland, Czechia, and Germany. At the same time, our NCURA faculty are going abroad to provide workshops—this fall in Warsaw for colleagues in Poland and Ukraine. December will see NCURA provide workshops for our colleagues in Helsinki, along with lab visits for US research administrators and their researchers. NCURA also co-led the effort of launching the very first North America Finnish Diaspora network together with our Finnish partners.

NCURA’s ability to sustain open dialog and provide research management training for colleagues in the US and abroad is critical to advancing global research collaboration. Research administrators provide a bridge between researchers and funders while supporting our institutions and maintaining compliance with federal policies. We help research projects run efficiently and collaboratively across borders, enabling breakthroughs by fostering partnerships and reducing administrative barriers. Without research administrators, much of the research enterprise would slow down—or even fail—due to missed funding opportunities, non-compliance, or inefficient management.

Thank you to all of you who dedicate your days—and often your nights and weekends—to supporting research. We appreciate you, and we know that without your commitment, the world would be a very different place.

Today, and every day, we celebrate you. N

Research resilience starts here Chart a steady course through today’s funding landscape Strategy

Operations

Compliance

Adapt your research portfolio for financial stability

Optimize for lean efficiency and new rules

Navigate changing regulations and shifting risk

huronconsultinggroup.com

3rd Annual NCURA

AI

Symposium Recap

By Nancy Lewis, Lori Ann Schultz, and Thomas Spenser

A

rtificial Intelligence (AI) is no longer an abstract concept or distant possibility for research administration—it is rapidly becoming part of our daily operations, wanted or not, and we are pivoting to learn and make effective use of AI in our work. This reality was the focus of the 3rd Annual NCURA AI Symposium, held August 9, in Washington, DC, where over 170 participants gathered to explore how AI is reshaping research, administration and technology.

Building on the momentum of the prior two years and a call from membership, this year’s event marked a pivotal shift, moving from exploration to operationalization—turning AI’s potential into tangible tools, strategies, and outcomes.

The symposium opened with a compelling keynote that offered a “peek under the hood” at how AI works and why our interactions with AI systems matter. The speaker emphasized that politeness toward AI agents is not just etiquette but reflects the importance of designing thoughtful, transparent interactions that foster trust and reliability and can statistically increase positive interactions. By demystifying how AI systems learn and respond, the keynote set the tone for a day focused on both the mechanics of AI and its strategic integration across the research enterprise. From proposal development to post-award monitoring, the research award lifecycle presents countless opportunities for automation and insight.

As universities, hospitals, research institutions, and funding agencies begin embedding AI into operations, the question is no longer if AI will change research administration, but how quickly can institutions adopt it responsibly, efficiently, and ethically.

Operationalization—moving AI beyond possibilities and pilot projects to embed it into everyday practice—was a central theme. Presenters showcased real-world applications where AI is already helping administrators reduce routine burdens, enhance accuracy, and redirect time toward strategic priorities and faculty engagement. Institutions are actively experimenting with AI tools that generate budget justifications, analyze workload assignments, detect early compliance gaps, predict financial or effort distribution anomalies, and even draft initial versions of progress 6

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reports—allowing human reviewers to refine and contextualize. These initiatives not only demonstrated efficiency gains but also underscored the transformational impact AI can have on research administration, empowering professionals to delegate transactional tasks to AI and focus on higher-level strategy and problem-solving.

With opportunity comes responsibility, and this symposium did not shy away from the tough questions. Sessions explored critical governance and ethical challenges, including safeguarding sensitive data—both regulated and unregulated—mitigating bias in AI models, training AI tools across different languages, understanding environmental impacts, and ensuring transparency and accountability for AI-generated recommendations.

Discussions also addressed the need to prepare staff for workforce changes brought on by AI adoption. Throughout, the emphasis was clear: institutions must develop a strategic approach to AI, aligning its use with their mission, values, and compliance obligations—rather than simply chasing the latest technology.

This year’s event also introduced a new dimension: for the first time, AI vendors were invited to speak directly about their tools and initiatives.

Their presence created an energetic exchange between developers and practitioners, giving participants the opportunity to ask candid questions about how AI models are trained, what protections are in place for their data, and how products integrate with existing research systems. The two-way dialogue underscored the importance of collaboration between institutions and technology providers to ensure that AI solutions meet the practical realities of research administration.

The symposium concluded with a myth-busting session that helped participants separate hype from reality, emphasizing that AI is not a magical solution but a set of tools with both strengths and limitations.

Presenters invited the audience to share their fears, hopes, and goals while pushing back against common misconceptions that AI will replace administrators, can be adopted overnight, or is inherently biased and unreliable. Instead, they underscored that AI augments rather than replaces human judgment, requires careful planning and governance,

and can improve fairness and accuracy when thoughtfully implemented.

This flowed into an interactive closing discussion where presenters and attendees reflected on key themes, shared personal takeaways, and identified next steps. A collective sense of urgency and opportunity permeated the room: urgency because AI adoption is rapidly accelerating across higher education, industry, and government, demanding that research administrators remain proactive to stay relevant; and opportunity because the careful integration of AI can elevate the profession and empower administrators to deliver greater value to faculty, institutions, and society. Attendees left with plans to form institutional task forces, create professional development programs to build AI literacy, working where they are in the organizational chart, and to continue exchanging experiences through professional networks such as NCURA. In the future, as opposed to a specific track for “systems and technology,” our meetings should include AI across the lifecycle of what we do.

The 3rd Annual AI Symposium demonstrated how far the conversation around AI has progressed in a few short years. What began as curiosity about emerging technologies has evolved into a pragmatic, collaborative movement to harness AI’s potential while upholding the core values of research integrity, equity, and transparency. As NCURA continues to lead and nurture this dialogue, one message resonated throughout the day: research administration is no longer just about processing transactions— it is about driving transformation. We have navigated major shifts before, from paper-based workflows to the internet and eRA systems. Now, AI stands as one of the most powerful tools yet to propel our profession forward—and that transformation has already begun. N

Nancy Lewis serves as the Associate Vice Chancellor for Research Administration at the University of California, Irvine (UCI). With over 25 years of experience in research administration, she brings deep expertise across a broad spectrum of areas, including preaward and post-award non-financial functions, electronic research administration, compliance, policy development, recruitment, and training. Nancy is a recognized leader, having delivered numerous workshops, presentations, and discussion sessions for both NCURA and the University of California system. She has twice served on the NCURA Board of Directors and currently serves on the Board of the Southern California Institute of Research and Education.

She can be reached at nrlewis@uci.edu.

Lori Ann M. Schultz is the Assistant Vice President, Research Administration at Colorado State University, and Co-Director of the NSF SECURE Center SW Region. She has worked in research administration for more than 30 years, and supports faculty researchers through policy, process, and research security. She works on evidence-based policies, marshaling research data in the service of the institution and the faculty who do research. Lori has spoken on research, data, and technology topics at the National Academies of Science, Engineering and Medicine, AAU, APLU, NCURA, SRAI, FDP, COGR, and Educause. Lori is on the Board of Directors of ORCID, COGR, and NCURA. She can be reached at lori.schultz@colostate.edu.

Thomas B. Spencer, PhD, MBA, is the Senior Associate Vice President for Research Operations and Associate Professor of Health Sciences in the Department of Health and Biomedical Sciences at The University of Texas Rio Grande Valley. He has worked in academia and research administration for over two decades and is currently a member of the Board of Directors for NCURA, and he worked for the Johns Hopkins Research Administration master’s degree program. He can be reached at thomas.spencer@utrgv.edu.

Save The Date Saturday, March 21st

4th AI Symposium

San Juan Puerto Rico Convention Center

More learning. More insights. So many choices!

March 19 & 20: NCURA FRA Annual Conference March 21: Workshop Day March 21: 4th AI Symposium March 22 & 23: NCURA PRA Annual Conference

AI Symposium Co-Chairs

Bryan Bachman University of Illinois Urbana-Champaign

Sylvia Bradshaw Southern Utah University

Vincent Borleske University of Arizona

In-person events provide the opportunity to meet our speakers and attend great sessions

Be there and share!

AI PROGRAM AND REGISTRATION AVAILABLE IN DECEMBER!

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| Oct/Nov 2025

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Uniform Guidance in

Mot ion:

A Year of Adapting and Translating

By Javeria Kazi

I

t is hard to believe that nearly a year has passed since our initial review of the revised Uniform Guidance. At the outset, our institution recognized that while some changes would require effort and careful planning to implement, the revisions overall promised greater clarity and consistency. For a brief moment, the research community welcomed that clarity. Yet on January 20, 2025, that sense of relief quickly gave way to uncertainty.

The higher education research enterprise has been jolted this year by a rapid succession of executive orders, funding terminations, and

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subsequent legal challenges. Among the many areas of disruption, the Uniform Guidance, formally known as 2 Code of Federal Regulations (CFR) 200, was placed squarely at the center. For both central and departmental administrators, sudden directives from federal agencies raised questions about legality, implementation timelines, and the long-term stability of research funding. In many instances, we found ourselves reassuring faculty with statements such as: “Uniform Guidance still governs this area” or “These changes will not withstand legal scrutiny.”

Institutional Response: Laying the Groundwork In preparation for the October 2024 revisions to Uniform Guidance, our institution acted quickly. Central offices assembled a team of experienced subject matter experts, including several who had been instrumental in implementing the original “Omni-Circular” in 2015.

Beginning in April 2024, this review team examined the revised guidance line by line, evaluating terminology, definitions, thresholds, and policy implications. The focus was on institutional-level adjustments, including updates to centralized systems, internal controls, and campus-wide policies. By late summer, the team had completed its analysis, presented recommendations to executive leadership, and established an implementation timeline. Most changes were implemented in Fall 2024, with threshold-related updates staggered to align with the federally negotiated rate agreement.

From the departmental perspective, the rollout was orderly and clear.

Updates were communicated across campus immediately following the October 1 implementation date, leaving campus constituents with the impression that the process had been wrapped up neatly.

The rapid issuance of executive orders and agency-level process changes suggests that the landscape will continue to shift.

The Shifting Federal Landscape That neat package began to unravel as 2025 unfolded. With each new executive order, our institution grew increasingly concerned about the durability of the revisions we had just completed amongst the state of the higher education research enterprise. One of the greatest challenges involved the negotiation of our indirect cost rate agreement, which had already been under review before the change in administration. Our submission included detailed data analyses with the updated thresholds for equipment and subawards, integrating those changes into our modified indirect cost base.

Yet discussions around across-the-board reductions to indirect cost rates left much of that careful preparation in question. Hours of work spent analyzing data, updating policies, modifying systems, and training campus partners suddenly seemed at risk of being rendered obsolete.

Another area of reconsideration involved our approach to direct charging administrative closeout costs. While the revised guidance allowed greater flexibility, the fast-moving policy environment forced us to weigh whether adopting that flexibility was prudent in light of potential reversals and additional scrutiny on reimbursements requests.

Departmental-Level Impacts For departments and schools, the most significant changes were absorbed centrally. Adjustments to system terminology, budget thresholds, and policy language were handled by central finance and research offices, who also coordinated campus-wide communications. Training sessions and reference materials were developed and made widely available, ensuring that departmental administrators had resources to support their faculty without shouldering the burden of interpretation.

The direct impact at the departmental level was therefore minimal: minor updates to budget templates, revisions to internal guidance documents, and consistent communication with faculty regarding sponsor expectations. The heavy lift including policy analysis, system reconfigura-

tion, and institutional training remained in the central offices.

Still the ripple effects were felt within the departments. Faculty often turn first to their departmental administrators with questions, meaning that even “minimal” impacts translated into hours of explaining and reinforcing changes. The key departmental role was not policy creation but bridging the gaps between central updates and faculty research realities.

Looking Ahead: Are We Done or Just Beginning?

Although our institution completed the Uniform Guidance review and implementation exercise in record time, it now feels as though that work was merely a preparatory dry run. The rapid issuance of executive orders and agency-level process changes suggests that the landscape will continue to shift.

From the departmental vantage point, the greatest challenge moving forward is not the technical implementation of policy but sustaining clarity for faculty in the midst of uncertainty. The Uniform Guidance has long served as a stabilizing framework for federal research administration, setting standards for cost principles, allowability, and institutional accountability (OMB, 2024). When that framework itself becomes subject to reinterpretation, departmental offices must be nimble translators, communicators, and most importantly advocates.

Lessons Learned from the Departmental Lens Reflecting on the past year, several lessons emerge for departmental research administrators: • Communication is as important as compliance.

Even when central offices shoulder the technical updates, departmental staff must be prepared to translate those updates into terms that resonate with faculty.

• Collaboration is key.

Close collaboration between central offices and departments ensures consistent messaging and reduces confusion across campus.

• Adaptability is essential.

What was true last month may change tomorrow. Adopting a mindset of adaptability helps alleviate frustration and maintain credibility with researchers.

• Change is imminent.

The October 2024 revisions may be “live,” but the work of interpreting, applying, and adjusting to them is far from finished.

The initial rollout of the revisions nearly a year ago offered a sense of resolution, but the events of 2025 reminded us that research administration is never static. For departments, the real work lies not only in implementing policy but in sustaining faculty trust, fostering adaptability, and bridging the gap between evolving federal directives and the day-today realities of researchers.

A year later, we can say that implementation of the October 2024 revisions is complete, but in truth, it feels as though we are only just beginning. N Reference

Office of Management and Budget (2024). Uniform administrative requirements, cost principles, and audit requirements for federal awards (2 CFR 200).

Javeria Kazi, MBA, CRA, Director of Grants and Contracts Accounting for Virginia Commonwealth University has been an active member of NCURA since 2008 and is a graduate of VCU’s Grace E. Harris Leadership Institute. Ms. Kazi has over 17 years of research administration experience in higher education, spanning both pre-award and post-award. In her current role, she leads VCU’s financial post-award function. She can be reached at kazij@vcu.edu.

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TRAVELING WORKSHOPS EXPERT PRESENTERS, UP TO DATE CONTENT, OFFERED AT A CITY NEAR YOU, ON YOUR CAMPUS OR VIRTUALLY! Contract Negotiation & Administration Departmental Research Administration Financial Research Administration Level I: Fundamentals of Sponsored Projects Administration Level II: Sponsored Projects Administration, Critical Issues in Research Administration

For current information on open workshop registrations, please visit our website here.

LOOKING TO FOSTER MORE COLLABORATION AND ENGAGEMENT WITH YOUR TEAM? NCURA is pleased to offer in-person and virtual On-Campus Traveling Workshop trainings. Visit our On-Campus website here or email Gabby Hughes, hughes@ncura.edu to learn more today!

Board Update The NCURA Board of Directors held its August 2025 meeting in Washington, DC, coinciding with the Annual Meeting (AM67). The board meeting focused on member engagement, continued innovation in research administration, and collaborative leadership across the organization. Some highlights of the meeting include: ■ President Denise Moody opened the meeting by emphasizing the Board’s steady leadership during a year of significant policy and funding challenges. She expressed gratitude for the dedication shown

by Board members, NCURA staff, and volunteers, highlighting their resilience and unity in service to the membership. Denise acknowledged the strong sense of “homecoming” at the Washington Hilton—a testament to the enduring bonds within the NCURA community.

■ The Annual Meeting team received enthusiastic praise for its robust programming, thanks to the hard work of Shannon Sutton, co-chairs Candice Ferguson and Katherine Durbin, numerous volunteers, and the NCURA staff.

■ Kathleen Larmett, NCURA Executive Director, reflected on the powerful tradition of member support during times of crisis. She shared NCURA’s ongoing efforts to help members facing job transitions through coaching and training resources offered through the NCURA Bridge program. Despite economic and federal funding challenges, membership remains strong at nearly 9,500.

■ NCURA’s leadership in emerging innovation areas was spotlighted through the success of the 3rd Annual AI Conference. Lori Ann Schultz and Thomas Spencer, along with co-chair Nancy Lewis, are spearheading NCURA’s AI Strategic Plan.

■ NCURA global connections continues to grow, with upcoming partnerships involving Greece and the University of Warsaw. These efforts underscore NCURA’s commitment to global engagement and innovation in research administration, pillars of NCURA’s strategic plan.

■ Preparations are underway for the September Leadership Convention with regional and national representation. Facilitated by a consultant from Tecker International, Jim Meffert, the two-day retreat Summit ! te comple n will focus on understanding member needs, envisioning future engagement strategies, and building o p Reca . page 14 stronger community across the organization.

■ The Board approved three new NICE Fellows for the Select Committee on Global Affairs. These appointments reflect NCURA’s commitment to global collaboration and knowledge exchange.

• Dr. Pankaj Gupta, Tata Institute for Genetics and Society • Mr. Matthew Saizi, University of Zimbabwe Clinical Trials Research Centre • Dr. Beatrice Sakyibea Biney-Nyamekye, University of Ghana NCURA continues to grow as a member-driven organization built on inclusion, engagement, community and a passion for advancing the research administration profession. The next Board meeting will be held in October in Chicago where the Board will continue to have strategic discussions and conversations around the future of research administration and the ways NCURA can stay current with the rapidly changing federal landscape to provide professional development, networking, and support to our expanding membership base.

Respectfully Submitted,

Kris Monahan Immediate Past President Kris Monahan, PhD, is the Immediate Past President of NCURA and serves as the Chief Research Administration Officer for the Faculty of Arts and Sciences at Harvard University. She can be reached at krismonahan@fas.harvard.edu.

If you have an questions, com y m or concerns, plea ents, se free to reach ou feel t any member of to the Board of Direct ors.

BOARD OF DIRECTORS President Denise Moody Lundquist Institute for Biomedical Innovation Vice President Shannon Sutton Georgia State University Immediate Past President Kris Monahan Harvard University Treasurer Kay Gilstrap Georgia State University Secretary Diane Hillebrand University of North Dakota Executive Director Kathleen M. Larmett National Council of University Research Administrators Eva Björndal KTH Royal Institute of Technology Natalie Buys University of Colorado Anshutz Medical Campus Jennifer Cory Stanford University Jill Frankenfield University of Maryland, Baltimore Katy Gathron MD Anderson Cancer Center Melanie Hebl University of Wisconsin-Madison Katherine Kissmann Texas A&M University Rosemary Madnick Lundquist Institute for Biomedical Innovation Danielle McElwain University of South Carolina Nicole Nichols Washington University in St. Louis Scott Niles Georgia Institute of Technology Lamar Oglesby Rutgers University Geraldine Pierre Boston Children’s Hospital Lori Ann Schultz Colorado State University Thomas Spencer University of Texas Rio Grande Valley

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One Year Later: The Impact of the 2024 Uniform Guidance Revisions on Departmental Research Administrators

By Jaiwan Harris and Kay Gilstrap

O

n October 1, 2024, the Office of Management and Budget (OMB) released a significant update to the Uniform Guidance (2 CFR 200), altering 36% of the existing text. One year later, research administrators continue to navigate the impacts of these changes across pre-award planning, post-award management, and day-to-day compliance.

While the revisions offer greater institutional flexibility and autonomy, implementation has been challenging. Below is an overview of the most significant changes and their impact on the work of departmental research administrators (DRAs).

Changes to the equipment threshold, supplies threshold, and indirect costs charged to subrecipients depended on your institution’s indirect cost agreement before changes could be made. For many institutions, their negotiated indirect cost rate agreement determined when to implement the change. For many DRAs, this meant waiting on upper administration to determine when the change would be implemented. If a recent rate agreement had been approved, it was recommended that the negotiations continue until the next cycle. If a rate agreement had been recently submitted but not yet approved, requesting an amendment to include the new thresholds was recommended. However, if your institution is a public entity, the threshold to determine equipment and supplies depends on that state’s definition.

This uncertainty created a holding pattern for DRAs, particularly in the pre-award phase, where clarity on cost classifications and budgeting rules is essential.

Equipment: Higher Threshold, More Flexibility Once an institution updates its negotiated indirect cost rate, the new equipment threshold definition—any item costing $10,000 (formerly

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$5,000 or more) and having a useful life of more than one year—qualifies as equipment.

For DRAs, this adjustment changed how many items are budgeted and tracked. Items previously considered equipment are now classified as supplies, which are generally not tracked in institutional inventory systems.

This can reduce administrative workload, especially in compliance and reporting.

However, a significant tradeoff is that these newly reclassified items are now subject to indirect costs. DRAs needed to update budgeting practices and educate Principal Investigators (PIs) on the financial implications.

Another positive update: the definition of special-purpose equipment was expanded to include associated software. This small but meaningful change simplified cost justification and purchasing processes for certain types of research-specific equipment.

Supplies: Faster Procurement, Less Paperwork In conjunction with the equipment change, the definition of supplies was updated to include all tangible personal property costing less than $10,000. Institutions with complex equipment procurement processes found that this change expedited purchases under $10,000, providing researchers quicker access to necessary tools and materials.

In addition, because many institutions do not formally inventory supply items, the change also reduced the administrative burden and paperwork for DRAs, freeing up time to focus on higher-value tasks in both the pre- and post-award phases.

Subrecipients: Increased Indirect Cost Threshold The Uniform Guidance revision also increased the indirect cost base for

subrecipient awards. Institutions that have adopted the change now apply their negotiated indirect cost rate to the first $50,000 of each subaward, up from the previous cap of $25,000.

For DRAs, this change had immediate implications for both pre-award budget development and post-award financial monitoring. Budgets required recalibration to reflect the higher indirect cost base, and subaward management practices had to be updated accordingly.

Prior Approvals: Less Sponsor Oversight, More Local Control One of the most DRA-friendly updates is reducing items requiring prior sponsor approval. This shift gives institutions and research teams greater control and flexibility in managing awards.

Key examples include: • Equipment Purchases: DRAs can now reallocate funds for large equipment purchases without sponsor approval, provided the funds are available and the expenditure aligns with project goals. For example, if a PI could not hire a postdoc in Year 1, those funds can be redirected to purchase a $35,000 piece of equipment in Year 2.

• Memberships, subscriptions, and professional activity costs.

This new flexibility can be used when a researcher registers for a meeting of a professional association and would like to pay their dues at the same time.

• Participant support costs: Though the guidance provides more flexibility in managing these funds, DRAs must still monitor agencyspecific rules, as some sponsors continue to require prior approval for changes in this category.

This increased autonomy streamlines award management, shortens turnaround times, and allows DRAs to better support researchers in making timely, project-driven decisions.

Conclusion One year into the revised Uniform Guidance, DRAs are beginning to see the benefits of increased flexibility and institutional autonomy. However, DRAs must now be more proactive in interpreting institutional policy, ensuring budgets comply with sponsor requirements and internal thresholds, and guiding PIs through new definitions and cost categorizations.

The changes have given DRAs more tools to support innovation and collaboration in federally funded research, but with those tools comes greater responsibility. As institutions refine their internal policies and prepare for future negotiations, the DRA’s role remains central to maintaining compliance, promoting efficiency, and fostering successful research outcomes. N

Jaiwan Harris is the Director of the Office of Research and Sponsored Projects for the College of Education and Human Development at Georgia State University. He has 20 years of experience in grant and contract administration, as well as a comprehensive understanding of university systems. Jaiwan holds a bachelor’s degree from Morehouse College and a master’s degree from Clark Atlanta University. He can be reached at jmharris@gsu.edu.

Kay Gilstrap, CRA, is the Director of Internal Controls & Policy Development at Georgia State University. She has over 30 years of experience in research administration and has been a member of NCURA since 2007. In NCURA, she has served as Treasurer, Chair, and Regionally Elected Board Member for Region III. She is currently serving as Treasurer and FRA Traveling Workshop faculty. She has served on numerous committees, has co-authored several articles, and has presented at many meetings. She is also a faculty member of Georgia State University’s Research Administration Training Program. She is a graduate of the NCURA Executive Leadership Program. She can be reached at kgilstrap@gsu.edu.

NOTABLE PRACTICES The Uniform Guidance: A Year Later

A

year after the October 1, 2024, revisions to the OMB Uniform Guidance, research administration offices across institutions have been actively adapting to the changes, which have had both operational and strategic impacts.

The impact of the 2024 revisions on research administration is subtle but significant. While the guidance itself is regulatory, its implementation has prompted deeper reflection within institutions on transparency and accountability in federally funded research.

Key Institutional Changes Dual-System Management: Institutions must manage both pre- and post-2024 guidance, requiring dual policies and tracking.

Internal Controls: Fewer prior approvals mean stronger internal review and documentation are needed.

Research Administrators’ Role: Expanding from compliance to strategic advising and data support.

Technology Modernization: Upgrading systems to track guidance versions and automate budgeting.

Subrecipient Monitoring: Enhanced tracking, updated templates, and technical assistance required.

Audit Evolution: Two audit tracks (old vs. new guidance) demand clear documentation.

Ethical & Equity Focus: Emphasis on tribal sovereignty, simplified language, and fairness.

Institutional Transition Plan (12 Months) • Assessment & Planning: Gap analysis, award inventory, task force formation.

• Policy Updates: Revise policies and procedures to align with new rules.

• Systems Modernization: Update grants systems and workflows.

• Training & Communication: Educate staff and stakeholders.

• Monitoring & Improvement: Internal audits, feedback, and policy refinement.

Sponsored Offices have put in place previous revisions and now they prepare for anticipating revisions to Uniform Guidance by: • Updating systems and budget templates to reflect new thresholds and rules.

• Training staff on revised approval processes and compliance requirements.

• Monitoring federal agency updates to stay aligned with evolving guidance.

• Adjusting indirect cost recovery strategies to optimize funding under new MTDC rules.

It is pertinent that institutions develop a resilient institutional strategy, aligned with strategic goals, to protect federal funding during these challenging times. Now, more than ever, research administrators should continue to foster and grow relationships with colleagues, other institutions NOTABLE PRACTICES of higher education, and national associations dedicated to the success of securing external federally funded research.

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Please contact NCURA Peer Programs: NCURA Peer Advisory Services and NCURA Peer Review Program at peerreview@ncura.edu.

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REIMAGINING COMMUNITY: Planning the NCURA of Tomorrow

By Caitlin Crowley, Lauren Gee, and Scott Niles

Last year, 2024 NCURA President Kris Monahan, Harvard University, engaged the Board of Directors in visioning conversations about how community is—and could be—experienced within NCURA. Building on this foundation, we expanded to focus groups and conversations with members and leaders across the organization. These discussions, shaped by our changing world and the evolving needs of our members, illuminated the importance of coming together to look ahead. National Leaders, Regional Leaders, and members of our Young Professionals Community came together to lift up what connects us now while imagining what lies ahead— opening space for new ways of connecting, collaborating, and supporting one another. The possibilities that emerge from our time together in September will be shared widely with you, our membership, as we shape the future of NCURA’s community…together.

Denise Moody, 2025 NCURA President The Lundquist Institute

O

rganizations, much like living organisms, must continuously adapt to their changing environment, responding to pressures both internally and externally to best serve their members.

In this spirit of adaptation and growth, more than 50 NCURA members gathered in September 2025 to imagine, plan, and dream of the NCURA of the future…and determine what it will take to make those dreams a reality.

The Reimagining Community strategic summit, facilitated by Jim Meffert of Tecker International LLC, invited participants to step away from the day-to-day details of research administration and engage in bold, values-driven thinking about NCURA’s evolution.

Throughout the summit, we kept a guiding principle in mind: NCURA’s unique mission, core purpose, and core values. These served as anchors as we considered how to adapt and grow in response to technological disruption, policy shifts, workforce expectations, and societal change.

The summit opened with a grounding exercise: a word cloud capturing the emotional landscape of our group. Words like nervous, collaborative, excited, innovative, anxious, and determined reflected the complexity

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of our professional environment and the urgency we feel as research administrators navigating rapid change. These emotions became a springboard for deeper conversations about identity, belonging, and the role NCURA plays in our professional lives.

We then explored our personal definitions of community and how they intersect with our experiences within NCURA. While tradition and cohesion were acknowledged as strengths, we also recognized that nostalgia can hinder progress. A central theme emerged: NCURA must be a dynamic, inclusive organization that meets members where they are, offering equitable access and flexible engagement at every stage of their professional journey.

In small groups, we engaged in “blue sky” thinking, imagining what would NCURA look like if there were no barriers—financial, historical, or structural? These unconstrained brainstorming sessions allowed us to imagine new models of engagement, connection, and leadership. As we transitioned from vision to implementation, we refined our ideas into actionable strategies, considering governance, accessibility, and the role of the national organization.

Several recurring themes surfaced across these discussions: • Membership: Expand engagement by reaching members earlier, revisiting the dues structure, and strengthening orientation, mentoring, volunteer recognition, and campus liaison programs.

• Regional Structure: Reimagine regions as hubs for programming and mentorship, while centralizing administration, sponsorship, and policy at the national level.

• Communication: Enhance member connections through modern platforms, clearer messaging, stronger social media presence, and input from faculty/PI stakeholders.

• Resources: Develop centralized platforms and AI-powered tools to share policies, templates, and best practices across the research administration community.

• Education: Broaden learning opportunities through “NCURA University” pathways, interactive virtual programs, regional/zone events, executive roundtables, and skill-building workshops.

For many participants, the most resonant theme throughout the summit was communication. It surfaced in nearly every discussion as a foundational priority as critical to breaking down silos and building stronger, more consistent channels of connection across regions. Whether through digital platforms, intentional cross-regional collaboration, or clearer value messaging, communication was seen as the key to unlocking NCURA’s full potential.

The summit fostered a collaborative environment for strategic renewal.

It was a space to reflect, imagine, and connect. For newer members, it offered a chance to build relationships and see the breadth of NCURA’s reach. For seasoned leaders, it was an opportunity to challenge assumptions and reframe priorities.

We left the summit invigorated, with a renewed commitment to shaping NCURA’s future together. The work ahead will require courage, creativity, and collaboration, but our members are ready.

As we return to our regions and roles, we carry forward the spirit of Reimagining Community, and the belief that our collective vision can— and will—positively transform our organization. N

Caitlin Crowley is a Research Administrator II at the Boston VA Research Institute, Inc. and 2025 Secretary-Elect for NCURA Region I, where she previously served as Communication and Membership Chair from 2023-2024. She can be reached at caitlin.crowley@bvari.org.

Lauren Gee, MFA, is the Research Administration and Development Manager for the Department of Medicine at the University of Wisconsin-Madison. She is a Board Member at Large for Region IV, serves as Co-Chair of the DEI Committee, and can be reached at lgee@medicine.wisc.edu.

Scott Niles, PhD, CRA is the Manager for the College of Engineering and IRIs team within the Office of Sponsored Programs at the Georgia Institute of Technology. He is currently an At-Large member of NCURA’s Board of Directors. Scott can be reached at scott.niles@osp.gatech.edu.

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Staying Nimble: What the 2024 Uniform Guidance Revision Means for Predominantly Undergraduate Institutions

By Virginia D. Shaffer

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mid shifting federal priorities and program terminations, the Uniform Guidance (the primary regulatory framework for managing federal grants) continues to serve as the backbone of federal grant administration. The Office of Management and Budget’s (OMB) 2024 update of the Uniform Guidance reflects an effort to expand federal funding across a broader range of academic communities while streamlining the administrative burden for recipients. For predominantly undergraduate institutions (PUIs), the revision creates opportunities to simplify internal processes, revise policies, and refocus on what matters most: supporting faculty and student researchers.

For predominantly undergraduate institutions (PUIs), the revision creates opportunities to simplify internal processes, revise policies, and refocus on what matters most: supporting faculty and student researchers.

The Uniform Guidance 2024 revision advances four key priorities: broadening access, reducing administrative burden, encouraging data-driven evaluation, and strengthening program integrity.

Broadening Access To improve accessibility for users without prior experience in federal regulations, the OMB revised much of the guidance’s terminology to enhance clarity and user-friendliness. Less intuitive terms were revised for clarity—for instance, “F&A Cost Recovery” is now “Indirect Costs,” and “Non-Federal Entity” has been replaced with “Recipient.” These linguistic shifts may appear minor, but they play an important role in improving accessibility, particularly for under-resourced institutions that can find federal jargon difficult to navigate. In addition to a net reduction of acronyms and some added definitions, the problematic term “participant” was clearly defined: “An individual who provides no contribution to a federally funded project but receives support (e.g., training, conferencerelated expenses) from that federal award.” This revised definition will undoubtedly help institutions more accurately categorize expenses for project-funded trainees.

The revision also clarifies the long-standing regulation that voluntary uncommitted cost sharing, such as donated faculty time, should not be counted toward direct costs or used in indirect cost calculations. This clarification is important to PUIs, where faculty frequently contribute uncompensated effort. It promotes transparency and helps protect institutions from unintentionally overcommitting resources.

Reducing Administrative Burden Two changes related to reducing administrative burden stand out: the single audit threshold has been raised to $1 million, and the cap on indirect cost recovery for subawards has increased to $50,000. For PUIs partnering with external collaborators on relatively modest subawards, this adjustment should streamline budgeting and reduce compliance stress.

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Encouraging Data-driven Evaluation Promoting the use of data for evaluation and continuous improvement is another welcome focus of the revision. New language explicitly allows awardees to include costs associated with data collection, evaluation, and dissemination as allowable expenses. This better enables PUIs to bolster their program assessment capabilities—an area often overlooked due to budget constraints.

The 2024 revision serves as a reminder that the compliance landscape is not static.

Strengthening Program Integrity Finally, the guidance now requires that whistleblower protections be communicated not just to staff, but to all individuals involved in a project.

Institutions will need to ensure that this information is shared and documented.

Next Steps for PUIs In light of the 2024 revision, PUIs are encouraged to conduct policy reviews to ensure compliance with the updated Uniform Guidance: procurement policies may need to be updated to reflect higher equipment thresholds and include revised terminology; grant management policies should replace outdated terms, raise internal subaward caps (where applicable), and reinforce messaging around voluntary cost sharing and program income.

must instead stretch limited resources. The current wave of regulatory change underscores the need for PUIs to remain nimble—developing creative, scalable strategies to maintain compliance while strengthening academic and community-impact efforts. N

The 2024 revision serves as a reminder that the compliance landscape is not static. This reality places added pressure on PUIs, which lack the specialized regulatory teams found at larger research institutions and

RESOURCE

Virginia Shaffer, MS, CRA, is Director of Sponsored Programs at Wheaton College (IL). She began her journey into the world of grants management while working at the University of North Carolina, Chapel Hill. Virgina can be reached at virginia.shaffer@ wheaton.edu.

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For details and to purchase visit https://onlinelearning.ncura.edu/read-and-explore 18

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The Strategy Time to get down to the details for execution. Develop a list of impacted resources and consider both the internal and external components in your communication plan. This is not a time for trick plays or surprises!

• Step 1: Update internal policies and procedures.

Do you have a procedure for incorporating the revised language?

Do you have a billing procedure document that includes the certification language required for outgoing invoices?

• Step 2: Confirm changes are reflected in forms and tools.

Approaching Regulation Changes

By Carrie Chesbro

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peer reaches out to you and inquires about how your implementation of the updated regulations is going. An anxious, queasy feeling settles in your stomach because you do not know where to begin. Changes, such as the Uniform Guidance updates released in fall 2024, can be daunting without a clear plan for how to tackle them. You need a game plan.

Our example: Revised subrecipient invoice certification language update, Uniform Guidance 2 CFR 200.415(b), formerly (a).

The Game Plan At a high level, the approach appears straightforward: review the guidance change and update procedures as necessary. This is like the approach for winning a football game: score more points to achieve victory. However, we all know that the difference lies in the details, and we will need a strategy for success.

• Step 1: Compare the previous language. o Typically, there is a summary of the changes to use as a guide.

Build a spreadsheet that compares the previous language side by side with the revised language. This will help you quickly identify the changes, giving you time to consider their impacts. Other options include utilizing the “Compare” function in Word or leveraging AI to provide a summation of the changes.

• Step 2: Identify the potential process impact points for each change and note these in your comparison document.

In this example, the certification language change would impact the billing team in our central office, as well as administrators reviewing incoming subaward invoices, the contracts team, etc.

The Team It is important to have the right personnel fulfilling crucial roles in the game plan. Start by identifying key individuals from the impacted areas to include in discussions about the regulation changes. Remember to communicate the plan to your team and brainstorm potential implications together to capture all perspectives and ideas.

• Step 1: Meet to develop a plan for communication and activity tracking. It may be helpful to use a technology tool, such as a spreadsheet or project management software.

• Step 2: Assign actions to specific individuals and set interim deadlines to keep on track. Meet regularly to hold each other accountable and identify issues or areas that require additional support along the way.

• Step 3: Determine the support needed for each activity to ensure it is staffed for success.

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Is there a subaward invoice review checklist for departments to use when reviewing incoming invoices?

Is there an outgoing subaward contract template that includes the language in the invoicing clause?

Did the citation in Uniform Guidance change? Revise any document where the specific citation is referenced.

• Step 3: Create an external communication plan for departments and subrecipients. o Consider how the change affects the daily work of the departmental administrator. Utilize your departmental administrator focus group, if you have one, to set up a meeting with a trusted group from various disciplines to provide feedback. o Provide administrators and investigators with notices via email, as well as regularly scheduled or ad hoc meetings, and other relevant communications.

• Step 4: Update technology, including any system modifications and web resources. o Coordinate your rollout so that all changes go live simultaneously. o Collaborate with your technology teams to ensure they can implement changes as part of the overall game plan. o The web resources are vital given the variety in work schedules for our teams and our subrecipients; information should be readily available.

In our certification language example, does this change require a revision to the standard certification on your outgoing invoice template?

Do you have an online subrecipient toolkit that discusses the certification statement, including the full text and Code of Federal Regulations (CFR) citation?

Game Day With all the planning, preparation, and communication, you have all you need for a high win probability. Stick to the plan and be flexible if changes are necessary to accommodate unanticipated needs. Remember, we are all in this together. Feel free to reach out to your network to discuss options, compare plans, and leverage resources to achieve a win. N

Carrie Chesbro is Assistant Director for Subawards & Subrecipient Monitoring at Stanford University. She has over twenty years of experience in research administration including departmental and central office administration roles, with a focus on compliance, process development, communication, and education. She can be reached at chesbro@stanford.edu.

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Uniform Guidance Revisions: One Year Later and Under New Management

By Gil Tran

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he “Extreme Makeover: 2 CFR Edition” was finalized and revealed on April 22, 2024 (with an update on October 1, 2024). The extreme makeover included revisions to all parts of the 2 CFR Part 200 Uniform Guidance (UG) that include the six subparts (A through F) and twelve appendices (I through XII). OMB revised 69 out of 191 sections, equaling 36 percent of the document (see Figure 1). The effective or “move-in” date was October 1, 2024, meaning that the revisions are now effective for all federal grants awarded after that date.

This article is a one-year look-back on five major changes and their implementation at universities. For these areas, I will summarize the changes, the benefits, the required actions and the challenges of implementation. As a bonus, I will look into the “Tran crystal ball” and predict some future possible revisions of the Uniform Guidance as I listen to the noises, observe the landscapes, and feel the political winds that swirl around the grant policies.

The Major Changes and Their Impact Among the multitude of changes in all the areas of the Uniform Guidance, and based on the questions I received from grantees, I believe that these five areas are most impactful: 1. The Subaward threshold change – 200.1 2. The Subrecipient monitoring requirement – 200.332, 200.415 (b) 3. The Equipment and Supply threshold change – 200.1, 200.313 4. The Unused Supplies revision – 200.314 5. The Administrative salaries, direct charge modification – 200.413 (c) Let’s get into each one of these changes.

The Subaward Threshold Change – 200.1 The change is described in the Definition section of the UG for the “Modified Total Direct Costs” where the previous threshold for the subaward is increased from $25,000 to a maximum of $50,000. This change allows you (the grantee) to recover more indirect costs that reflect the administrative resources consumed for administering subawards.

Some considerations for your implementation: • The threshold of $50,000 is a maximum (or ceiling) and is not a requirement so you can decide whether or when your institution wants to go for the higher threshold.

• The higher threshold is only effective when a proper rate agreement is renewed. If you have a predetermined rate through fiscal year 2028, the increase in threshold can only occur for fiscal year 2029.

If you are unsure of the current threshold, check the definition of modified total direct costs on your rate agreement.

• If you elect to go with the higher threshold, as reflected in your rate agreement, you will need budget changes and system changes for proper charging of indirect costs at the $50,000 level.

The Subrecipient Monitoring Requirement – 200.332, 200.415 (b) From the federal government’s perspective, the subrecipient monitoring responsibility for the grantee has always been an area of importance since the creation of the Uniform Guidance in 2013. The reason is simple—the federal agencies do not have a relation with the subrecipients and rely totally on you to manage/monitor the subrecipients. It was reinforced by the Federal Funding Accountability and Transparency Act (FFATA) in 2006 that requires all kinds of reporting on subawards in SAM.gov. This

Figure 1. Summary Count of Revisions by Subpart

TITLE Subpart A

Acronyms and Definitions

Subpart B

General Provisions

Subpart C

Pre-Federal Award Requirements and Content of Federal Awards

Subpart D

Post Federal Award Requirements

Subpart E

Cost Principles

Subpart F

Audit Requirements

Appendix

Various

Total 22

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NUMBER OF SECTION WITH CHANGES

PERCENTAGE OF CHANGES

2

100%

4

29%

8

47%

25

53%

18

23%

6

27%

12

6

50%

191

69

36%

NUMBER OF SECTIONS 2 (200.0-200.1) 14 (200.100-200.113) 17 (200.200-200.216) 47 (200.300-200.346) 77 (200.400-200.476) 22 (200.500-200.521)

revision continues to focus on subrecipient monitoring by adding stronger language that includes ensuring the subrecipient is not suspended/ debarred or otherwise excluded from receiving federal funds, has completed the “goals and objectives of the subaward,” and requiring notification to funding agency of imposition of additional Terms and Conditions (T&C) on subrecipients. Another addition to section 200.415 (b) now requires the subrecipient (inclusive of all tiers) to submit a certification of compliance to you as the pass-through entity (similar to your certification to the federal government) whenever applying for funds, requesting payment, and submitting financial reports.

The good news here is that many grantees have systems already in place to efficiently monitor and report on subrecipients spending and performance as the results of the 2013 UG provisions, the implementation of FFATA and the many single audits performed in this area. Thus now, you only need to update the current monitoring systems and continue your vigilance for compliance in this area.

The Equipment and Supply Threshold Change – 200.1, 200.313 Equipment and supply threshold level is another change for you to decide on the proper level at your institution. The new threshold is $10,000.

Again, this is not a requirement, and similar to the subaward threshold change, it can only be implemented with a new rate agreement. The change is impactful because as it can drastically reduce the number of equipment items that are required to be inventoried and properly disposed under section 200.313 (d) and (e) thus possibly reducing significant administrative burden. It also increases the amount of indirect costs recovered on the project since more items are now treated as supplies.

Based on my conversations with grantees, many have elected not to go (or are delaying implementation) with the higher equipment thresholds because they want to be consistent with their state or financial statement reporting level for capitalization of equipment. Some feel that its current level of $5,000 is necessary for adequate control of property.

The Unused Supplies Revision – 200.314 As the revision allows a higher threshold for equipment, the amount for supplies on a project will grow relatively. The amount of unused supplies at the end of the project can also be greater, up to $10,000 from $5,000 previously. The rules for unused supplies are simple: • If the aggregate value of unused supplies is equal or less than $10,000, then there is no requirement to account for it.

• If that amount is more than $10,000 and the supplies are needed and planned to be used on other federal projects, then you do not need to account for them. That means that there is no reduction of reported expenditure on the project other than a note to list the project(s) that will benefit from the unused supplies.

• If there is no need for unused supplies on federal projects, then you can sell the supplies and keep a portion of the sales. The federal government will receive credit for a portion of the sales as well.

A major change that needs your attention is the definition of “aggregate value” for the unused supplies. The new definition combines all the types of supplies in the total aggregate value, instead of counting just one type of supply. This may result in the total aggregate value being higher than $10,000 more frequently and thus require some accounting of the unused supplies (as described in the 2nd and 3rd bullets above).

The Administrative Salaries, Direct Charge Modification – 200.413 (c) By far, the most frequently asked question about the new revisions is the change to the direct charge for administrative salaries on federal projects.

Specifically, the revision deletes the requirement for prior approval by the federal sponsor (or have the costs clearly listed on the proposal budget)

for administrative salaries. This removes one of the four conditions (item 3) previously listed in section 200.413 (c) to direct charge administrative salaries to a special project. This change has great potential in reducing the administrative burden and provides greater flexibility for you to charge salaries in direct support of complex programs. However, be aware that with that “power,” the responsibility is assigned to you (instead of the agency with its review and approval) to justify and document the direct benefit to the project and confirm the costs are not already recovered under the indirect costs.

Research will benefit if principal investigators spend more time doing research and not research administration. This change provides you the flexibility to accomplish that goal, but be aware of the requirements for documentation and consistency of cost treatment.

Future Revisions to the Uniform Guidance As we are now comfortably settling in with this extreme makeover version of the Uniform Guidance, there are already signs that OMB is drafting architectural plans for another round of renovations or reconstructions —as soon as this coming winter. The reasons for the possible upcoming revisions are: • OMB states in its final revision on April 22, 2025, four areas for future update considerations such as the requirements for research security and the challenges related to indirect cost negotiations.

• The April 2024 revisions contained references and objectives from five executive orders issued by the Biden administration, which are now rescinded by this Administration (EO 13988, EO 13985, EO 14057, EO 14094, EO 14091).

• The new EO 14332 – Improving oversight of federal grantmaking, August 7, 2025, requires OMB to redesign the grant award approval process, strengthen the termination for convenience clause (section 200.340 (a)), and restrict the recovery of indirect (F&A) costs.

Conclusion In conclusion, the UG revisions of April 2024 are now effective for all grants starting on October 1, 2024, though some changes depend on the approval of the rate agreement. Your action items are: • Evaluate the revisions and implement them accordingly.

• Update and document, in writing, all changes since failure to update the policies will certainly result in future audit findings and possible paybacks. For some universities, the Disclosure Statement DS-2 (if applicable) is a good and convenient place to update all current policies and procedures.

• Check the 2025 Compliance Supplement (an annual guide to the auditors of grants) to recognize the focus areas by the federal government. For example, subrecipient monitoring has always been an area of concern in past compliance supplements.

Most of all—the future of research depends on you—the Research Administrators. The nation cannot thank you enough for your dedication and your belief in what you do for research. So, stay active and engaged, stay alert and informed, and stay vigilant on compliance. Be ready for the next waves of UG renovations. N

Gil Tran, CPA, Senior Specialist Leader at Attain Partners, is a 27-year veteran of OMB. He played an integral role in the development of the 2013 Uniform Guidance. Gil started his grant career as a research administrator at Georgetown University. He can be reached at hmtran@attainpartners.com.

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Implementing Uniform Guidance 2024 Revisions: Updates from the University of Maine

By Stefania Irene Marthakis

O

n October 1, 2024, the Office of Management and Budget (OMB) released the most significant revisions to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the government-wide framework for grants management commonly referred to as “Uniform Guidance” [UG]) since its inception in 2014. This current revision of the UG aimed to (1) incorporate statutory requirements and administration priorities, (2) reduce agency and recipient burden, (3) clarify sections that recipient or agencies have interpreted in different ways, and (4) rewrite applicable sections in plain language to improve flow and address inconsistent use of terms within the guidance.

At the University of Maine (UMaine)—a Carnegie R1 Top-Tier Research University—the University of Maine Systems Offices and the Office of Research Administration (ORA) reviewed the 2024 UG revisions. Due to recent federal changes, limited resources, and the complexity of the revisions, UMaine’s responses have been diverse, taking into consideration the specific requirements and consequences of each individual revision.

UMaine’s responses to the revised UG have been diverse, taking into consideration the specific requirements of each individual revision.

There are some UG 2024 revisions with limited to no impact on UMaine practices. As a university that receives substantial funding, the increased single audit threshold (raised from $750,000 to $1,000,000) is not a significant change. Since UMaine has a federally Negotiated Indirect Cost Rate Agreement (NICRA), the updated de minimis rate from 10% to 15% also does not directly affect UMaine. It does impact some subrecipients named on UMaine awards. ORA has seen smaller organizations without a NICRA use the updated de minimis rate of 15% to the benefit of their budget.

There are two areas of the revised guidance that do reduce administrative burden for UMaine. With the removal of the requirement for Institutions of Higher Education that receive $50 million or more in Federal awards to file a DS-2, UMaine no longer needs to submit this form. While UMaine does not issue many fixed price subawards it welcomes having one less sponsor approval request as a consequence of the $500,000 threshold increase on fixed amount subawards.

UMaine currently emphasizes revisions that focus on compliance and the safeguarding of information. ORA meets with procurement team members regularly to address the prohibition on telecommunications, which impacts contract terms during award review. Cybersecurity measures are also set in place through Systems IT. Cybersecurity is a 24

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rapidly evolving field; Systems IT continues to learn and adapt, which is a necessity for universities in today’s digital landscape.

UMaine adheres to revisions that focus on compliance and the safeguarding of information.

There are two noteworthy UG 2024 revisions that increase spending thresholds and which would impact different universities in different ways: (1) Modified Total Direct Costs (MTDC) was updated to exclude subaward costs over $50,000 from the previous limit of $25,000; and (2) the capital equipment threshold was raised from $5,000 to $10,000, with expenses less than $5,000 moving to supplies. The previous thresholds had been in place since shortly after the 1996 revision of OMB circular A-21; any process by UMaine to implement the new thresholds would directly affect its next negotiated NICRA. Like most universities, UMaine’s indirect cost rate is based on MTDC. Any adjustments affecting UMaine’s MTDC will have to be negotiated with the Department of Health and Human Services (DHHS) as part of an intricate planning process to update the indirect cost rate. To incorporate any threshold adjustment, therefore, one of two things needs to happen: (1) negotiate a new indirect rate or (2) negotiate an extension of the current rate agreement. For some universities, there might be little benefit to higher thresholds, since adjusting thresholds could increase the direct cost base, which would lower the indirect rate that universities could charge.

Currently, UMaine is negotiating a four-year extension of their current NICRA, which will include the new threshold for subawards. Once completed, any amended rates and terms will be retroactive for all new awards as of July 1, 2025. As for the capital equipment revision, the threshold of $5,000 will remain unchanged until at least FY2029.

UMaine anticipates any adjustments to the subaward and capital equipment thresholds would result in implementing these new limits into actual accounting system changes. For example, adjustment to allocation rules, changing cost pools, and new accounting codes would be required.

UMaine is committed to finding the best processes on how to implement uniform guidance revisions to support scientific research. N Stefania Irene Marthakis is a Grant and Contract Administrator in Pre Award Services at the University of Maine. Stefania has also worked on seven National Science Foundation grants; providing administrative, fiscal, reporting, communication, and project management support. Her science-related articles can be found at https://www.simarthakis.com/articles, and she can be reached at simarthakis@maine.edu.

67th Annual Meeting

August 10–13, 2025 Washington, DC

Nearly 1,400 research administrators gathered at the Washington Hilton for NCURA’s 67th Annual Meeting (AM67), embracing the theme Forward Focused: Priming for Change. This year’s program reflected not only the rapidly evolving research environment but also NCURA’s enduring commitment to Supporting Research … together.

A WELCOME HOME

The opening event was designed to foster friendships, both old and new. In conjunction with NCURA President Denise Moody, we were delighted to welcome everyone to Sunday evening’s Welcome Home Dinner. Volunteers were celebrated for their contributions across committees, task forces, conferences, training, publications, and governance.

“Look around,” Moody said, as volunteers raised their hands across the ballroom. “This is what makes NCURA so special. It’s all of us— helping each other because we are committed to our profession and our community.”

SUPPORTING RESEARCH THROUGH CHANGE

Monday morning opened with NCURA Executive Director Kathleen Larmett affirming the strength of the NCURA community amid times of uncertainty. From 9/11 through hurricanes and the pandemic, she reflected, NCURA has consistently stepped up to support colleagues and institutions. She spotlighted programs such as the NCURA Bridge Fund, First Week career resources, and the Navigating Change Conversations webinar series as examples of how NCURA continues to meet members where they are.

President Denise Moody expanded on these commitments, reflecting on a year of challenges and growth. “Our Board of Directors has spent this year focused on NCURA’s strategic plan,” she said. “In keeping with the theme Forward Focused – Priming for Change, we are thinking 3–5 years ahead in all of our conversations and decisions.”

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67th Annual Meeting

AM67 PROGRAM COMMITTEE (pictured left to right)

Shannon Sutton, Georgia State University, AM67 Chair

Shannon

Katherine

Candice

Leah

Katherine Durben, Marquette University, AM67 Co-chair Candice Ferguson, Georgia State University, AM67 Co-chair Leah Acajabon, Attain Partners Sybile Bayiha, University of Maryland

Sybile

Vincent

Sylvia

Alpana

Vincent Borleske, University of Arizona Sylvia Bradshaw, Southern Utah University Alpana Dave, National Institute of Biomedical Genomics Jeremy Forsberg, The University of Texas at Arlington

Jeremy

Sandra

Jill

Kathleen

Sandra Fowler, University of Wisconsin-Madison Jill Frankenfield, University of Maryland, Baltimore Kathleen Halley-Octa, Attain Partners Liliana Keany, Howard University

Liliana

Katherine

Danielle

Tanta

Katherine Kissmann, Texas A&M University Danielle McElwain, University of South Carolina Carpantato “Tanta” Myles, Georgia Institute of Technology Scott Niles, Georgia Institute of Technology Dennis Paffrath-Nelson, Temple University

Scott

Dennis

Keith

Robyn

Keith Page, Washington University in St. Louis Robyn Remotigue, University of North Texas Health Science Center at Fort Worth Stacy Riseman, College of the Holy Cross

Stacy

Denise

Michelle

Laina

Denise Rouleau, Cummings School of Veterinary Medicine at Tufts University Michelle Schoenecker, University of Wisconsin-Milwaukee Laina Stuebner, University of Wisconsin-Green Bay Garrett Steed, University of Colorado Denver Lisa Stroud, University of Florida

Garrett

Lisa

Curtis

Julie

Curtis Van Slyck, Northeastern University Julie Ward, University of the Sunshine Coast

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August 10–13, 2025 August 10–13, 2025 Washington, DC Washington, DC

EDUCATION AND KNOWLEDGE EDUCATION AND KNOWLEDGE

Many amazing educational sessions were offered through eleven unique Many amazing sessions were offered through eleven unique tracks.

Offeringseducational included a range of opportunities from workshops and tracks.

Offerings included a range of opportunities from workshops and concurrent sessions to discussion groups and breakfast roundtables. concurrent sessions to discussion groups and breakfast roundtables.

In addition, attendees gained insight from two nationally recognized In addition, attendees gained insight from two nationally recognized keynote speakers: keynote speakers: • Amy Walter, publisher and editor-in-chief of The Cook Political Report, • delivered Amy Walter, and editor-in-chief of The analysis Cook Political Report, thepublisher Monday morning keynote, offering of Washington’s delivered the Monday morning keynote, offering analysis of Washington’s shifting political climate and what it means for the future of science and shifting political research policy. climate and what it means for the future of science and research policy.

• Paul Begala, political strategist and CNN commentator, provided the • Monday Paul Begala, political strategist and CNN commentator, provided lunch keynote, encouraging attendees to see beyond thethe headlines Monday lunch keynote, encouraging attendees see beyond the headlines and focus on the deeper forces shaping federal to decision-making. and focus on the deeper forces shaping federal decision-making.

Both speakers encouraged the research administration community to Both speakers encouraged research us administration community to continue to have hope. Theythe challenged to better inform the public continue to have hope.

They challenged us to better inform the public about the excellent scientific research and innovation produced daily by our about theuniversities excellent scientific research and innovation produced daily by our colleges, and institutes. colleges, universities and institutes.

This year’s winner of the Discovery and Innovation Showcase also exemplified This year’s winner of the Discovery and Innovation Showcase also exemplified knowledge and education by leveraging artificial intelligence (AI) in the knowledge and education by leveraging artificial intelligence (AI) in research space. Congratulations to the team of Emily Devereux, Lumithe Bakos research space. Congratulations to the team of Emily Devereux, Lumi Bakos and Alex Teghipco, all from the University of South Carolina, on their awardand Alex Teghipco, all from the University of South Carolina, on their awardwinning project. A big thank you goes out to all who took part in winning project. A big thank you goes out to all who took part in the Showcase! the Showcase!

COMMUNITY AND CONNECTION COMMUNITY AND CONNECTION

Beyond the plenaries and sessions, AM67 was infused with opportunities to Beyond the plenaries and AM67 was infused with opportunities build community.

From thesessions, Family Reunion Event with backyard games, toto build community.

From the Family Reunion Event with backyard games, to the regional networking events, to informal hallway conversations, attendees the regional networking events, to informal hallway conversations, attendees embraced the “Welcome Home” spirit. As Sutton reminded members “NCURA embraced theand “Welcome spirit.stronger As Sutton reminded members “NCURA is like a family, we areHome” better and working together.” is like a family, and we are better and stronger working together.”

We honored our Federal Partners (pictured left Weright), honored our Federal Partners (pictured NSF left to Michelle Bulls, NIH, Jean Feldman, to right), Michelle Bulls, NIH, Jean Feldman, NSF and Gil Tran, formerly OMB, now Attain Partners, and Gilleadership Tran, formerly now Attain whose and OMB, dedication have Partners, been whose leadership and dedication have been anchors for our community. anchors for our community.

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67th Annual Meeting

August 10–13, 2025 Washington, DC

LOOKING FORWARD

The meeting closed with NCURA’s Annual Business Meeting, where members reflected on accomplishments and looked ahead to strategic initiatives. The volunteers, Board of Directors, and staff were recognized for their tireless work in ensuring that NCURA remains both responsive to members’ immediate and upcoming needs in shaping the profession’s future.

A SHARED PURPOSE

From celebrating volunteers and awardees to tackling the complexities of federal policy, AM67 reinforced the core of NCURA’s mission: advancing research administration through education, collaboration, and community.

As Moody put it, “We may be forward focused, but we’re also present—rooted in the joy of connection and the comfort of shared purpose.”

And with that, NCURA members left Washington, D.C., inspired, recharged, and primed for change—ready to support research, together.

Shannon

Katherine

Candice

Shannon Sutton Georgia State University NCURA Vice President & AM67 Chair

Katherine Durben Marquette University AM67 Co-Chair

Candice Ferguson Georgia State University AM67 Co-Chair

Thank you Kuali, NCURA Silver Year Long Sponsor, who offered professional headshots during this year’s Annual Meeting!

NCURA APP PODCASTS: Check out two new podcasts exclusively on the NCURA App featuring Amy Walter, publisher and editor-in-chief of The Cook Political Report, who delivered the Monday morning keynote and Paul Begala, political strategist and CNN commentator, who provided the Monday lunch keynote, in separate episodes. The podcasts will be pinned to the top of the newsfeed through the end of this year.

Don’t have the NCURA App yet? Download it today!

Android Users or Apple Users

ORDER YOUR COPY!

L

eadership and management are complicated. The “soft stuff” of managing people can be the most challenging aspect. NCURA has a new resource to help!

In this new publication, we discuss the principles of research administration, the art of leadership, the skills of communication, the management of personnel, and the importance of people skills.

TOPICS INCLUDE: CHAPTER 1:

THE CHALLENGE OF RESEARCH ADMINISTRATION

CHAPTER 2: THE ART OF LEADERSHIP IN RESEARCH ADMINISTRATION CHAPTER 3: COMMUNICATION: THE MOST IMPORTANT LEADERSHIP SKILL CHAPTER 4: CIVILITY AND THE LANGUAGE OF EFFECTIVE LEADERSHIP CHAPTER 5: KINDNESS: A COROLLARY TO CIVILITY CHAPTER 6: WORKING WITH DIFFICULT BOSSES CHAPTER 7:

WORKING WITH DIFFICULT EMPLOYEES

CHAPTER 8: FIGHTING BURNOUT CHAPTER 9: CLIENT SERVICES AND THE FUNDAMENTALS OF RESEARCH ADMINISTRATION CHAPTER 10: RECRUITING AND RETAINING TALENTED STAFF NCURA Magazine

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NCURA Education Scholarship Fund Select Committee (ESFSC)

Open Doors

I

t might come from giant leaps of faith or from baby steps. You might take that big scary job promotion or move to that new city. You might stay with one organization for your entire career or live in the same city all your life. All the choices that we make will lead down many different paths.

I dreamed of being a registered nurse. As a first-time college attendee in my family, I chose to support myself while obtaining my bachelor’s degree and secured a position at a university that supported my professional goals of being in the healthcare setting. Little did I know accepting this job would not only change my decision to be a nurse but would provide me with a rewarding career surpassing 25 years and counting. While working and going to school I have had the privilege of working with many amazing professionals and realizing my full potential.

NCURA is not only a networking and learning platform, but it also is a place where professionals from across the world can come together to share experiences, collaborate, and most importantly, to learn from each other.

Somewhere along the way, someone believed in me and my educational goals changed from nursing to business. A new door opened. I had no idea what a grant manager was, however, I was given an opportunity that more than 15 years later is my career path and exactly what I love doing every single day. One door opens, and then another, and another, and this is where NCURA comes in. A membership to an organization dedicated to advancing the profession of research administration opened another door. NCURA is not only a networking and learning platform, but it also is a place where professionals from across the world can come together to share experiences, collaborate, and most importantly, to learn from each other. The NCURA annual meeting is where I heard about a master’s degree in research administration.

Some days I wish I had become a registered nurse because caregiving is a big part of who I am, and I believe that being a research administrator also is about caring. I know that I care about my faculty and their success.

Without faculty, successful grant funding, sharing knowledge and experiences, and people empowering one another, we would not have NCURA or successful careers supporting the future of research administration— just like the NCURA Education Scholarship has done for me.

Everything you do contributes to forward movement, whether it be that day, the next week or the following year…we all have bright futures and with amazing support from NCURA the possibilities are endless. Thank you to the NCURA Education Scholarship Committee for selecting me and many others for the Education Scholarship. N

Brandi Freeman is a Senior Research Administrator at the University of Arkansas for Medical Sciences (UAMS). Brandi has been employed at UAMS for more than 25 years and has worked in grants administration for over 15 years. She has a bachelor’s degree in business administration and has the Certified Research Administrator certification. Brandi has maintained a 4.0 GPA while working on her master’s degree in research administration at the University of Central Florida and will graduate in Spring 2026.

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Research Administration in Europe

2025 -

The Year of the Snake?

By Ellen Thompson

I

n the current climate, it is hard for those of us working in entities outside of the U.S. to recall the changes made in the Uniform Guidance just last year. 2025 has definitely been the year of the snake for foreign recipients of U.S. federal funds. More specifically, the Coastal Taipan snake nicknamed Whiplash, currently residing at the Australian Reptile Park in Sydney, Australia, and holding the record for the largest venom yield (Australian Reptile Park, 2022).

Why is that? One may ask. We just need to look at the federal funding policy whiplash in 2025 thus far: • January 2025: NIH communication ban and federal funding freezes. Those of us due to attend the NIAID-led and King’s College London-hosted NIH workshop in London, UK, remember the NIAID pulling out at the 11th hour. Fortunately, King’s College London re-organized the workshops themselves. Let’s also not forget the DOGE and cuts to existing funding programs and grants that do not meet the current administration’s priorities (Science Insider, 2025).

• February 2025: NIH cap on indirect costs to 15% (and associated temporary restraining order) and the dismantling of USAID (National Institutes of Health [NIH], 2025a).

• March 2025: Questionnaires sent to foreign organizations from CDC, U.S. Department of State, and U.S. Geological Survey (League of European Research Universities [LERU], 2025).

• April 2025: Department of Energy cap on indirect costs to 15% (yet another temporary restraining order) (U.S. Department of Energy, 2025).

• May 2025: NSF funding freeze and, more importantly, the NIH policy changes for foreign sub-awards (NIH, 2025b).

Whilst this whiplash has primarily occurred in 2025, one must look further back to see rumblings as to what has brought this on, namely, back to 2020 and the COVID-19 pandemic. Given the murky origins of the pandemic, particularly concerning the EcoHealth Alliance-WIV grant, NCURA Magazine

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there has been increased focus on who the NIH is disbursing funds to (EcoHealth Alliance, 2024). The way the NIH projects have historically worked is to disburse funds to the Pass-Through Entity (PTE) or Prime recipient of the award, who in turn establishes subaward agreements with collaborators, both domestic and foreign. The NIH themselves deal solely with the PTE, who in turn is responsible for the subawards who nest under the primary award. Consequently, the NIH does not have direct oversight of where subrecipient funding is sent, both in terms of countries and individual organizations.

In 2023, the NIH took baby steps to try to counter this, by issuing NOT-OD-23-133, which codified the need for all Sub-Recipients to provide access to their lab research materials, although they were keen to stress this was a clarification of an existing policy, rather than a new policy in its entirety (NIH, 2023).

In late 2023, the Office of Inspectorate General (OIG) of the DHHS performed a review of a sample of 2019 and 2020 single audit reports from foreign organizations. They found that only 28 out of the sampled 109 had been received by December 2023. Further to this damning report, another NIH NOT was released in 2024, NOT-OD-24-151. This particular NOT codified the need for all foreign organizations that expend more than $750,000 in federal awards during their fiscal year to conduct either a single audit in accordance with 2 CFR 200 Subpart F or a program-specific audit effective 1 October 2024. This was a change from the existing audit threshold, which was $750,000 per annum in DHHS funding only (NIH, 2024). Those of you now receiving Management Decision Letters from the DHHS Division of Financial Advisory Services regarding their Single Audit reports know that at least these Single Audit reports are being reviewed at a federal level and actions taken on the findings if necessary.

The new administration in 2025 did not consider this sufficient to counteract the perceived risks of these foreign subrecipients, so in May 2025, NOT-OD-25-104 was released which prohibited ANY new awards to foreign subrecipients, and NO annual renewals, meaning all those multi-year awards would not be extended into a new year. Direct awards to foreign Prime Organizations were not impacted, assuming the research

aims did not contradict the administration’s aims (NIH, 2025b). From 30th September 2025, the NIH is aiming to launch a new platform whereby foreign organizations can apply directly for their own element of a project (and the NIH can thereby have oversight of where their funding is going), but details are scant, so who knows what will happen by the time this article goes to publication.

At a less granular level, the Uniform Guidance overhaul, with effect from 1 October 2024, does have some amendments which impact foreign organizations: • The Single Audit threshold increase from $750,000 to $1,000,000.

As discussed above, the NIH NOT-OD-24-151 has superseded these, and the audit threshold for foreign organizations remains at $750,000 in annual federal expenditure.

• The definition of equipment has increased from $5,000 to $10,000 (which may allow more F&A costs).

• The De Minimis indirect costs rate has increased from 10% to 15% (although not for NIH projects, whose F&A for foreign organizations remains at 8% modified total direct costs).

• Indirect costs on Sub-Recipients have increased from $25,000 to $50,000 (more F&A on the first $50,000 to each Subrecipient).

Whilst 2025 has been the year of the snake, we can only hope that 2026 will be the year of the horse—powerful, yet adaptable, with a herd mentality. We’re all in this together. N

References

Australian Reptile Park. (2022, January 14). Australian Reptile Venom Program has giant record break. https://www.reptilepark.com.au/about/zoo-news/venom-programhas-giant-record-break EcoHealth Alliance. (2024, June 3). EcoHealth Alliance’s response to recent allegations. https://www.ecohealthalliance.org/2024/06/ecohealth-alliances-response-to-recentallegations League of European Research Universities. (2025, March 21). LERU members receive questionnaires about US research projects. https://www.leru.org/news/leru-members-receive-questionnaires-about-us-research-projects National Institutes of Health. (2023, October 1). NIH updated policy guidance for subaward/consortium written agreements (NOT-OD-23-133). https://grants.nih.gov/ grants/guide/notice-files/NOT-OD-23-133.html National Institutes of Health. (2024, July 17). Single audit requirements for foreign recipients and subrecipients of NIH grants (NOT-OD-24-151). https://grants.nih.gov/ grants/guide/notice-files/NOT-OD-24-151.html National Institutes of Health. (2025, February 7). Supplemental guidance to the 2024 NIH Grants Policy Statement: Indirect cost rates (NOT-OD-25-068). https://grants.nih. gov/grants/guide/notice-files/NOT-OD-25-068.html National Institutes of Health. (2025, May 1). Updated NIH policy on foreign subawards (NOT-OD-25-104). https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html Science Insider. (2025, January 22). Trump hits NIH with ‘devastating’ freezes on meetings, travel, communications, and hiring. https://www.science.org/content/article/ trump-hits-nih-devastating-freezes-meetings-travel-communications-and-hiring U.S. Department of Energy. (2025, April 11). Department of Energy overhauls policy for college and university research, saving $405 million annually for American taxpayers. https://www.energy.gov/articles/department-energy-overhauls-policy-college-and-university-research-saving-405-million?_ ga=2.114315911.1491524680.1755878763-911989632.1738311165

Ellen Thompson is a Senior Grant Audit Manager at LEES Chartered Certified Accountants, specialising in the audit of UK, European and US federal auditing. Ellen is alumni of the University of Stirling (Scotland) and University of Massachusetts – Amherst. Ellen is Treasurer of NCURA Region VIII and co-champion of the ARMA (UK) Audit Special Interest Group. She can be reached at e.thompson@ leesaccountants.co.uk.

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San Juan SAVE

THE DATE!

PUERTO RICO 2026

Financial Research Administration Conference

FRA/PRA Workshop Day

Pre-Award Research Administration Conference

March 19-20

March 21

March 22-23

CONFERENCE REGISTRATION OPENS IN NOVEMBER!

National Council of University Research Administrators

A Time for Self-Care: Reigniting Energy and Positivity in Research Administration

By Laura Rosales

T

he past six months have felt like six years—a relentless stretch of stress, shifting policies, and Zoom fatigue. It has been a trying time for research administrators as the new federal leadership has turned our world upside down. Additionally, colleges and universities are scrambling to pivot their policies and operations in this new era, with cancellations of grants, few-to-no new funding opportunities, and the looming thought of our Facilities & Administrative (F&A) rates being drastically cut. And let’s not forget the policy changes being dropped on Fridays, after spending the week trying to navigate institutional budget cuts and layoffs, all while trying to keep the research administration team motivated. Our world has become a lot of doom and gloom lately!

As I talk with my colleagues across my institution and at others, it’s pretty much the same. We are all feeling stressed, drained, and exhausted!

As a departmental leader, I meet weekly with my chair. Last week, before we ended our virtual meeting, he asked if I was ok. I have never had a poker face, and I knew he could see right through me. I told him I was ok, but I was just tired of feeling stressed all the time. He told me that I should be doing self-care. We should all be doing self-care during this time. He was doing self-care daily. He loves to work out and has been doing so daily to help relieve stress. What’s funny is I would have never imagined my chair, who is very scientific, academic, and a workaholic, using the word self-care! My chair’s comment to me was a wake-up call!

Over the years, I’ve read so many books about self-care. I thought, why am I not doing what I’ve read?

When I need motivation or inspiration related to my work-life, I look up those who motivate or inspire me: Adam Grant, Simon Sinek, Dan Harris, Daniel Pink, Angela Duckworth, and John Maxwell. When I read their books, visit their website, or listen to their TED Talks, they light a spark and get my brain going again.

Here are a few ways I’ve found to rekindle engagement, both for myself and my team.

• Find the experts – If you don’t already know what each of your staff members likes to do, ask them. Some may like to organize, while others may want to write, and others may like to be the team cheerleader and plan birthdays and luncheons. Let them serve as leads to some of these ideas, but don’t volunteer anyone. Self-care can become a “work assignment” if not considered.

• Process Improvement – Perhaps the proposal review process may not be working as smoothly. So, we quickly identify how to tweak the process for improvement and go on. But what about a thorough review of all your current work processes? This is usually at the bottom of the list, and we rarely have time for it. Now’s the time to do a deep dive and review your current work processes. Revise the ones that have not been working well and never had time to develop standard operating procedures. How about now?

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• Revise Your Departmental Webpage – Do you have a departmen-

tal website where you have procedures, policies, reference materials, etc.? Update it! Ask team members to identify the areas they would like to update.

• Implement AI – What research administration processes can you automate with AI? For inspiration, check out the NCURA YouTube Tuesday videos by Lori Ann Schultz from Colorado State University.

Encourage your team members to incorporate AI into their jobs.

• Onboarding and Training – Refine and document your onboarding and training, especially for a virtual environment. Develop checklists. Develop easy reference guides for staff and faculty.

• Luncheon Meetings – Everyone wants to work from home, but for the days staff are in the office, add in some happy hour and team building time. I believe “breaking bread” helps build a team environment. Perhaps once a month, you can have everyone work in the office on the same day for an in-person lunch. No departmental funds for food? How about potluck? Encourage the staff to bring discussion topics and have open dialogue.

• Celebrate – Always make sure to celebrate wins, even small ones, such as when that large, multi-Principal Investigator, cooperative grant proposal got submitted. Celebrate again when it gets funded!

And, of course, don’t forget to celebrate birthdays, graduations, and service anniversaries.

You need to take time to do the things you love, too! They are those things that put us in the zone. We get lost and forget about time. For me, it’s watching Hallmark movies, especially the Christmas in July ones. How can you not feel good after watching a Christmas movie? For me, there’s just something about a decorated Christmas tree, hot cocoa, and gingerbread cookies that warms my heart! What else do I love to do? Binging on Netflix; seeing a new movie at the theatre; doing a 1,000-piece puzzle; doing arts and crafts; reading motivation, leadership, and self-care books; getting lost in Barnes and Noble; going to a flea market or resale store; journaling; having a spa day!

Only you can rediscover what brings light back into your day. I hope my journey and small joys—from Hallmark movies to puzzle marathons— inspire you to do the same for yourself and your team. N

Laura Rosales, Ed.D., MBA, CRA is the Administrator for the Department of Molecular and Human Genetics at Baylor College of Medicine (BCM). With over 30 years of higher education experience, she has worked in fiscal affairs, student services, departmental administration, and research administration, both in the central and departmental offices. Laura has been a member of NCURA since 2001. She can be reached at laura.rosales@bcm.edu.

A Guide to Effective Strategies and Recommended Practices

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COLLIDING AUTHORITIES: Navigating Uniform Guidance and Recent Federal Actions

By Roseann Luongo, Karen Johnson, Jeremy Forsberg, and Lisa Mosley

Introduction

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he federal research landscape has always been dynamic, but 2025 has brought a particularly unsettling and uncertain environment for research institutions. Executive orders (EOs) and agency directives are diverging from, and in some cases contradicting, the Office of Management and Budget’s (OMB) Uniform Guidance (UG). For institutions and their compliance offices, this divergence translates into heightened operational, financial, and compliance risks.

This article explores recent federal actions, identifies key areas of conflict with the UG, examines implications for the research community, and highlights practical strategies institutions can take during this period of uncertainty.

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Executive Orders and Agency Actions Since January 2025, a series of executive orders have reprioritized federal research funding, targeting research related to Diversity, Equity, and Inclusion (DEI), “gender ideology” initiatives, climate change, and increasing scrutiny of foreign collaborations. Moreover, the EOs have granted federal agencies unprecedented flexibility and authority to align funding with administration priorities and policies.

To enforce the mandates, the OMB issued a memorandum in January 2025 pausing certain grant funding until agencies could certify alignment with the new directives. Although the memo was rescinded on January 29, 2025, the White House clarified that this rescission did not lift the underlying federal funding freeze policy, which remains in effect per the administration’s executive orders.

More recent executive orders continue to disrupt the research enterprise in multiple ways: interrupting award lifecycles, delaying or eliminating funding, causing uncertainty around compliance, and adding new layers of administrative burden. These developments have introduced a volatile and fragmented regulatory environment, forcing institutions to adapt quickly while managing increased operational, financial, and compliance risks.

Federal agencies have responded to these EOs differently, leaving institutions to navigate conflicting signals and policies.

For example, NIH imposed a 15% indirect cost cap, applied both retroactively and prospectively, until a federal injunction paused implementation. NSF, DOE, and DoD introduced their own versions of the indirect cost restrictions. Some agencies have included award-specific actions such as “stop work” orders, prohibitions on public communication, and instructions for institutions to self-identify potentially noncompliant awards.

The Improving Oversight of Federal Grantmaking Executive Order, issued on August 7, 2025, marks a significant shift in federal grantmaking policy, introducing sweeping changes aimed at increasing oversight, streamlining operations, and aligning discretionary awards with national priorities (The White House, 2025). At its core, the order mandates that senior political appointees exercise independent judgment in reviewing and approving funding opportunity announcements, effectively politicizing the grantmaking process. This elevation of strategic oversight places discretionary awards under heightened scrutiny, raising concerns about the impartiality and scientific integrity of future funding decisions.

Operationally, agencies are now required to implement formal review processes that include senior leadership, subject-matter experts, and interagency coordination. These changes will likely necessitate new workflows, staffing adjustments, and extensive training to meet compliance expectations. The timeline for building these processes remains uncertain.

Still, the temporary restriction on issuing new funding announcements without senior appointee approval could delay or disrupt existing grant cycles, creating administrative bottlenecks and uncertainty for research institutions.

The executive order also emphasizes the need to reduce redundancy and complexity in funding announcements. Agencies must now write calls in plain language and coordinate to avoid duplicative efforts, potentially leading to the consolidation or elimination of overlapping programs. For scientific research, the order reinforces a commitment to “Gold Standard Science,” requiring expert review and prioritizing reproducibility and rigor over institutional prestige. This shift could significantly impact how institutions are evaluated and funded, challenging long-standing norms in research administration.

From a compliance standpoint, the implications for UG are significant.

The EO introduces new termination clauses that would allow agencies to end awards based on misalignment with agency priorities, a provision that conflicts with §200.343 of UG. Additionally, proposed indirect cost caps and restrictions on post-termination costs further diverge from established UG principles, raising legal and operational risks. Institutions must now navigate a fragmented regulatory landscape where agency-specific directives may override or contradict federal regulations, complicating grant lifecycle management and financial planning.

As legal challenges to these changes unfold, research institutions face a precarious environment marked by uncertainty and risk. Lawsuits challenging indirect cost caps and EO-based terminations underscore the tension between executive authority and regulatory consistency. In this evolving landscape, institutions must remain vigilant, monitor litigation outcomes, and proactively adapt their compliance frameworks to safeguard funding and uphold research integrity.

Uniform Guidance and Agency Policies UG was originally established to bring clarity, consistency, and transparency to federal grant administration across agencies. It aimed to harmonize cost principles, streamline administrative requirements, and reduce institutional burden. However, the 2024 revisions to UG—combined with the sweeping EOs issued in 2025—have reintroduced fragmentation and uncertainty, leaving institutions unsure which rules govern their awards and compliance obligations. The 2024 updates to UG include several provisions that significantly broaden agency authority, often at the expense of predictability and uniformity:

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• Elimination of the “Fair Share” Cost-Sharing Clause The removal of language requiring agencies to consider a “fair share” of cost-sharing has raised questions about federal expectations for institutional contributions. Without a clear benchmark, institutions may face inconsistent demands for cost-sharing across agencies and programs, complicating budgeting and proposal development.

• New Termination Clause (§200.340(a)(4)) This clause allows agencies to terminate awards if a project no longer aligns with program priorities. While intended to provide flexibility, it introduces a subjective standard that can be influenced by shifting political or administrative agendas. Institutions now face the risk of midstream terminations based on evolving agency interpretations, undermining long-term research planning and stability.

• Expanded Authority to Deviate from Cost Principles Agencies are now permitted to deviate from established cost principles without prior approval from OMB. This change weakens centralized oversight and opens the door to inconsistent application of cost rules, increasing the likelihood of audit findings and disputes over allowable expenses.

• Audit Requirements for Fixed Amount Awards Previously exempt from detailed expenditure tracking, Fixed Amount Awards are now subject to audit of actual costs. This reversal adds administrative burden and may deter institutions from pursuing these streamlined funding mechanisms, particularly for smaller projects or pilot initiatives.

When layered with EO-driven directives, these UG revisions have eroded the consistency and predictability that UG was designed to provide.

Agencies now interpret and apply UG provisions in divergent ways, often influenced by political priorities or internal policy shifts. For example, some agencies have embedded termination-for-convenience clauses into discretionary awards, while others have imposed indirect cost caps or introduced new reporting mandates that extend beyond UG’s scope.

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This regulatory fragmentation forces institutions to manage compliance on a grant-by-grant basis, developing customized workflows and monitoring systems to accommodate varying requirements. The result is a more complex, less transparent, and higher-risk environment for research administration—particularly for institutions with limited administrative capacity.

Further revisions to UG are anticipated in response to ongoing litigation, stakeholder feedback, and evolving federal priorities. These changes may either reinforce agency discretion or attempt to restore consistency and clarity. Institutions must remain engaged in the rulemaking process, advocate for transparency and fairness, and prepare to adapt their internal policies and systems to align with future updates.

Points of Conflict and Impact The intersection of the 2024 UG revisions and the wave of 2025 federal actions—particularly EOs and agency directives—has created a regulatory landscape riddled with contradictions, ambiguities, and operational challenges. These conflicts are not merely technical; they strike at the heart of how research institutions manage federal awards, ensure compliance, and safeguard academic integrity.

Termination for Convenience. One of the most consequential changes is the expansion of termination authority. The August 7, 2025, EO mandates that all discretionary grants include “termination for convenience” clauses, allowing agencies to cancel awards if they no longer align with evolving program goals or administration priorities. This directive is incongruent with UG §200.343, which outlines specific conditions under which awards may be terminated, emphasizing due process and regulatory consistency. Institutions now face the risk of abrupt terminations based on subjective assessments of alignment, undermining long-term planning and jeopardizing multi-year research initiatives. Agencies have begun reviewing and revising their standard terms and conditions to comply with this mandate, further destabilizing the grant lifecycle.

Indirect Cost Restrictions. The NIH’s imposition of a 15% cap on indirect costs—retroactively and prospectively—was temporarily blocked by a federal injunction in March 2025. However, similar caps have surfaced across NSF, DOE, and DoD, signaling a broader trend toward limiting F&A recovery. These caps not only contradict UG’s cost principles but also violate procedural norms under the Administrative Procedure Act, as agencies failed to provide adequate notice and comment periods. The financial implications are severe. Institutions, especially those with high-cost infrastructure or specialized research facilities, face significant budget shortfalls. The lack of uniformity in how agencies apply these caps exacerbates the challenge, forcing institutions to develop agency-specific cost recovery models and increasing administrative overhead.

Peer Review Undermined. The August EO redefines the role of peer review in federal grantmaking. It explicitly states that peer review recommendations are “advisory, not determinative,” placing final funding decisions in the hands of senior political appointees. This shift undermines the scientific merit-based evaluation process that has long been the cornerstone of federal research funding. By elevating political discretion over expert judgment, the EO introduces a new layer of uncertainty and potential bias. Institutions must now consider not only the scientific rigor of their proposals but also their perceived alignment with political priorities—a dynamic that could discourage research in sensitive or controversial areas.

• Expanding Compliance Burden. New reporting mandates have emerged that extend well beyond UG’s original scope. These include: • Foreign funding disclosures under Section 117 of the Higher Education Act, now tied to False Claims Act liability.

• DEI audits and antisemitism compliance reports, which require institutions to validate program content against evolving federal definitions.

• Self-identification of potentially noncompliant awards, as required

by NIH and other agencies in response to EO directives.

These requirements introduce dual compliance tracks—one for UG and another for EO-driven mandates—creating operational inefficiencies and increasing the risk of audit findings. Smaller institutions, with limited administrative capacity, are particularly vulnerable to these burdens.

Fragmentation and Vulnerability The cumulative effect of recent executive orders, agency-specific directives, and the 2024 revisions to UG has created a fragmented and uncertain regulatory environment. Institutions must now navigate a maze of conflicting policies, inconsistent enforcement, and evolving compliance expectations, often without clear direction or precedent.

Inconsistent Application of UG Across Agencies Uniform Guidance was originally designed to harmonize federal grant administration across agencies. However, recent changes have reintroduced inconsistency. Agencies now interpret UG provisions differently, particularly around cost principles, termination clauses, and indirect cost recovery. For example, while NIH’s 15% IDC cap was paused by injunction, other agencies like DOE and DoD have quietly implemented similar restrictions without formal rulemaking.

This patchwork approach undermines the predictability UG was meant to provide and forces institutions to develop agency-specific compliance frameworks.

Divergent Interpretations of Executive Orders Executive orders issued in 2025 have granted agencies broad discretion to align funding with administration priorities. However, the interpretation and implementation of these EOs vary widely. Some agencies have issued “stop work” orders or paused funding cycles, while others have continued operations with minimal disruption.

This divergence leaves institutions guessing which rules apply, when, and to which awards. The lack of centralized guidance from OMB exacerbates the confusion, especially as agencies are encouraged to consult their own General Counsel for interpretation.

Disproportionate Impact on Smaller Institutions While all institutions are affected, those with limited administrative capacity are particularly vulnerable. Smaller colleges and universities often lack the resources to maintain dual compliance systems, track evolving agency guidance, or absorb financial shocks from reduced indirect cost recovery. As a result, they face heightened risk of audit findings, funding losses, and reputational harm.

Strategic Implications To address these vulnerabilities, institutions might explore: • Investing in flexible compliance infrastructure that can adapt to shifting requirements.

• Strengthening internal coordination between research administration, legal counsel, and government relations.

• Engaging in external advocacy through professional associations like NCURA to promote consistency and transparency.

• Monitoring litigation and policy developments closely to anticipate changes and adjust strategies accordingly.

Legal Challenges and Risk Landscape The regulatory turbulence of 2025 has not gone unchallenged. Legal actions have been filed in response to agency-imposed indirect cost caps and EO-driven award terminations, with plaintiffs arguing that these measures violate the Administrative Procedure Act (APA), conflict with Uniform Guidance (UG), and undermine the integrity of federally funded research.

One of the most visible cases involves the NIH’s 15% cap on indirect costs, which was applied both retroactively and prospectively. A federal court issued a preliminary injunction halting implementation, signaling judicial concern about the legality and procedural fairness of the agency’s actions. Similar caps introduced by NSF, DOE, and DoD are now under scrutiny, and additional lawsuits are expected as institutions seek to protect their financial viability and contractual rights.

At the heart of these legal disputes is a fundamental question: Can executive orders override UG, a regulation issued by the Office of Management and Budget with the force of law? Courts may ultimately determine the boundaries of executive authority in the context of federal grantmaking. However, litigation is inherently slow and unpredictable.

Institutions must manage the consequences now—often without clear guidance or precedent.

Award-Specific Terms That Vary by Agency, Program, and Cycle Institutions are increasingly encountering award terms and conditions that differ not only across agencies but within the same agency depending on the program or funding cycle. Some awards now include termination-for-convenience clauses, restrictions on public communication, or requirements for self-identification of potentially noncompliant activities. These variations complicate grant lifecycle management, requiring tailored compliance strategies for each award and increasing the risk of oversight or error.

Erosion of Predictability and Stability This fragmentation erodes the foundational principles of UG—clarity, consistency, and fairness. Institutions can no longer rely on standardized rules or uniform enforcement. Instead, they must operate in a landscape where policies shift rapidly, enforcement is uneven, and compliance expectations are unclear. This unpredictability hampers long-term planning, disrupts research continuity, and increases administrative burden.

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Key Risk Domains In the absence of timely legal resolution, institutions face a growing array of risks across multiple dimensions: • Financial Risk • Reduced F&A Recovery: Indirect cost caps threaten the financial sustainability of research programs, particularly those with high infrastructure or compliance costs.

• Budget Uncertainty: Retroactive changes to award terms disrupt long-term planning and may require reallocation of institutional funds to cover shortfalls.

• Delayed Funding: Paused or rescinded FOAs create cash flow challenges and jeopardize ongoing projects.

• Compliance Risk • Conflicting Requirements: Institutions must now reconcile UG provisions with EO-driven mandates, which often diverge in scope, terminology, and enforcement.

• Dual Monitoring Systems: Compliance offices must track both UG and agency-specific directives in real time, increasing the complexity of audits and reporting.

• Expanded Reporting Obligations: New requirements—such as foreign funding disclosures, DEI audits, and antisemitism compliance—extend beyond UG’s original intent and require new infrastructure and training.

• Operational Risk • Fragmented Award Management: Award terms now vary not only by agency but by program and funding cycle, requiring customized workflows and documentation.

• Staffing Strain: Administrative teams must manage parallel compliance systems, often without additional resources or clarity.

• Process Redesign: Institutions may need to overhaul grant lifecycle processes to accommodate new termination clauses, review protocols, and reporting formats.

• Research and Academic Risk • Scope Adjustments: Faculty are increasingly pressured to revise project aims, language, and methodologies to align with shifting political priorities.

• Chilling Effect: Sensitive research areas—such as DEI, climate science, and gender studies—may be deprioritized or defunded, undermining academic freedom and scientific progress.

• Loss of Talent: Uncertainty and instability may deter earlycareer researchers and international collaborators from engaging with federally funded projects.

Strategic Response To mitigate these risks, institutions should: • Engage Legal Counsel: Review award terms and agency communications for potential violations of UG or APA. • Document Impacts: Maintain records of financial losses, administrative burdens, and research disruptions to support future litigation or advocacy.

• Coordinate with Peers: Share insights and strategies through NCURA, COGR, and other professional networks.

• Advocate for Clarity: Participate in public comment periods and policy forums to promote transparency, consistency, and fairness in federal grantmaking.

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While legal challenges may eventually clarify the boundaries between executive orders and Uniform Guidance, institutions cannot afford to operate in a holding pattern. The risks are immediate, multifaceted, and compounding. Financial strain, compliance complexity, operational disruption, and threats to academic freedom are no longer hypothetical— they are unfolding realities. Institutions must respond with agility, foresight, and collaboration, leveraging legal expertise, peer networks, and strategic planning to safeguard their research enterprise. The path forward demands resilience and proactive engagement, not only to weather the current storm but to shape a more stable and equitable regulatory future.

Managing Uncertainty and Preparing for the Future In today’s unpredictable regulatory environment, marked by the collision of executive orders, agency directives, and evolving UG, institutions must adopt a proactive and adaptive posture. Waiting for clarity from the courts or definitive guidance from OMB may not be a viable strategy, especially as further revisions to UG are anticipated. These revisions may either reinforce agency discretion or attempt to restore consistency, but in either case, they will require institutions to recalibrate their compliance frameworks.

To navigate this chaotic and constantly shifting landscape, institutions should consider the following strategies: Active Monitoring. Establish a system for real-time tracking of litigation outcomes, OMB memoranda, and agency-specific guidance. This includes monitoring Federal Register notices, FOA updates, and policy statements from NIH, NSF, DOE, and other major funders. Institutions should also maintain close contact with legal counsel and government relations teams to interpret emerging directives and assess institutional impact.

Scenario Modeling. Partner with finance and sponsored programs teams to model various risk scenarios. These may include reduced indirect cost recovery, award terminations, or delays in funding cycles.

Use these models to inform contingency planning, budget adjustments, and strategic decision-making. Institutions should also assess the impact of potential UG revisions on cost allocation, audit exposure, and administrative workload.

Maximize Cost Recovery. In light of indirect cost caps and shifting cost principles, institutions must optimize allowable recovery. This includes: • Strategic allocation of direct costs.

• Full recovery in core facilities and recharge centers.

• Careful documentation of effort and administrative support.

• Leveraging fringe benefit rates and service center billing.

Institutions should also revisit their cost accounting standards to ensure alignment with both UG and agency-specific expectations.

Diversify Funding Sources. To reduce reliance on federal funding, institutions should expand efforts to secure philanthropic, state, and industry support. This may involve: • Building relationships with foundations and corporate sponsors.

• Pursuing state-level research initiatives and economic development grants.

• Encouraging faculty to explore non-federal opportunities and interdisciplinary collaborations.

Diversification not only enhances financial resilience but also supports research independence in politically sensitive areas.

Operational Efficiency and Cost Savings. Institutions should conduct a comprehensive review of administrative operations to identify cost-saving opportunities. Consider: • Consolidating or renegotiating leases.

• Outsourcing non-core functions.

• Streamlining procurement and travel processes.

• Reducing duplicative reporting systems.

Efficiency gains can help offset funding losses and reduce the burden on research administration staff.

Policy Updates and Internal Alignment. Review and revise internal policies to reflect the current regulatory landscape. Key areas include: • Termination clauses and award closeout procedures.

• Cost-sharing and effort reporting standards.

• Foreign influence and research security protocols.

• DEI and compliance reporting frameworks.

Ensure that institutional policies are flexible enough to accommodate both UG and agency-specific requirements, and that staff are trained to implement them consistently.

External Engagement and Advocacy. Leverage NCURA, COGR, and other professional networks to stay informed, share best practices, and coordinate advocacy efforts. Institutions should: • Participate in working groups and policy forums.

• Contribute to comment letters and regulatory feedback.

• Collaborate with peer institutions to develop shared tools and templates.

Collective engagement amplifies institutional voices and promotes transparency, consistency, and fairness in federal research administration.

Conclusion The collision between executive orders, agency actions, and the Uniform Guidance has created a regulatory environment that is anything but uniform. Institutions are now operating within a complex and fragmented landscape marked by increased administrative burden, heightened audit risk, and potential funding disruptions. While federal courts—including possibly the U.S. Supreme Court—may eventually provide clarity or relief, institutions cannot afford to wait passively.

Adding to the uncertainty, further revisions to Uniform Guidance are on the horizon. These changes may either reinforce agency discretion or attempt to restore consistency across federal research administration.

Depending on their scope and implementation, upcoming UG updates could reshape cost principles, termination authority, and compliance expectations—either mitigating current conflicts or deepening them.

In this evolving climate, institutions must remain vigilant and proactive.

Strategic monitoring of litigation, policy developments, and OMB guidance will be essential. Equally important is active engagement with peer institutions and professional associations to share insights, coordinate advocacy, and develop resilient compliance frameworks. These efforts will be critical to maintaining operational stability, protecting research integrity, and sustaining institutional capacity in the face of ongoing regulatory flux. N

Reference

The White House. (2025, August 7). Improving oversight of federal grantmaking. https://www.whitehouse.gov/presidential-actions/2025/08/improving-oversight-of-federalgrantmaking/ Roseann Luongo is an Education & Research Senior Director for Huron Consulting Group. She is a research compliance professional with extensive experience in regulation interpretation and analysis.

She has more than 19 years of experience in research compliance, including risk assessment, policy and process development, compliance concern investigation, conflicts of interest analysis and management. She can be reached at rluongo@hcg.com.

Karen Johnson is a Senior Research Grants & Contracts Specialist at Huron. She has more than 20 years of experience in post-award research administration. She can be reached at karjohnson@hcg.com.

Jeremy Forsberg has been in research administration for more than 25 years. As the Associate Vice President of Research at the University of Texas at Arlington, he currently oversees the Offices of Sponsored Projects and Regulatory Services and serves as the Research Integrity and Export Control Officer for the university. He can be reached at j.forsberg@uta.edu.

Lisa Mosley is the Executive Director of the Office of Sponsored Projects at Yale University. In this role, she provides oversight and leadership to pre-award, administrative and financial post-award, as well as industry and clinical contracting teams. She can be reached at lisa.mosley@yale.edu.

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Research Administration in Africa

A Year Later – A Ugandan Institution’s Reflection on the Impact of October 2024 Uniform Guidance Revisions

By Josephine Amuron

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his issue explores the impact of the October 2024 revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as the Uniform Guidance. These revisions included not only general updates, but also incorporated recent legislation, clarified regulatory requirements, and redefined several terms. As we mark a year since these changes took effect, we ask: How did your institution respond? Did you conduct a thorough analysis and prioritize key areas, or did you adopt a more selective, gradual approach? Have you completed the transition, or is the process still ongoing?

This is an opportunity to reflect and share insights into how organizations, including ours, have responded to the changes and what we have learned in the process.

A Changing Landscape of Federal Support Over the past two years, the United States has invested approximately USD 953 million into Uganda’s prosperity programs, health sector, and democracy-building initiatives. Much of this funding has been disbursed through various forms of Federal financial assistance, including grants, cooperative agreements, cost-reimbursement contracts, and other formal arrangements between the U.S government, and non-federal entities such as local governments, NGOs and institutions of higher learning.

Despite the temporary freeze on U.S. foreign aid, which posed a serious threat to Uganda’s NGO sector, including our own institution, this longstanding partnership has yielded transformative benefits. U.S. support has empowered communities, improved health and education outcomes, spurred entrepreneurship, and advanced human rights efforts across Uganda.

updates aim to reduce administrative burden, enhance clarity, align with statutory requirements, and introduce anti-corruption safeguards. Key definitional changes included replacing terms like “non-Federal entity” with “recipient” or “sub-recipient” and simplifying terms such as “cost share” to include both matching funds and other contributions.

Our Institutional Response A year on, our institution has made measured responses to these changes.

While we continue operating under the previous version of the Uniform Guidance for existing awards, we are carefully reviewing and assessing which version applies to each grant, especially those issued before and after the transition date. Where uncertainties exist, we consult directly with the relevant federal awarding agencies for clarification.

Although many versions are targeted at federal agencies, our organization uses these updates to better anticipate expectations from other donors and to ensure compliance moving forward.

The Major Revisions Include: 1

Increased flexibilities and thresholds.

T he 2024 revision raises several thresholds, including the equipment threshold, which increased from $5,000 to $10,000. However, our organization has not adopted this revision and has retained the existing threshold. Upon reviewing the equipment and supplies thresholds outlined in our current policies, we have determined that no immediate changes are necessary. Nonetheless, we will consider adjustments should we receive any new federal awards.

The fixed amount for sub-awards and the de minimis rate for 2 The 2024 Revisions to Uniform Guidance: What Changed?

In October 2024, the U.S. Office of Management and Budget (OMB) announced sweeping proposed changes to the Uniform Guidance, representing the most significant overhaul since its inception in 2014. These 42

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indirect costs.

F or the recipients and sub-recipients without a current federally negotiated indirect cost rate, the Office of Management and Budget (OMB) has increased the de minimis rate from 10% to 15% of

modified total direct costs for budgeting and cost reporting purposes.

OMB also clarified that neither federal agencies nor pass-through entities may require recipients or sub-recipients to apply a de minimis rate lower than this standard, unless mandated by federal regulation or statute.

Our organization has not made any changes in response to this update, as we have consistently applied a standard de minimis rate of 15%, except in cases where a donor specifies a different rate, which we then adopt accordingly.

10 Transition readiness

T he 2024 revisions to the Uniform Guidance introduce both significant challenges and valuable opportunities for organizations receiving federal financial assistance. In response, my organization is already taking proactive steps by staying informed, updating our policies and procedures, investing in data management and cybersecurity, and positioning ourselves for a smooth transition while maintaining ongoing compliance.

11 Fixed amount sub-award threshold

33. Optimizing funding value.

U nderstanding the additional flexibilities and updated thresholds has allowed us to maximize the use of federal funding and save administrative time, our organization has always maintained this.

44. Impact of increased single audit threshold.

T he threshold for the single audit has been increased from $750,000 to $1 million in federal expenditures per fiscal year. Our organization has not made any adjustments in response to this change, as our current level of expenditures does not require it.

5

Policy and internal control updates.

We are in the process of aligning internal policies with the revised Uniform Guidance. While no major changes have yet been required due to the timing of new grants, our existing policies continue to reflect our understanding of the different applicable versions.

6

Internal controls. ur internal controls are effective in supporting the administration O of awards in accordance with the applicable version of the Uniform Guidance. Additionally, my organization has updated its internal policies and procedures to ensure alignment with the new requirements.

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Whistleblower protections.

A nother change involves the requirement to notify employees of their whistle-blower rights and protections by providing a written notice.

My institution has remained compliant with this requirement, and the recent update reinforces the commitment to ensuring that all employees receive written communication regarding their whistleblower rights and protection.

T he threshold for fixed amount sub-awards that recipients may issue with prior written approval from the federal agency has been raised from $250,000 to $500,000. Upon completion of the sub-award, the recipient is required to provide written certification confirming that the project was completed as agreed or to specify any activities that were not completed. The federal award amount must then be adjusted to reflect the value of any incomplete work, my organization is already participating actively on this.

12 Fewer prior approvals

T he updated guidelines eliminate the need for prior written approval from the federal agency before incurring specific types of costs under grant agreements. These include expenses related to entertainment, memberships, subscriptions, professional activities, participant support, and select sales and marketing efforts.

Additionally, the update clarifies that certain data and evaluationrelated costs are now considered allowable. My organization has previously been seeking prior approval for some of these expenses when they fall outside the approved budget.

13 Administrative closeout costs

A dministrative closeout costs may be incurred up to the deadline for submitting the final report. If such costs are incurred, they must be settled before the report’s due date and allocated to the final budget period of the award, unless the federal agency provides alternative guidance. All other costs must be incurred within the approved budget period, previously, my organization would evaluate if a no cost extension would be appropriate, and we are gradually considering this change.

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Cybersecurity compliance.

I n response to the requirement to implement “reasonable cybersecurity and other measures to safeguard information,” my organization has established robust cybersecurity protocols that effectively protect sensitive data, including personally identifiable information. These protocols are regularly updated and tested to ensure ongoing compliance. One year later, my organization continues to uphold and strengthen these measures.

Conclusion The 2024 revisions to the Uniform Guidance reflect a broader effort to streamline processes, improve transparency, and ensure accountability in the administration of federal awards. While some elements of these revisions were already in practice within our organization like new wine in an old bottle, we recognize the value of formalizing and updating our systems to reflect current federal expectations.

As we move forward, we remain committed to ongoing improvement, policy alignment, and proactive engagement with these evolving regulatory frameworks. N

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Audit preparation. y organization takes a proactive approach to audit readiness M by ensuring that all records and documentation are current and fully compliant with updated requirements, including proper documentation of the applicable version of the Uniform Guidance (UG) for our awards. We also carry out regular internal assessments and audits to identify and resolve any potential issues in advance of external audits. These efforts have been ongoing and aligned with the latest revisions.

Josephine Amuron is the Projects Accountant with African Centre for Global Health and Social Transformation (ACHEST) in Kampala, Uganda, a Health NGO, that collaborates with several Universities and Civil Society Organizations. She has more than a decade an experience of in financial reporting, budgeting, compliance, audit and grants management. She monitors research project budgets and financial reports, ensures compliance with institutional and other regulations, timelines, coordinating project activities, providing administrative support to researchers, managers and project teams. She can be reached at jamuron@achest.org.

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Uniform Guidance one year later: From Policy to imPlementation

By Mirayda Torres-Avila and Glorimar Colón

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s we approach the first anniversary of the 2024 federal changes, do we know where we stand? Are colleges and universities feeling the intended results of improved management, transparency, and oversight? The plethora of Federal mandates experienced during 2025 and continuous changes in the regulatory landscape (both at the federal and state levels) have made it difficult to focus on assessing the impact of the 2024 amendments to the Uniform Guidance. The following tools may be helpful to evaluate institutional alignment with the changes while ensuring effective operations.

The Office of Management Budget (OMB) updated the regulations for the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200, also known as Uniform Guidance) effective October 1, 2024 (Guidance for Federal Financial Assistance, 2024), to incorporate statutory requirements, reduce burden, and add clarity by eliminating ambiguity and addressing inconsistencies. The stated final aim was to “improve management, transparency, and oversight” in the administration of federal financial assistance by both agencies and recipients. Some of the most impactful changes were: (1) the increase in threshold for capitalizable equipment, from $5,000 to $10,000; (2) the increase in the de minimis indirect cost rate, from 10% to 15%, for recipients that have never had a federally negotiated rate; (3) the increase in the indirect cost recovery amount of subawards, from $25,000 to $50,000 of modified total direct costs (MTDC); (4) the increase in the threshold of fixed amount subawards, from $250,000 to $500,000; and 44

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(5) an increase in the threshold for the single audit requirement from $750,000 to $1,000,000.

Compliance Matrix Framework To enact the change, a university needs to understand the new requirements in an easy-to-understand method, such as a compliance matrix. Compliance matrices can help assess the status of implementing regulatory change by outlining new requirements, determining the method for compliance, and stakeholders (Finney, 2020). Compliance matrices serve as the basis for identifying priorities or areas for attention as well as implementing a change management model.

The Council on Government Relations’ (COGR) Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance was released as part of its “COGR Look” series (“the Readiness Guidance”) (COGR, 2024). The Readiness Guidance was written with the intention of assisting institutions in preparing for and implementing updates to the Uniform Guidance. This guide provides a foundation for developing a compliance matrix tailored to the institution's specific circumstances. It serves as a checklist to evaluate an institution’s progress through the process.

An example of a compliance matrix in the context of the 2024 amendments to the Uniform Guidance could have the following: description of new Uniform Guidance requirements, the sources containing the specific sections in the code of federal regulation, description of current processes at the institution, the compliance status, the methods or necessary steps for compliance (action items), a list of relevant stakeholders, and any additional comments to aid in the process. This compliance matrix may be developed

using a simple tracking tool such as Excel or a Word document or implemented in a more complex software program, depending on available resources. This tool should facilitate understanding the requirements and status, rather than obstruct this process.

Change Implementation Framework Implementing changes can be a challenging and stressful process for every stakeholder involved. A general framework for implementing changes within an institution is the ADKAR model, which guides the development of the implementation plan, enhancing communication and assessment (Hiatt, 2006). The ADKAR model focuses on understanding new requirements (Awareness), identifying stakeholders (Desire), communicating changes through education and training (Knowledge), designing an execution plan (Ability), and implementing quality improvement (Reinforcement). An application of this model could be as follows: Awareness – The new requirements are reviewed, and a compliance matrix is developed. This matrix can be used to inform the upper administration of the new requirements and notify research administration directors and managers of any potential changes resulting from the new requirements.

Desire – All stakeholders identified in the compliance matrix should be notified, and a task force must be created. Task force members should be invested in achieving the goal by understanding the process and the compliance requirements while participating in the implementation. This should include all stakeholders from the research administration area and other institutional offices. Together, they should evaluate and update all Standard Operating Procedures, identifying any necessary resources or training required to implement the change, and ensuring that everything aligns with the compliance matrix.

Knowledge – A formal training session needs to be offered to all members of the research administration units. When designing formal training, the training modality and methods should be carefully considered. Virtual modality may be necessary to incorporate hybrid or remote employees.

Depending on the required knowledge or skill, teaching methods such as hands-on training, simulations, or case studies may be effective. For example, training could be offered during a biannual professional development meeting for all research administration and compliance personnel at both central and departmental levels.

Ability – The processes affected by the new requirements should be refined, and all stakeholders should implement the changes. In some cases, the new requirements involve modifying intake forms to implement changes, such as capturing capitalizable equipment costs and modified total direct costs. In other cases, an institution may opt not to modify the process to ensure quality assurance measurement and compliance. An example of this is the increased threshold for single audit requirements; however, institutions may decide to revisit this item in the future to reduce burden. The compliance matrix should be updated to reflect any changes or modifications made to achieve compliance.

Reinforcement – To support effective implementation, quality assurance measures should be embedded within the process to help sustain and reinforce changes. Reinforcement strategies may include incorporating prompts or logic into intake forms, utilizing reminder notes, or establishing a dedicated quality assurance plan and personnel to ensure consistency. Consistent oversight and timely feedback from relevant offices are essential to maintaining alignment and ensuring procedural consistency.

Challenges Implementing change presents a series of challenges that may range from anticipated to unexpected issues, which can impact the institutional response timeline. For some institutions, common challenges included an unambiguous interpretation of new regulations, implementing changes into now-out-

dated systems and processes, managing the administrative burden without additional resources, and communicating effectively with customers across decentralized operations or campuses. While each institution has its own approach to overcoming these challenges, a coordinated approach is beneficial in addressing the burden and maximizing resources. Any plan must be adaptable and open to improvement by focusing on the goal of achieving and maintaining compliance. For unforeseen challenges, an open communication mechanism should be in place to enable everyone to identify areas that require attention or modification, and to ensure that any plan adaptations or changes are communicated to all stakeholders. Additionally, quality assurance procedures are helpful to identify areas that need improvement during and after implementation.

Conclusion Whether your institution has checked all the marks on the compliance matrix or is unsure on their status after the 2024 Uniform Guidance changes, it is worth revisiting a summary of the changes and reflecting on your institution's adaptability to the amended regulations, and ask yourselves “how are we doing and what are we missing?” As you embark on the review, also determine whether the change has actually improved management, transparency, and oversight within your institution. N

“implementing changes can be a challenging and stressful process for every stakeholder involved.”

References Finney, S. (2020). Developing an Effective Compliance Strategy. In Information Security in Healthcare, (pp. 195–204). HIMSS Publishing.

Guidance for Federal Financial Assistance, 89 FR 30046 (April 22, 2024) (to be codified at 2 CFR §§ 170, 175, 180, 182, 183, 184, 1, 200, 25). www.federalregister.gov/d/2024-07496 Hiatt, J. (2006). ADKAR: a model for change in business, government, and our community. Prosci Learning Center Publications.

Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance, prepared by the COGR. (2024). In OMB Guidance for Federal Financial Assistance. www.cogr.edu/sites/default/files/UG%20Readiness%202024_5th%20Look_Final%20Draft_9.17.24.pdf

Mirayda Torres-Avila, PhD, MHEA, Assistant Director of Post Approval Monitoring Compliance at The University of Texas Rio Grande Valley, provides assessments for research activities approved by the Institutional Review Board, Institutional Animal Care and Use Committee, and Institutional Biosafety Committee. She can be reached at mirayda.torresavila@utrgv.edu.

Glorimar Colón, JD, MHEA, ECoP, Assistant Vice President for Research Integrity at The University of Texas Rio Grande Valley, has over two decades of progressive experience at the intersection of research compliance, policy development, integrity, and research administration. She can be reached at glorimar.colon@utrgv.edu.

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Before Burnout Settles In: A Discussion on Stress in Research Administration

By Vanessa Rook

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f a friend asked me to describe the best quality needed for a job in research administration, I’d probably recommend someone who can handle long days, deal with messy inboxes, and survive on office snacks. Is that healthy? Probably not, but it is a harsh reality for many of our colleagues in this profession. Over the years I’ve moderated several discussions on stress and mental health with colleagues and found that creating space to discuss the mental health needs of staff in our profession is vital–now more than ever.

In August 2025, I led a Wicked Good Chat for Region I on stress in research administration and specifically how to understand, identify and mitigate burnout. Defined in the 1970s by psychologist Herbert Freudenberger for workers in caregiving professions such as doctors, nurses and EMTs, burnout is a medical diagnosis to address severe stress (Institute for Quality and Efficiency in Health Care, 2024). In recent years it is used to describe devastating strain in any career or life event. Some major signs are: • Exhaustion - physical and emotional • Alienation - from work and colleagues • Reduced performance - listless & negative As I’ve written about in the past, I have suffered from burnout myself in research administration and the ways in which I keep it at bay. This includes a continuous practice of mindfulness, maintaining work/life balance, and utilizing institutional resources such as Employee Assistance Programs when needed. However, I’ll be the first to admit that as much as I promote tips and tricks on wellness, it’s not always that easy. Your personal life, lack of support in your position at work, and the resources you have available all play a factor. Here are some key takeaways I’ve learned: Burnout and Your Capacity: One of best resources I have found over the years is the work of RaQuel Hopkins, a Clinical Mental Health Counselor and Capacity Expert. In many of her videos she discusses a person’s “capacity” which she defines as the ability to handle stress and change in life (Hopkins, 2025). What does capacity mean in the context of research administration?

How do we find the capacity within ourselves, and what happens when it’s gone? I would argue it’s about finding and understanding your limits and not being afraid if your limits aren’t as robust as some of your colleague’s.

I’ve often found in the past that I compare myself to co-workers if they seem to handle a stressful task better than I do – does that take away from my abilities? Not at all; it simply means I haven’t yet understood my capacity to handle it due to lack of training, experience, or support in that task.

Addressing Burnout for Your Team: If you are worried that one or more of your staff might be experiencing burnout, what can you do as a leader or manager? Robert Lee Barber, a Leadership Architect, finds that

burnout is created not from long hours but from reactivity, shifting priorities, and no structure (Barber, 2025). As a manager or leader on your team, I would recommend doing a thorough review of your staff portfolio; can you shift tasks and priorities so one person is not always the most overwhelmed? What resources and training are offered on campus or through professional organizations that you can offer to your team? And make sure to set the example: no amount of after-hours work is going to reduce that inbox. Stop overworking yourself and expecting that staff won’t follow in your footsteps.

When Wellness Isn’t Perfect: Do I still practice mindfulness every day?

Nope! I’ll admit it, these days I find wellness and mindfulness by getting under the covers with a thrilling television series or pulling weeds out of my garden. Balance from burnout looks different to everyone, and a win is a win if I find my mind calm after meditation or dinner with family.

The biggest threat to your personal wellness and burnout at work is never addressing it to begin with – believing that you are strong enough, or that you will just feel better once that report is completed. While we move towards the end of 2025, I hope we take care of that which is most important to research administration: ourselves. N References Barber, Robert Lee. “Robert Lee Barber, Leadership Academy Builder” LinkedIn. 2025. www.linkedin.com/in/robertleebarber Hopkins, RaQuel. “RaQuel Hopkins, MS” LinkedIn. 2025. www.linkedin.com/in/raquel-hopkinscapacity-expert-758ba2173 Institute for Quality and Efficiency in Health Care (IQWiG), 2006. Depression: Learn More – What is burnout? [Updated 2024 Apr 15]. www.ncbi.nlm.nih.gov/books/NBK279286

Vanessa Rook is a Research Administrator at the Harvard Medical School with over a decade of experience. She has an extensive background in communication with a concentration on academic writing, science communication and online communities. Her professional focus is on the future of research administration: the retention and investment of young professionals in their careers through mentorship, education and self-assurance. She can be reached at vanessa_rook@hms.harvard.edu.

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2025 Robert C. Andresen

Outstanding Achievement in Research Administration Award Denise Wallen received the 2025 Robert C. Andresen Outstanding Achievement in Research Administration Award at the 67th Annual Meeting in August. This award is given to a member who has made a significant contribution to the profession and demonstrated noteworthy service to NCURA. The following are her remarks: ood morning, esteemed colleagues, friends, and members of NCURA. I would like to thank NCURA for generously selecting me as this year’s recipient of the Robert C. Andresen Outstanding Achievement in Research Administration Award. This award was named after a dear friend and colleague and past president - Bob who served tirelessly to NCURA and our profession. It is an honor to stand before you today as the recipient of this Award.

When I learned that I was selected for this recognition, I was immensely humbled, and it is with a great sense of gratitude and humility that I am here today.

Our community, who I consider and value as my NCURA Family, is comprised of so many people who give of themselves through dedication and passion. This community - those of you who are here today - that comprise our field of research administration - support and shape the success of research, advance discovery and innovation, and make miracles happen every day.

Our voices and experience are so critical. Especially at the present time when we are faced with “rising to the occasion” and be nimble problem solvers to rally our support and maintain our commitment so we may continue to secure and defend the value and importance of research.

I want to acknowledge and thank my mentors and the many people who have supported and guided me throughout my journey. It was their generosity, knowledge and wisdom, patience, and humor that I deeply appreciate.

Throughout my career in research administration I have been the recipient of, witness to, and afforded the opportunity to work with people who authentically value and embrace a climate of creativity and innovation, honesty, trustworthiness and ethical behavior. I honor these qualities and am committed to being that Research Administrator and contributing to an environment that values that.

As we know, Research Administration is a team effort, and it is that collective generosity, brain trust, commitment, as well as those shared values of everyone I have worked with, that has made my career possible and joyful. And I am very grateful for that.

I want to take this opportunity to recognize several people who have been my pillars, my fonts of wisdom, and my support system. They have carried me through my professional and personal journey.

Rosie Madnick, Lundquist Institute for Biomedical Innovation Denise Moody, Lundquist Institute for Biomedical Innovation Shannon Sutton, Georgia State University Kris Monahan, Harvard University Tony Ventimiglia, Auburn University

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Recipient Denise Wa

llen (L) and Nomina

tor Rosie Madnick (R)

David Mayo, California Institute of Technology Georgette Sakumoto, University of Hawaii Josie Jimenez, New Mexico State University Robyn Remotigue, UNT Health Fort Worth Kathleen Larmett, NCURA Tara Bishop, NCURA And my University of New Mexico team and leadership I have had the honor to support and work with so many incredible researchers and faculty whose work went on to impact developments in cancer, the environment, science and engineering, education, to name a few -this award is also an acknowledgement of their efforts and dedication. It is their intellectual curiosity, and yearning to find answers, new ways of discovery, making a difference for a better world that affords a critical space for us as Research Administrators to do our job -- our part. And I find that both thrilling and challenging.

As we know, research administration is an integral part of the research landscape. We inhabit a dynamic environment that indeed challenges us to harness our expertise and experience to rise to a rapidly shifting horizon.

Especially now. And I remain hopeful and positive that we as research administrators are part of the solution. It will demand that we remain knowledgeable, responsive, committed to serve our researchers and institutions, and our extended communities.

In closing, thank you again for this incredible honor. I am eager and excited to continuing to contribute to the field of research administration.

I thank you for all that YOU do and for coming to DC to be part of this conference.

Please enjoy the Annual Meeting and the opportunity to learn, to expand, to network and to grow your NCURA Family.

Thank you.

How To

In Your Career Lessons Learned Transitioning from Academia to Research Administration

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By James Brooks, Jeanne Kisacky, and Christine Sislak

re you considering a job change that would be more than just a step up the ladder but into an entirely new line of work? If so, then this article is for you. Each of the authors has made multiple career pivots. This article will explain why they did it, how they did it, and what was gained (and lost) as a result.

Since each of the authors transitioned to their current research administration positions from academic positions (research or teaching), this article will focus on that career shift, but the strategies and approaches apply to shifts between other careers.

Identifying when to Pivot. There is no single definitive sign indicating when it’s the right time to pivot in a career, and there can be myriad reasons for wanting a change. A certain degree of unease with the reality of day-to-day life in an existing position can motivate to look elsewhere, but where else to look and when it’s best to do so is rarely clear. Timing is essential: not just in determining what makes the most sense for this stage of your life or career, but also in assessing the current state of the job market in other potential career fields, including research administration.

Are there positions available that are interesting and accessible to someone of your skill set?

Yes, You do Have Skills!

Anyone who has worked in academia (or as an administrator in a different field) inevitably has some relevant experience and likely a basic understanding of research administration skills (Vanderford, 2023). Research administration is not a linear profession; there are several subfields such as pre-award and post-award administration; research and development; institutional review board (IRB); biosafety; animal care and use (IACUC); finance; export control; and research security (Brown & Lucas, 2022; Crockett, Foland, & Ritchie, 2022; Moeini, McClelland, & Allen, 2024; Reardon, 2021; Tri-University Research Administration, 2025). While each subfield requires specific skills, they also rely on some basic core skills: • Working with Project Investigators (PI) and Supervisors. At any stage of a Sponsored Project, Research Administrators must communicate effectively with the PI. If you are pivoting from an academic position, you may already know how many demands are made on a PI. This awareness provides a better understanding of how to capture the PI’s attention and

effectively communicate your needs. It also provides the experience necessary to synthesize the required elements of an administrative action and understand how to prioritize the numerous deadlines and requirements within that action, thereby minimizing administrative burden for the PI and departments while still bringing it to resolution. The connections Christine made with the PIs she worked with as a Technician prior to moving to Research Administration have been invaluable in creating positive working relationships and administering their projects.

• Reading and Understanding Technical Documents. Suppose you are pivoting from an academic position to Research Administration. In that case, you likely already have earned a bachelor’s degree at a minimum, and that means you have read, comprehended, and synthesized technical and scientific documents. You have the skill to read through proposals from various fields and provide feedback if the objectives of the proposal align with objectives of the funding opportunity. You also have the skill to read quickly for content and distill the important information from a much larger work. Coming from a background in academia and the lab, James was equipped with the ability to quickly synthesize and implement skills and protocols, a skill that has lent itself well to research administration.

• Collaboration. Academics frequently collaborate with colleagues and other researchers within their own lab, department, institution, or even at other institutions. Working with people from diverse locations, fields, and expertise requires strong management and interpersonal skills.

Understanding people’s roles within a collaboration allows accurate structuring of agreements to support those varying roles. These skills are invaluable in Research Administration, since each of the subfields must collaborate effectively with the others.

• Problem solving. Academics are always problem-solving; this is a broad skill equally necessary in Research Administration. While the actual tasks of a Research Administrator may appear repetitive from the outside, the circumstances and details of each project, agreement, and requirement vary continuously depending on the sponsor, scope of work, terms of the agreement, compliances, and other factors. Solving problems is a skill used daily in research administration.

How to explore your options In terms of pivoting in a career, it pays to be prepared and not just make NCURA Magazine

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the jump unquestioningly, hoping for the best. One of the most significant difficulties in making a pivot is realizing how little you know about what you are getting into. The best way to mitigate this is to conduct thorough research. There is no one-size-fits-all approach to gathering information on research administration, but here are several practical strategies: • Interview Research Administrators. Speak with people who already work in the field; they have the most intimate and accessible knowledge of what it is like to do the job. Sending cold emails to set up meetings can be daunting, but many people are happy to answer questions about their day-to-day work life and even larger questions about their profession. These conversations can pay dividends by providing valuable networking for continued growth. James successfully gained insight into the profession of research administration and formed many valuable connections through cold emails and conversations.

• Apply. It cannot be overstated that it’s always advisable just to apply. If you have seen an intriguing position announcement, apply for it. Even if you don’t get the position, this is a chance for a structured conversation about career possibilities. It is also a foot in the door, because if you are not right for that specific position, there is a good chance that an interviewer will remember you for a future position that would be a better fit.

Bottom line: you must be willing to take a chance to get out of whatever rut you find yourself in.

• Consider Entry-Level Positions. Do not be afraid of taking a more entry-level position, even if you feel overqualified. Quite frankly, the learning curve in some positions can be steep. Learning the profession from the ground up might, in the end, facilitate faster advancement.

Christine was initially interviewed for a senior position in the university’s central office because, at the time, that was the available opening. While she was not offered that job, when a more entry level position opened up, the Director reached out to her and encouraged her to apply. It was a great starting point and led to an advancement in under two years.

• Clarify Opportunities for Growth and Advancement. Before making the jump to an entry-level position, have a conversation with your prospective new employer about your career expectations and possibilities for an expedited advancement. This should include not only the likelihood of moving up to the next level, but the chances of there being an opening at that next level in the near future (whether with the current employer or at another employer in a similar position).

• Pivoting is likely a process, not a One-and-Done. It is important to remember that you do not need to achieve (and in fact are likely not to get) the perfect career fit on your first try. Each of the authors began in a different subfield of research administration before transitioning to post-award administration. Jeanne started in post-award project administration within a unit. It took several years for her to fully understand the life cycle of a sponsored project, from proposal to closeout.

However, building on that experience, she was able to pivot to a position in post-award research administration within the central sponsored projects office. The skills learned in one sub-field directly support the skills needed in the next. Research Administration is a broad profession with many specialties and many opportunities to explore.

Benefits of the Switch Whatever career you are in now, you are familiar with the rhythms and requirements, which in turn influence both what you want and do not want in a new career. Research Administration has its own rhythms and requirements, which can vary significantly from academic positions: • Hours: Research administrators typically work business hours (9-5) with short periods of greater intensity around proposal or award deadlines.

• Physicality: Pre-award, and post-award, and research development are desk jobs. As a colleague said, “I never sat in a chair more in my life.”

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On the other hand, animal welfare and some other subfields can be far more hands-on.

• Communication style: Research administration is email or text-focused, with an emphasis on documentation. Meetings and conversations punctuate the day, but email remains the primary mode of communication.

• Growth opportunity: Academia has established advancement tracks (think professor, research associate, or teaching aide), but outside of tenure track positions, advancement within academia can be limited.

Research Administration is a relatively new profession with greater opportunities for movement within the profession and to adjacent fields.

Pivoting in your career requires reframing your goals and expectations of yourself. It can be terrifying facing the prospect of leaving a profession or career to which you may have committed a good amount of time, effort, and study. Sticking with a career that is not providing the rewards you need, or thinking you are not good enough for the job, is not a failure; it’s admitting that the job is not good enough for you.

Conclusion Time for action! You have identified that it is time (or soon to be time) for a career pivot to see what opportunities are out there. Wanting to stay in academia? Don’t forget many departments or schools have their own Sponsored Research Offices, IRBs, and financial offices separate from the main University. Expand your search to include companies and non-profits that may have sponsored your own research; what opportunities might they have for you? Do not limit yourself, and enjoy the search! N

References Brown, H., & Lucas, M. (2022). Research Administration Careers: Career Options. SRAI News, October 13. www.srainternational.org/blogs/srai-news/2022/10/13/research-administrationcareers-career-options NCURA. (June 29, 2022). Career Paths & Career Planning in Research Administration (Young Professionals Webinars). YouTube. www.youtube.com/watch?v=ftXKeA2Yt7s Moeini, S., McClelland, S., & Allen, L. (April 16, 2024). Choose your own adventure: Careers in Research Administration [PowerPoint]. TURAC 2024 Session Proceedings. https://turac.info/wpcontent/uploads/2024/04/Choose-Your-Own-Adventure_-Careers-In-ResearchAdministration.pdf Reardon, S. (2021). We’re problem solvers: research administrators offer guidance to working scientists. Nature, 595, 321-322. https://doi.org/10.1038/d41586-021-01829-8 Tri-University Research Administration (2025). TURAC Archives, Professional Development, Session Recordings. https://turac.info/browse-archives-by-topic/#Professional-Development Vanderford, N. L. (Nov. 24, 2023). Research Administration: a career path uniquely fitted for Ph.D.s. ASBMB Today. www.asbmb.org/asbmb-today/careers/112423/research-administration

Christine Sislak is a Grant & Contract Officer at Cornell University primarily managing NSF, NIH, and USDA awards supporting research in departments across Cornell. She previously worked in pre-award administration. She can be reached at cds277@cornell.edu.

James Brooks is a Grant and Contract Officer at Cornell University managing primarily NSF, NIH, NASA and DOC awards that support research in a multitude of departments across the university. He has previously worked in academia, startups, pre-award administration and research development. He can be reached at jcb78@cornell.edu.

Jeanne Kisacky is a Grant & Contract Officer at Cornell University providing pre- and post-award management of federally-sponsored projects. She came to research administration after a variety of other positions including: editor, faculty, PI, author, and sponsored project manager. She can be reached at jsk7@cornell.edu.

• Administering Research Contracts • Compensation-Personal Services: Documenting and Supporting Salary Charges to Federal Award • Crafting Fully Compliant Budgets • Financial Management of Sponsored Program Awards • How to Effectively Manage an Audit • Improving Efficiencies: Assessing the Sponsored Research Operation • International Research Collaborations • A Primer on Business Continuity • A Primer on Export Controls • Understanding & Managing Sponsored Program Administration at Predominantly Undergraduate Institutions

The Financial Accountability in Research (FAIR) Model: A New Approach to the Government-Researcher Partnership for American Leadership in Research and Innovation

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By Kelvin K. Droegemeier, Penny Gordon-Larsen, Jenny Lodge, Kurt Marek, and Stacey Patterson

1. Introduction Since World War II, US Federal funding for research grants has been bifurcated into direct and indirect costs, also known as facilities and administrative (F&A) costs.i This model applies to institutions of higher education (IHEs), independent research institutes (IRIs), and research hospitals and medical centers. Although the direct/indirect cost structure is effective, it is not without limitations and critics. Indeed, concerns began to be raised as early as 1946 and continue to this day (e.g., US General Accounting Office 1992, 1995; US Government Accountability Office 2010, 2013, 2017). The effectiveness of the F&A system now in place often is overshadowed by several well-known issues which, in combination, make the model difficult to understand and appear somewhat opaque to the public.

Major government concerns center around a perceived lack of transparency and accountability in the use of F&A funds. Another concern exists that some F&A rates, especially at large and elite institutions, are excessively high, suggesting that such institutions are recovering far more F&A than is 52

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appropriate. In addition, the F&A rate is applied equally across types of research, except for certain activities,ii which creates the impression that certain types of research are charging excessively high F&A rates relative to their actual performance costs. Finally, confusion persists in differentiating between the F&A rate and the fraction of a research budget comprising F&A costs.

2. The Driver of Change In recently issuing F&A caps for several federal research funding agencies, the government made clear its intention to provide fewer federal dollars for indirect costs, with the difference between actual costs and those paid by the government to be made up by industry, philanthropy, and research institutional resources. These and other actions, coupled with unmistakable messaging from congressional leaders, have made clear that the current F&A model for indirect costs is no longer viable and will be replaced. The research community responded by organizing a collaborative effort, working

with government, to develop a durable model for federal research funding that addresses known limitations of the current F&A approach. The overarching goal is to create a new funding model that helps ensure a robust research enterprise and maintains American global leadership in research and innovation.

3. Creation of the Joint Associations Group ( JAG) on Indirect Costs To achieve the goal noted above, the Joint Associations Group (JAG) on Indirect Costs was formed. JAG comprises nine non-profit associations representing all sizes and types of IHEs, IRIs, and academic hospitals and medical centers, as well as the Science Philanthropy Alliance. To develop the model, JAG established a 26-member subject matter expert (SME) team of volunteers comprising experts in indirect costs, research policy, finance and cost accounting, research administration, communication, government relations, and research operations. Unlike previous efforts, the SME team included representatives from private industry, philanthropic research funders, IRIs, hospitals, and former senior government officials.

4. Description and Benefits of the FAIR Model The FAIR model shifts from historical practices—where certain institutional costs are grouped into generalized reimbursement categories—to an approach that explicitly defines and budgets for the services and infrastructure that make research possible. The model deliberately moves away from outdated “direct and indirect cost” terminology, replacing them with cost categories that describe the actual resources needed to conduct research. By aligning costs to the type of research being performed, the FAIR model brings unprecedented clarity to researchers, institutions, federal sponsors, and taxpayers alike.

The FAIR model also addresses the increasing complexity of research portfolios by allowing cost recovery to vary with actual project requirements specific to their geographic locations. Because costs are tied to actual project requirements, they are specific to the costs of performance at the specific institution and area in which they are located.

With the FAIR model, institutions will no longer prepare and negotiate an F&A rate proposal. Research costs are organized into three standardized categories (Figure 1). It is important to note that the FAIR model is not simply a renaming or reshuffling of components within the existing F&A model, but rather is a complete restructuring of the entire cost framework.

1. Research Performance Costs (RPC): RPC refers to all project-specific costs that are explicitly managed by the researcher(s) and are necessary to carry out the goals of a sponsored project. These are the most familiar and visible costs in project budgeting and are typically under the control of the Principal Investigator (PI). Examples include personnel salaries, laboratory supplies, and project-related travel.

2. Essential Research Performance Support (ERPS): ERPS encompasses institutional services and infrastructure that enable the execution of sponsored research projects. Unlike RPC, which are managed directly by the researcher(s), ERPS costs represent institutional support essential for the compliant and effective conduct of science.

ERPS consists of four elements. ○ Regulatory Compliance (RC), which are project-specific costs necessary to meet institutional and sponsor-imposed compliance requirements, including Institutional Review Boards (IRBs), Institutional Animal Care and Use Committees (IACUCs), biosafety committees, export control, radiation safety, clinical trial monitoring, project-specific research security policies, and other researchrelated regulations. ○ Award, Oversight, and Reporting (AMOR), which are projectspecific costs that ensure compliant execution and financial stewardship of awarded funds. This includes financial management, progress reporting, and award closeout.

○ Essential Research Performance Facilities (ERPF), which are project-

specific physical infrastructure costs required to perform the specific research project, including research space, utilities, maintenance, operations, building depreciation, leases, and other facility expenses directly supporting a given research project. ○ Research Information and Data Services (RIDS), which are projectspecific costs including institutionally-provided access to digital and physical research resources, infrastructure, consultative services, and repositories that support the information needs of research projects.

3. General Research Operations (GRO): GRO includes institutionwide infrastructure and services that support the broader research enterprise but are not allocable to individual sponsored projects.

These activities are necessary to maintain overall institutional capacity for research and to enable the successful conduct of projects across departments and disciplines.

Figure 1. Structure of the FAIR model and Detailed Option.

Several important points are noteworthy about the FAIR model. First, the F&A concept has been eliminated, and all costs are explicitly accounted for in the budget. In two categories, costs are expressed as a percentage of the total budget. In ERPF, the percentage model avoids requiring a detailed square footage analysis of all rooms and buildings used for research yet is fully accountable. Additionally, GRO is represented as a fixed 15 percent of a total research project budget for all organizations (Figure 1). This value represents an average across all institutions that was determined by analysis of publicly available cost recovery data.

Finally, the FAIR model addresses one of the most important concerns of some in Congress, namely, that funds reimbursed by the government for F&A costs are being improperly used by some organizations it funds. By tracking federal reimbursements into specific and allowable categories from which the funds were expended by an organization as research took place, the FAIR model ensures government funds are used as intended.

5. FAIR Model Options To accommodate this spectrum of institutions and research types, the FAIR model includes two implementation options. These options address one of the central challenges in reforming research budgeting: creating a system that is both universally applicable and sufficiently flexible to reflect institutional differences in scale, structure, location, and administrative capacity.

• The Simple Option uses fixed percentages of the total project budget for a subset of the FAIR cost categories (i.e., 10% for ERPS, 15% for GRO).

• The Detailed Option allows institutions to calculate each ERPS element individually, while GRO remains fixed at 15%.

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The Simple Option (Figure 2), which in concept is similar to the standard deduction option of a personal income tax form, enables institutions to apply the FAIR model with the use of mostly existing administrative systems.

With it, the ERPF and RIDS elements are not explicitly costed in the budget but rather are included as a flat 10 percent of the total budget. Consequently, institutions utilizing the Simple Option (see below) would have 25 percent of the total budget of a given project allocated to support costs, with the ability to still include RC and AMOR costs as explicit charges.

A comparison of the Simple Option (Figure 2) to the Detailed Option (Figure 1), the latter of which is analogous to the itemized version of a personal income tax form, shows that the Detailed Option provides greater specificity and allows institutions to align ERPS charges with actual support services provided on a project-by-project basis. This approach is most appropriate for institutions with established costing infrastructure, a diverse set of project types, or a desire for more accurate attribution of support costs. Each institution would, based upon analysis of its own data, select which option is most appropriate and apply it to all proposals.

A final and very important question about the FAIR model concerns whether it saves the government (taxpayers) money. The JAG goal was to develop a costing model that explicitly accounts for the actual costs of research. Because the FAIR model does just that, it enables a conversation about how much, and in what categories, funding for research should be apportioned among the government and other sources. The responsibility for determining this distribution rests with Congress and the executive branch, though hopefully with input from the research community.

6. Summary and Implementation of the FAIR Model In summary, the FAIR model eliminates the F&A structure entirely, applies to all organized research, increases accountability and transparency by explicitly accounting for the actual costs for performing and supporting research, is expected to apply equally to all agencies, accommodates all types and sizes of research organizations which operate under 2CFR200 (Unform Guidance), automatically accounts for geographic and institutional cost differentials, aligns project costs with the type of work being performed, funds federallymandated research compliance, addresses the reimbursement issue, and has a structure similar to that utilized by private foundations which fund research.

From the outset, JAG has promoted the idea that the FAIR model be placed in law, thereby providing durability and stability to the research enterprise. Without question, time and effort will be required to implement the FAIR model, which is why JAG is proposing a two-year implementation period. The FAIR model is recommended to be applied uniformly, by all federal agencies, to research assistance awards without arbitrary and capricious changes that damage the government-researcher partnership.

As such, changes to the Uniform Guidance will be necessary and can be developed during the implementation period. N

Figure 2. FAIR model Simple Option (compare to the Detailed Option in Figure 1).

References US General Accounting Office, 1992. System for reimbursing universities’ indirect costs should be reevaluated. Publication RECD-92-203. www.gao.gov/assets/rced-92-203.pdf US General Accounting Office, 1995. University research: Effect of indirect cost revisions and options for future changes. Publication RCED-95-74. www.gao.gov/products/RCED-95-74 US Government Accountability Office, 2010. Policies for the reimbursement of indirect costs need to be updated. Publication GAO-10-937. www.gao.gov/assets/gao-10-937.pdf US Government Accountability Office, 2013. Biomedical research: NIH should assess the impact of growth in indirect costs on its mission. Publication GAO-13-760. www.gao.gov/products/GAO-13-760 U.S. Government Accountability Office, 2017. National Science Foundation: Actions needed to improve oversight of indirect costs for research. Publication GAO-17-721. www.gao.gov/products/GAO-17-721 i

The term facilities and administrative (F&A) costs came into existence in the May 1996 revision of “Cost Principles for Higher Education Institutions” (OMB Circular A-21) to more accurately describe the components of what had previously and synonymously been known as indirect costs or overhead. ii Exceptions include, for IHEs, research performed off campus, which involves applying only the administrative component of the F&A rate, as well as other sponsored activities (OSA) and educational activities. Many institutions apply their uncapped F&A rate to private company sponsors.

Dr. Kelvin K. Droegemeier is Professor and Special Advisor to the Chancellor at the University of Illinois Urbana-Champaign. He spent 38 years at the University of Oklahoma and was Vice President for Research.

Droegemeier served on the National Science Board and was Director of The White House Office of Science and Technology Policy. He can be reached at kkd@illinois.edu.

Dr. Jenny Lodge is Vice President for Research and Innovation at Duke University, having been a leader in academic administration for over 20 years at three universities, (Duke, Washington University, St. Louis University). She focuses on strategic growth and operational excellence and is an active biomedical scientist studying pathogenic fungi. She can be reached at jennifer.lodge@duke.edu.

Dr. Kurt Marek is the Chief Research Development Officer at Sanford Burnham Prebys Medical Discovery Institute (SBP). As a member of the Institute’s executive leadership team, he provides oversight of research operations, sponsored projects, research development, and business development. He can be reached at kmarek@sbpdiscovery.org.

Acknowledgments The authors gratefully acknowledge the following, all listed in alphabetical order.

Principals of the Joint Associations Group (JAG) organizations: Mark Becker, David Cabrera, France Cordova, Waded Cruzado, Kara Freeman, Barbara Mistick, Ted Mitchell, Matt Owens, David Skorton, Barbara Snyder, and Chuck Welch; members of the JAG Steering Group: Debbie Altenburg, Meredith Asbury, Leslie Belcher, Liz Clark, Ian Dunn, Stephanie Giesekce, John Hildreth, Cindy Hope, Hollye Hunt, Susan Martinis, Sue Merrilees, Jeff Peters, Heather Pierce, Tannaz Rasouli, Dave Richardson, Carol Silva, Sarah Spreitzer, Roger Wakimoto, Paul Weinberger, and Carrie Wolinetz; and members of the Subject Matter Expert Team: Anupam Agarwal, Nancy Andrews, Meredith Asbury, Kristina Baum Gargiulo, Neil Canfield, Robert Cramer, Howard Fox, David Gray, Cindy Hope, Jim Incalcaterra, Ming Lei, Tim Lieuwen, Willie May, Stacy Rastuskas, Euan Robinson, Sally Rockey, Michael Rosenfield, Gil Tran, Diego Vasquez Nick Wigginton, and Steve Zuraf.

We also extend our sincere thanks to Congress, The White House Office of Management and Budget, and the many thousands of our colleagues in the research community for their thoughtful suggestions and support of our effort.

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Dr. Stacey Patterson is Vice President for Research at Florida State and has served in research leadership for nearly 20 years (FSU and University of Tennessee). Dr. Patterson has secured significant extramural funding, led major statewide initiatives, and co-founded a tech-based startup to further her research. She fosters innovation through strategic partnerships and collaboration. She can be reached at stacey@fsu.edu.

Dr. Penny Gordon-Larsen is Vice Chancellor for Research at UNC-Chapel Hill and William R. Kenan, Jr. Distinguished Professor of Nutrition. She leads the University’s $1.5B research enterprise and is an internationally recognized obesity researcher. Dr. Gordon-Larsen advances strategic partnerships, research infrastructure, and translation, while shaping national science policy through leadership roles with NIH, AAU, and APLU. She can be reached at pglarsen@unc.edu.

2025 UNIFORM GUIDANCE DESK REFERENCE This handy reference includes the regulatory updates issued April 2024, OMB FAQS and Key Revisions issued January 2025.

Bulk Pricing Available.

Order Yours!

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2024 Updates to Uniform Guidance: Key Changes and Terms for Pass-Through Entities and Foreign Subrecipients

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By Amanda Humphrey

ecent announcements from the US federal government, through the National Institutes of Health (NIH) and the White House, signaled to the research community that pass-through entities (PTEs) and subrecipients should anticipate changes in how research collaborations are funded and managed. NIH Policy Announcements (NOT-OD-25-104 and NOT-OD-25-130) state the NIH’s intent to fundamentally reshape the relationship between PTEs and subrecipients, while the White House’s recent Executive Order “Improving Oversight of Federal Grantmaking” lays out a plan for the US government to make significant changes to the grantmaking and oversight process. Prior to these announcements, material updates to the Uniform Guidance (UG) recently became effective, impacting the oversight

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of subrecipients. Both PTEs and subrecipients should be aware of the following changes: An emphasis on the programmatic monitoring of subrecipients Sections 200.308.b and 200.308.f Revision of Budget and Program Plans, 200.329.b Monitoring and Reporting Program Performance, and 200.332.e Requirements for Pass Through Entities underwent subtle changes that emphasize the responsibility of the PTE to monitor both the financial and programmatic aspects of a subrecipients’ work. By reviewing the modifications to the three sections together, a general theme arises making clear that PTEs have a responsibility to monitor both the programmatic and financial performance of a subrecipient.

200.308.b was modified to add a direct tie to the requirements of Section 200.329 and to include additional language regarding prior approvals for programmatic changes to work performed by a subrecipient.

200.329.b Reporting Program Performance has been revised to include stronger language that PTEs are responsible for understanding and measuring subrecipient performance: “Reporting requirements must clearly indicate a standard against which the recipient's or subrecipient's performance can be measured.” Since appropriate measures may vary significantly based on discipline and the scope of work, determining the best way to incorporate this new requirement into subrecipient monitoring efforts is likely to be project specific. Still, it should be a focus for PTEs and subrecipients. Partners should consider developing measures that are tailored to the resources available to the institution, as well as to the discipline and scope of work.

200.332.e Requirements for Pass-Through Entities have been revised to add language requiring the PTE to ensure the subrecipient has completed the “goals and objectives of the subaward.”

Changed or clarified specificity regarding prior approvals and communication between PTEs and subrecipients, and PTE and funding agencies 200.308.b and 200.308.f Revision of Budget and Program Plans has been updated to clarify that grant recipients must seek prior approval for changes to the program scope and objectives. 200.308.f clarifies when PTEs must seek prior approval to add, change, or modify a subrecipient organization or a subrecipient’s scope of work.

While not a significant change, it serves more as a clarification of the PTE's responsibilities to communicate specific changes in work performed by a subrecipient to the funding agency.

200.332.e Requirements for Pass-Through Entities includes a new requirement for PTEs to notify the funding agency when the PTE adds additional terms and conditions to a subaward. This section is largely complementary to the changes in 200.329, both of which point to a clear need for communication up and down the chain from funding agency to PTE and PTE to subrecipient and vice versa.

PTEs and subrecipients should be mindful of effective communication practices that may help to ensure the requirements of 200.308, 200.329, and 200.332 are thoroughly documented to stand up to any audit.

Changes in prior approval requirements for administrative and clerical salaries 200.413 Administrative Salaries was updated to remove the requirement for the federal funding agency to explicitly approve administrative and clerical salaries. However, the modifications to the provision do not relieve PTEs or subrecipients from the requirement to document the direct benefit to the project of any administrative and clerical salaries charged to a project. It also does not alleviate the PTE from verifying that administrative and clerical salaries are not also being charged as part of the overhead or Facilities and Administrative (F&A) cost recovery pool. While this change is less likely to impact foreign subrecipients (foreign entities are less likely to have a negotiated overhead rate) PTEs should remain vigilant as they still have an obligation to ensure that any administrative or clerical salaries directly benefit the project and are well-justified.

A new reporting requirement related to equipment 200.313.d.3 Equipment. In addition to increasing the threshold for capital equipment from $5,000 to $10,000, the UG updates also added a requirement that in the event equipment is lost, damaged, or stolen during the period of performance, that the recipient must investigate the matter and report on it to the funding agency.

While equipment does not often come up in the context of subrecipients, especially foreign subrecipients, it is worth noting because this new provision may require organizations with equipment to develop some new procedures to ensure compliance with this new requirement. PTEs may wish to consider

adding a specific notification requirement to subawards that contain a budget item for capital equipment.

A revised invoice certification 200.415 Required Certification includes a straightforward change to the required attestation on all subrecipient invoices that the expenses reimbursed conform to federal funding agency requirements. The language now includes a reference to 18 USC 1343, a statute that criminalizes wire fraud.

Additionally, PTEs will need to review invoices to ensure that the certification language meets the new requirements. On the other hand, subrecipients must ensure that their invoice templates include this new certification.

Notably, these updates are worth highlighting to foreign subrecipients because they may have subtle or explicit impacts on how PTEs manage and interact with their international subrecipients. Foreign entities should be aware of these changes and understand their intent, so they can better prepare to implement them within their organization. N

“

PTEs and subrecipients should be mindful of effective communication practices that may help to ensure the requirements of 200.308, 200.329, and 200.332 are thoroughly documented to stand up to any audit.

” References Executive Order No. 14332, 90 FR 38929 (2025). www.whitehouse.gov/presidentialactions/2025/08/improving-oversight-of-federal-grantmaking.

National Institutes of Health. (2025). Updated NIH policy on foreign subawards (NOT-OD-25-104).

U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/noticefiles/NOT-OD-25-104.html.

National Institutes of Health (2025). Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects (NOT-OD-25-130). https://grants.nih.gov/grants/guide/noticefiles/NOT-OD-25-130.html.

2 CFR 200.308 (2024). www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpartD/section-200.308.

2 CFR 200.313 (2024). www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpartD/subject-group-ECFR8feb98c2e3e5ad2/section-200.313.

2 CFR 200.329 (2024). www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpartD/subject-group-ECFR36520e4111dce32/section-200.329.

2 CFR 200.332 (2024). www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpartD/subject-group-ECFR031321e29ac5bbd/section-200.332.

2 CFR 200.415 (2024). www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpartE/subject-group-ECFRd93f2a98b1f6455/section-200.415.

Amanda R. Humphrey is the Chief Research Operations Officer for Northeastern University in Boston, MA. Amanda serves as the Region 1 Professional Development Chair for NCURA. At the Federal Demonstration Partnership (FDP), she serves as the Chair of the Research Administration Committee. Amanda is a Certified Research Administrator and completed an MBA at Northeastern. She can be reached at a.humphrey@northeastern.edu.

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National Academies of Sciences, Engineering and Medicine Report, Simplifying Research Regulations and Policies:

Optimizing American Science

By Lisa Nichols, Stacy Pritt, and Christopher Viggiani

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he National Academies Committee on Improving Regulatory Efficiency and Reducing Administrative Workload to Strengthen Competitiveness and Productivity of U.S. Research published its report, Simplifying Research Regulations and Policies: Optimizing American Science on September 3, 2025. The Committee “conducted an expedited study to examine federal research regulations and identify ways to improve regulatory processes and administrative tasks, reduce or eliminate unnecessary work, and modify and remove policies and regulations that have outlived their purpose while maintaining necessary and appropriate integrity, accountability, and oversight.”

The report highlights “a dramatic rise in regulations, policies, and requirements over time” and “excessive, uncoordinated, and duplicative policies and regulations surrounding research” that “are hampering progress and jeopardizing American scientific competitiveness.” Rather than prioritized recommendations, the report offers numerous options the federal government could adopt to simplify the oversight of research, enabling researchers and research administrators to focus more on scientific discovery. Topics addressed include: • Grant Proposals and Management • Research Misconduct • Financial Conflict of Interest in Research • Protecting Research Assets, which includes Research Security, Export Controls, and Cybersecurity and Data Management • Research Involving Biological Agents • Human Subjects Research and, • Research Using Nonhuman Animals 58

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Overarching options to address issues raised in the report include: • Establishing a permanent career role in the Office of Management and Budget that is charged with coordinating cross-agency requirements that affect federally funded academic research and has the authority to ensure agency coordination, working collaboratively with the Office of Information and Regulatory Affairs (OIRA) and the Office of Science and Technology Policy (OSTP), and utilizing the National Science and Technology Council to institute harmonization.

• Reauthorizing the creation of a Research Policy Board within OIRA, granting it similar composition and authorities to those outlined in the 21st Century Cures Act. • Using the Federal Demonstration Partnership to explore innovative ideas and practices through pilot programs, including use of approaches that are tiered to risk.

As members of this NASEM Committee, we highlight here a few areas where we were principally engaged, including protecting research assets (research security, export controls, and cybersecurity and data management), research misconduct, research involving biological agents, and research involving human participants or animals. Readers are encouraged to review the full report.

Protecting Research Assets In the area of protecting research assets several options were put forth, including: • Implement the National Security Presidential Memorandum-33 (NSPM-33)

common disclosure forms and disclosure table, without deviation, as the primary means to identify and address Conflicts of Commitment (COCs) and develop federal-wide FAQs via the existing interagency working group; in addition, federal-wide use of the Science Experts Network Curriculum Vitae (SciENcv) system, persistent identifiers, and application programming interfaces.

• Establish common principles for agency research security risk reviews for fundamental research.

• Continue prior efforts, chiefly the Export Controls Reform Initiative, to streamline and clarify export controls and reduce associated administrative work, with representation from the academic research community, and expedite licensing processes for low-risk controlled research.

• Adapt cybersecurity requirements for university settings: direct the National Institute of Standards and Technology, in collaboration with OSTP and the broader research community, to undertake a comprehensive review of cybersecurity controls as they apply to institutions of higher education and make appropriate modifications to ensure alignment with the academic research environment.

The report notes the efforts of the SECURE Program, Center and Analytics, including that “This organization, established in September 2024 and now known as the SECURE Program…serves to connect the research community and collectively design and develop resources and tools to address research security risks and federal agency research security requirements.”

“Although it is relatively new and its evaluation is ongoing, the SECURE Center could be a model for community codesigned resources that facilitate coordinated implementation across institutions.”

Research Misconduct How institutions respond to allegations of research misconduct is challenging because different funding agencies have different policies and required processes. This results in inconsistencies and confusion on the part of research institutions and the uneven application of standards. The report explores ways to streamline research misconduct proceedings including the creation of a single, flexible federal misconduct policy to which all funding agencies defer, or the option to more clearly designate a lead agency to coordinate cases involving multiple funders.

Research Involving Biological Agents The report also highlights the complexity of regulations governing research with biological agents and toxins. Leveraging successful oversight frameworks, it provides options for a more centralized, coordinated federal approach to biosafety oversight, through a single agency that registers and empowers institutional biosafety committees (IBCs).Of note, after the publication of this report, NIH announced its biosafety modernization initiative aimed at strengthening biosafety policies, practices, and oversight to keep pace with the evolving risks.

The report also notes that in recent years, research institutions have become responsible for biosecurity oversight, including the identification and management of dual use research of concern (DURC) and dangerous gain-of-function studies. This type of research has been notoriously difficult to define, making oversight at the institutional level exceedingly challenging.

Compounding the challenge is the fact that universities and other research institutions are typically ill-equipped to identify research with national security implications. The report offers an alternative that would shift responsibility for identifying DURC and gain-of-function research to federal funders, where broader national security and public health expertise resides. This would reduce institutional burden while still ensuring such studies are identified and proceed with appropriate containment and security measures in place.

Human Subjects Research The National Academies report Optimizing the Nation’s Investment in Academic Research, released in 2016, provided a recommendation for single or central institutional review boards (IRBs) to be adopted as a mechanism to improve regulatory burden. While that recommendation has been adopted, clarity around other institutional compliance responsibilities, including those areas that are in addition to human research protections (e.g. data security, privacy, financial conflicts of interest, export control) has emerged as a contributing factor of ongoing administrative burden.

Additionally, there has been inconsistent adoption of the revised 2018 Common Rule (45 CFR 46) across multiple federal agencies. Multiple options provided in the report address these important areas of human research oversight.

Research Using Nonhuman Animals Oversight of research using non-human animals is an area with a well-documented history of regulatory and administrative burden. Multiple agencies directly oversee non-human animal research with overlapping and, in some instances, contradictory requirements. Following previous reviews on this subject, several options are provided to enable the United States Department of Agriculture and the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) to harmonize, streamline, and modernize their oversight processes. Of note, the report contains an option for NIH OLAW to adopt an online platform and streamlined approach for its Animal Welfare Assurance process, building upon nearly identical processes already found within Health and Human Services and NIH. As indicated in the report and known to members of the NCURA community, the lack of agency coordination, duplication, and compounded burden of research administration and compliance requirements is well worn territory.

The question is whether in the current climate, the community can advance these common sense options. The report serves to reignite the discussion.

As a community we can seek to maintain the dialogue and look for opportunities to promote change. N

Dr. Lisa Nichols is the Executive Director, Research Security at the University of Notre Dame where she oversees many of the university's research compliance programs. In addition to her experience in the academic research sector, she previously held roles with OSTP, NIH, NSF and COGR. She can be reached at lmnichols@nd.edu

Dr. Stacy Pritt is the Associate Vice Chancellor and Chief Research Compliance Officer at the Texas A&M University System and oversees research compliance initiatives across 12 academic institutions and 8 state agencies. Additionally, she is an adjunct professor in the College of Veterinary Medicine & Biomedical Sciences at Texas A&M University.

She can be reached at spritt@tamus.edu Christopher Viggiani, PhD, is Associate Vice President for Research Integrity at Oregon State University, leading programs that promote ethical, safe, and compliant research. He previously led biosafety and biosecurity policy at NIH and has experience as a molecular biologist, focusing on chromosome stability and telomeres. He can be reached at christopher.viggiani@oregonstate.edu

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Perils of Section 117

FOREIGN GIFTS REPORTING

By Jeff Seo

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he requirement that colleges and universities receiving federal financial aid disclose to the Department of Education (ED) contracts and gifts from foreign sources amounting to more than $250,000 a year is quickly moving to the top of lists of highest compliance risks for higher education. Section 117 of the Higher Education Act of 1986 (Disclosures of Foreign Gifts, 1998) has been in place for decades, yet little attention was paid to the requirement until 2018 Congressional testimony from then FBI Director Christopher Wray called out the threat posed by China’s exploitation of open research at American universities (Redden, 2018).

Several investigations were initiated into top US universities following that hearing, requiring those institutions to provide extensive supplemental data to ED. Most of these investigations were resolved during the Biden administration.

However, the current administration signed an executive order April 23, 2025, charging ED to work with other agencies—including the Department of Justice (DOJ)—to enforce compliance with Section 117 (White House, 2025). New investigations into Section 117 reporting have been announced against the University of California, Berkeley and the University of Michigan (Department of Education, 2025a; Department of Education, 2025b).

Foreign Disclosure: We Have Been Warned While the semi-annual disclosure requirement appears simple, compliance with Section 117 reporting requires careful coordination among various units and a nuanced understanding of the institution’s financial infrastructures—including but not limited to the respective offices responsible for advancement, research administration, procurement, alumni relations, satellite campuses and global affairs.

In July 2022, ED released guidance for Section 117 reporting from which the following highlights can be gleaned (Brown and Corday, 2022): • Institutions are not required to make a Section 117 disclosure if there is no data to report for the relevant period.

• Institutions that fail to report in a timely manner are not in compliance with Section 117.

• Contracts should be evaluated when signed, and gifts should be evaluated based on the amount actually received.

• Institutions must make a reasonably good faith effort to determine whether a gift or contract relates to a foreign source, including gathering information from the counterparty or conducting independent research.

• Institutions can correct errors in prior reports by emailing the DOE’s Foreign Gifts Access Team as soon as it identifies an undisclosed reportable transaction.

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• In certain situations, a foreign subsidiary of a US-based corporation or parent company may constitute a foreign source; in such cases institutions must make a determination as to whether the subsidiary meets the definition of “foreign source”.

• Disclosure reports should not be reported in the aggregate, but rather “must reflect the details of each discrete transaction”.

Although the $250,000 per year threshold may currently limit the number of institutions required to make Section 117 disclosures, the pending “Deterrent Act” in the House of Representatives proposes to reduce the amount to $50,000 per year and require the disclosure of foreign gifts or contracts from a foreign country of concern (i.e., China or Russia) for any amount (Deterrent Act, 2025). If enacted, the House Bill would further require institutions of higher education to disclose individual researcher’s gifts and contracts from foreign sources as well as any institutional foreign assets and investments.

The challenge for most institutions is determining what constitutes a reasonably good faith effort to determine whether a gift or contract relates to a foreign source.

The institutional effort to comply with Section 117 reporting varies widely among colleges and universities. Most institutions designate a single point of contact within the treasurers or finance office to consult with relevant units, gather the data, and make any disclosure through the ED portal.

However, the renewed focus on transparency of such disclosures and subsequent investigations emphasizes the need for complete accuracy in Section 117 disclosures, especially for those institutions which have a significant population of international students or operate global programs.

The challenge for most institutions is determining what constitutes a reasonably good faith effort to determine whether a gift or contract relates to a foreign source. While a focus on immediate financial transactions is common, institutions should perform greater due diligence by looking more broadly to understand how the dollars being received are tied back to foreign entities.

What remains unknown is how federal research sponsors might leverage the Section 117 data. Similar to the use of ORCID and Science.gov data by sponsors to identify potentially undisclosed foreign collaborations and/or evidence of undue foreign influence, institutions should anticipate sponsors comparing any Section 117 reported gifts or contracts with any related funded grants, and doublecheck whether the relevant Biosketches, Other Support, or Current & Pending documents also reference these gifts and contracts. Any disparity between such documents could very well serve as a basis for an investigation and, in extreme cases, a basis for the withholding of federal funds.

Once viewed as a vague and obscure administrative requirement, Section 117 reporting now represents a formidable and resource intensive obligation that should be taken very seriously.

Once viewed as a vague and obscure administrative requirement, Section 117 reporting now represents a formidable and resource intensive obligation that should be taken very seriously. When the ED requirement is viewed in conjunction with related sponsor requirements such as NSF’s implementation of PAPPG Chapter VII.D.3 (PAPPG, 2024) and state reporting requirements such as the Florida statute on Foreign Gift Reporting (Florida, 2021) careful coordination, assessment and review of any disclosures demands extreme due diligence as evidenced by the use of these disclosures as an enforcement tool.

We have been warned. N

WORK SMART Small Changes To Incorporate Collaboration Yield Big Results

By Hang McLaughlin

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he benefits of collaboration have been documented: helping achieve goals more efficiently, increasing employee engagement and motivation, better individual and team performance (Pentland, 2013; Carr & Walton, 2014). Employee engagement is especially important in post-Covid research administration since many offices allow hybrid or remote working arrangements. Creating a fully collaborative team could require making drastic changes, but one small change that might provide big results towards building collaborative practices is engaging team members in the development of a running meeting agenda.

Creating a running meeting agenda ensures time is used efficiently to address issues that truly matter to team members while including meaning items on the agenda for discussion at team meetings. Examples of agenda items may include sharing notifications of new sponsor guidelines; presenting case studies; or posing questions about how to handle a tricky scenario. The agenda then serves as a resource for the team by documenting the team’s approach and creating a ready reference of written guidelines. This accessible documentation could ease anxiety associated with changes, such as implementing new processes from Uniform Guidance updates.

Below are simple steps to developing a running, collaborative meeting agenda: • Make the agenda a shared document that everyone on the team can edit and access.

• Create a rotation whereby each team member takes a turn at being responsible for preparing the agenda and taking notes during the meeting.

• Make all team members, regardless of whether it is their turn in the rotation, responsible for adding agenda items before each meeting.

• Add new meeting items to the top of the agenda, but retain the old agenda items (along with notes) in the same document; this allows for easy searching of past agenda items.

References Brown, L., & Cordray, R. (2022, July). Section 117 of the higher education act presentation by the U.S. Department of Education. [Powerpoint slides]. www.ed.gov/sites/ed/files/policy/highered/leg/section117-webinar-202206.pdf Deterrent Act, H.R.1048 - 119th Congress (2025-2026) (2025, February 6). www.congress.gov/bill/119th-congress/house-bill/1048 Florida Statute 1010.25 (2021), Foreign Gift Reporting. Florida.Public.Law. https://florida.public.law/statutes/fla._stat._1010.25 National Science Foundation (2025). NSF’s implementation of PAPPG Chapter VII.D.3 ‘Foreign Gifts and Contracts Disclosure’. www.nsf.gov/research-security/foreign-gifts-contracts-disclosure Proposal and Award Policies and Procedures Guide, National Science Foundation (2024), Chapter VII.D.3 “foreign gifts and contracts disclosure.” www.nsf.gov/policies/pappg/24-1/ch-7-awardadministration.

Redden, E. (2018, February 14) “The chinese student threat?” Inside Higher Ed. www.insidehighered.com/news/2018/02/15/fbi-director-testifies-chinese-students-andintelligence-threats U.S. Department of Education, Office of Communications and Outreach. (2025a, April 25). U.S. Department of Education returns section 117 foreign funding enforcement to Office of General Counsel, announces investigation into UC Berkeley. www.ed.gov/about/news/press-release/usdepartment-of-education-returns-section-117-foreign-funding-enforcement-office-of-generalcounsel-announces-investigation-uc-berkeley U.S. Department of Education. (2025b, July 15). U.S. Department of Education opens foreign funding investigation into the University of Michigan. www.ed.gov/about/news/press-release/usdepartment-of-education-opens-foreign-funding-investigation-university-of-michigan White House, Executive Orders (2025, April 23). Transparency regarding foreign influence at American universities. The White House. www.whitehouse.gov/presidentialactions/2025/04/transparency-regarding-foreign-influence-at-american-universities Disclosures of Foreign Gifts, 20 U.S.C. § 1011f (1998). https://uscode.house.gov/view.xhtml?req=(title:20%20section:1011f%20edition:prelim

References Carr, P. B. & Walton, G. M. (2014). Cues of working together fuel intrinsic motivation.

Journal of Experimental Social Psychology, 53, 169-184. https://doi.org/10.1016/j.jesp.2014.03.015 Pentland, A. (2013). Beyond the echo chamber. Harvard Business Review, 91(11), 80-86. https://hbr.org/2013/11/beyond-the-echo-chamber

Jeff Seo is the Chief Research Compliance Officer at Northeastern University where he is responsible for the development and oversight of the office for research compliance that serves as a broad resource for the research community across sponsored and regulatory compliance areas. He also serves as a NCURA peer reviewer and as a contributing editor of NCURA Magazine. In 2023, he was recognized as one of the recipients of the NCURA Julia Jacobsen Distinguished Service Award. Jeff can be reached at j.seo@northeastern.edu.

Hang McLaughlin, M.Ed., is the Grants and Contracts Manager for the Department of Surgery at the University of Minnesota. With over fifteen years of research administration experience in various roles in the department and central sponsored projects office, she has experience with federal, foundation, and business & industry grants from the proposal stage to post-award management. She has been involved with NCURA for more than five years as a volunteer, presenter, committee member, and a Region IV board member. Hang can be reached at mcla0030@umn.edu.

The running meeting agenda and its development through a collaborative process can yield great benefits for research administration teams. Team members might actually want to have meetings because they are more engaged and know that their questions and concerns will be addressed or that they will learn something relevant. N

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TRAINING TIPS

Managing the 2024 UG Update: Challenges and Successes in Training and Communication

By Luke Lynch, Tricia Callahan, David Hollingsworth, and Kathryn

T

he October 2024 revisions to the Uniform Guidance (UG) sent ripples through institutions, prompting significant adjustments beyond “general” updates for some. With new legislation, regulatory requirements, and refined definitions, institutions faced the task of integrating these changes. This article delves into the diverse strategies employed by institutions to navigate this evolving landscape, from prioritizing key areas to undertaking comprehensive overhauls of policies, processes, and systems. We also discuss, as trainers, how we handled or responded to the changes brought by the UG update, including some tactics that were beneficial to our institutions and research administration staff.

Prioritizing Key Areas Faced with uncertainty and conflicting information, institutions were compelled to prioritize internal changes strategically. Prioritization often began with the formation of cross-functional task forces including representatives from sponsored programs, grants and contracts, finance and accounting, internal audit, procurement, legal counsel, information technology, research compliance, and faculty/staff leadership.

These task forces were responsible for reading and interpreting the new UG and monitoring changes to agency-specific policies. To monitor these changes, many of us looked to: • Council for Federal Financial Assistance (COFFA.gov): Provides official Office of Management and Budget (OMB) guidance on the UG, including the latest revisions, redline edits, implementation information, and FAQs. • Council on Governmental Relations (COGR.edu): Offers a dedicated 2 CFR 200 UG resource page with publications, webinars, and analyses of proposed and final guidance.

• Federal Agency Websites: Provide news and updates on agency policies and procedures.

• Federal Demonstration Partnership (THEFDP.org): Hosts meetings and working groups on developing research terms and conditions, subaward templates, and UG implementation.

• NCURA 2025 Changing Federal Landscape Online Community: A collaborative community that provides dedicated space for research administrators to connect, collaborate, and navigate the evolving landscape of policies and regulations with the federal government.

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Once changes were understood, task forces performed gap analyses to ensure their institutions’ existing policies, procedures, and systems met the new requirements. Following this, risk assessments helped prioritize areas that posed the greatest financial and reputational risks.

The task of prioritizing and making these changes is still ongoing. Once changes were implemented, clear communication and training became critical to ensure all stakeholders understood and could properly follow any newly developed policies and procedures.

“Faced with uncertainty and conflicting information, institutions were compelled to prioritize internal changes strategically.”

Training and Communication Dissemination of information about the 2024 UG update was key for our institutions. Fortunately, a pre-publication version of the guidance was issued in April, well before the October effective date. This provided an opportunity for our institutions to prepare for the changes by communicating updates in meetings and university-wide presentations, engaging in external training opportunities (such as webinars and conferences), organizing training sessions and communications on the updates, and offering refresher courses on the UG itself.

Key updates on immediate implementations, such as modifications to capitalization and subrecipient thresholds, were clearly communicated, alongside information on future adjustments. This approach allowed our institutions time to make necessary changes to systems and procedures.

Email listservs for faculty and staff, as well as hosting monthly research administrator campus meetings, proved very effective for communicating changes and timelines.

Training’s Role in the Evolving Landscape As trainers, we must remain flexible and ready to shift priorities. Often, we are among the first to know about impending changes in research administration. With the steady stream of information from federal agencies since the beginning of 2025, our top priority has been to disseminate these updates in tandem with changes being made at the institutional level.

As our institutions continue to monitor and communicate on the evolving federal landscape, it’s our job to ensure ongoing communication precisely captures what these changes mean for the day-to-day roles and responsibilities of our faculty and staff. By being good communicators, we set ourselves, our faculty and staff, and our institutions up for success. N

Luke Lynch, MA, MEd, is Assistant Training Coordinator in Sponsored Projects Administration at the University of Minnesota. In his role at UMN, he develops and teaches courses on various topics in research administration and helps manage a curriculum certification program. He is an active member in NCURA, currently sits on the Select Committee on Diversity, Equity, and Inclusion (SCDEI), and has presented at several of NCURA’s regional meetings. He can be reached at lync0172@umn.edu.

“As trainers, we must remain flexible and be prepared to adjust our priorities.”

Tricia Callahan, Interim Director for Research Training, Emory University, has been a long-time volunteer with NCURA. Tricia currently serves on the NCURA Select Committee for Peer Review and is a Traveling Workshop Faculty for the Fundamentals of Sponsored Project Administration. She can be reached at tricia.callahan@emory.edu.

David Hollingsworth, CRA, is the Director of Professional Development and Outreach in Sponsored Research Services, Texas A&M University.

In this role, he implements and maintains a broad array of research administration-related learning opportunities and resources and coordinates review sessions for the CRA. He can be reached at dhollingsworth@tamu.edu.

Kathryn O’Hayre, CRA, is a Training and Information Coordinator at Colorado State University, building programs and resources for sponsored programs. Kathryn has contributed to NCURA professional development learning opportunities since 2020 through volunteering on various committees and presenting at conferences and webinars at both the regional and national levels. She can be reached at kathryn.ohayre@colostate.edu.

Crafting Fully Compliant Budgets This publication introduces foundational concepts and best practices in sponsored project budget development.

Topics include: • Sponsor Requirements • Allowable Direct and Indirect Costs on Federal Awards • Cost Sharing • Budget Justification • Salary Limitations • Types of Budgets • Requirements and Nuances for Federal and Non-Federal Awards • Sample Calculations and Explanations

GET IT HERE! https://onlinelearning.ncura.edu/read-and-explore

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Shifting the Lens: Female PIs and RAs Navigating Administrative & Financial Changes in 2025 By Kathryn Callahan and Alex Domaleski

I

n recent years, the research administration community has seen significant shifts in funding priorities, compliance requirements, and institutional processes. Recent administrative adjustments, particularly those aligning with updated Uniform Guidance, have reshaped the day-to-day realities of research. Principal Investigators (PIs) are navigating increased demands for supporting documentation and new pre-award compliance requirements.

While they acknowledge that the current environment demands adaptability and persistence, they also see opportunities to strengthen their proposals, diversify their funding sources, and pursue cross-disciplinary projects that may not have been feasible in the past. The increased emphasis on compliance has, for some, prompted more strategic planning and proactive engagement with pre-award staff.

In this article, we sought to collect feedback from female PIs/Research Administrators (RAs) for questions on navigating the current administration, limited funding, and challenges when facing diversity.

Administrative Changes and Adaptation The evolving funding landscape has required both PIs and researchers to broaden their grant-seeking approaches. This means casting a wider net beyond federal opportunities to include foundations, industry partnerships, and collaborative consortia.

At the Lundquist Institute for Biomedical Innovation at Harbor-UCLA Medical Center, early-career investigator Dr. Bridgette Blebu shared her thoughts and approaches. “I think as an early-career investigator, funding and project management is already a challenging thing to navigate as you begin to move into independence as a researcher.” Those challenges are amplified when evolution in the funding and compliance landscapes is rapidly occurring.

When it came to navigating funding opportunities, Dr. Blebu focused on changing her mindset. “Instead of looking only at the ways the new landscape may limit my research, I considered ways that it could meaning64

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fully expand.” Additionally, she sought external partnerships outside the institution and expanded her scope to look at “intersections of research and programming that could support more innovative research.”

PIs face many changes not only navigating increased documentation and pre-award compliance requirements but also navigating the changes in policies. It is on our administrators to be accountable, being informed and proactive, to help support and guide PIs through the changes successfully.

“With increasing competition for limited resources and growing complexity in sponsor requirements, I’ve found it essential to remain flexible, proactive, and highly collaborative,” said Jessica McDonough, Assistant Director of Research Administration and Subaward Compliance Officer at the Lundquist Institute.

Diversity and Equity It is crucial that investigators still consider inclusive practices, regardless of changes in federal funding priorities. Increased scrutiny means that researchers must be deliberate about how diversity and equity considerations are woven into both proposal narratives and project execution. Effective strategies and approaches not only reinforce funding competitiveness, but also emphasize the long-term sustainability of inclusive research environments.

Examples of effective strategies to build diversity include building multidisciplinary teams that reflect a range of backgrounds, partnering with minority-serving institutions, and incorporating mentorship components to support early-career scholars from underrepresented groups.

When it came to how she wanted to manage her projects and apply for funding, Dr. Blebu considered diversity and equity needs at the forefront.

She discovered that doing this opened her up to new opportunities she may not have come across otherwise.

“First outline everything” Dr. Blebu said, “and clearly define what it would take to ensure diversity and equity are centered in the work upfront.”

This approach of outlining all the needs ahead of time “is useful for maintaining productivity while relieving some pressure on getting the bigger grants.”

Institutional Support Institutional support is another important factor for research administrators as much as it is for the PIs. For researchers, it is beneficial to know they have the trust of the administrators. For the administrators, it is important that they have the trust of leadership. These relationships are crucial for the success of the institute and institutional research.

For PIs like Dr. Blebu, she emphasized the importance of support from staff and administrators. “It has taken a lot of pressure off keeping up with the influx of information and has helped create more actionable next steps.”

She also credited “staff support for navigating, communicating, and distilling guidance and changes in real-time [which] has been a monumental benefit.”

Administrators such as Jessica McDonough focused on the importance of communication between leadership and the team, stressing that communication and sharing information allows us to be better prepared and face challenges strategically.

“Building strong, trusting relationships with faculty and teams is my priority— meeting folks where they are, listening, and helping them navigate the processes with as much clarity and calm as possible,” McDonough said.

“It’s important to me [that] they feel supported, not overwhelmed, so I try to anticipate potential obstacles early, remove as many administrative burdens, and communicate thoughtfully and transparently. It’s also been a reminder to treat myself kindly since it can be hard to stay positive and remain focused in times of such uncertainty. I’ll take a quick break to move around, reach out to a friend, or laugh, and it helps keep a better mindset.”

Support also needs to come from a place of care and compassion. McDonough reminded us that it not only pays to be strategic, but also to be compassionate. It’s especially important that this compassion comes from leadership. “They remind us to take care of ourselves, which is validating,” she said. “I’ve found reaching out to folks in my network and catching up has also been helpful as a reminder that we’re navigating these challenges together.”

Looking Forward These stories and strategies display both the resilience and innovation at play in today’s research environment. While updates to Uniform Guidance and shifts in funding landscapes present undeniable hurdles, they have also prompted PIs to refine their approaches, seek out new partnerships, and strengthen their commitment to diversity and equity.

Although the future of research administration may seem unsure or unsteady, it has proven time and time again to be resilient. By exchanging skills and best practices across institutions, we can better equip researchers, especially women in leadership roles, to thrive in a continually evolving ecosystem of research administration.

“I choose to believe science will win; research and research administration will hold the line and in the end be stronger,” McDonough says. N

RESOURCE

Kathryn Callahan works in shared services in RISE (Resources for Investigator Services and Engagement) as a pre-award administrator at the Lundquist Institute for Biomedical Innovation at Harbor-UCLA Medical Center. Kathryn has a little under 2 years of experience in research administration and looks forward to getting involved more.

Kathryn can be reached at kathryn.callahan@lundquist.org.

Alex Domaleski is a Grants and Contracts Officer III with the Georgia Health Policy Center at Georgia State University. In this role, she provides comprehensive support for sponsored research activities, specializing in pre- and post-award administration, budget development, proposal routing, and compliance oversight. Alex can be reached at cdomaleski1@gsu.edu.

Available for immediate download through NCURA’s Online Learning Management System

The requirements for documenting compensation charges to federal awards are complicated - we have a resource to help!

This resource provides the framework for understanding the federal requirements for documenting compensation charges to federal awards and the complexities in meeting the requirements, as well as the implications and potential re-percussions if not met.

Topics include: • Requirements of supporting salary charges • Determining what constitutes compensation • Documentation and Internal Controls • Issue and Risks • Common Audit Findings • Other considerations • Example of internal control framework for compensation compliance

Get it here https://onlinelearning.ncura.edu/read-and-explore NCURA Magazine

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Navigating Change:

What the Federal Landscape Means for Research Administration Overview from the NCURA Navigating Change Webinar on 9/15/2025 Dennis J. Paffrath, Associate Vice President for Research Administration, Office of the Vice President for Research, Temple University, Mindy B. Pava, Feldesman LLP Partner, and Edward “Ted” Waters, Feldesman LLP Managing Partner

Disclaimer: This article reflects the panelists’ views and is for informational purposes only; it is not legal advice. Institutions should consult counsel regarding how federal actions apply to specific facts and awards.

A

s panelists in NCURA’s Navigating Change conversation series, we’ve spent the past year tracking rapid shifts affecting federal research awards—grant terminations, indirect cost policy, executive orders, DEI guidance, research security requirements, and rules for foreign subawards. Our goal here is to translate what’s moving in Washington into practical guidance for research administrators.

Where to fight—and what relief is possible.

For decades, grantees typically challenged unlawful grant terminations in federal district court, where judges can issue injunctions that actually restore awards on a temporary basis as the case proceeds on the merits.

Recent Supreme Court actions, however, signal a turn toward the Court of Federal Claims, a forum designed for money damages, not reinstatement.

That distinction matters: we don’t only want money damages—we want the grant back. Shadow-docket decisions from the U.S. Supreme Court leave open questions about where non-termination actions (e.g., freezes) belong, and procedures in the lower courts are still evolving. Expect more

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litigation and, we hope, clearer rules.

FAIR and the 15% de minimis—what’s real now.

Agencies’ efforts to impose a 15% cap across the board ran into preliminary injunctions in district court that have temporarily stopped those efforts; institutions with negotiated rates should continue charging those rates unless and until terms legally change. The FAIR concept remains a proposal, it has not yet become binding law and may be too complex in its current form. Durable policy requires realistic timing: any durable change needs a reasonable transition, not a three-day pivot. Abrupt implementation strains grants management and creates unnecessary risk.

Executive orders and termination for convenience.

Recent executive orders push tighter drawdown controls, elevate indirect cost levels as a selection factor, require political appointee sign-off on NOFOs, and reinforce termination for convenience in grant terms (with broader adoption expected through potential revisions to the Uniform

Guidance). Practically, that means more policy-driven variability across award lifecycles. Remember: executive orders are directives to agencies— not grant conditions—but they’re increasingly being shoehorned into terms once implemented by funding agencies. Read the actual language, assess whether a true mandate applies, and document your interpretation.

DEI: from ambiguity to a (clearer) risk map.

A recent DOJ memorandum offers more concrete examples of practices likely to trigger scrutiny (e.g., preferential treatment, proxy criteria, exclusionary affinity groups) and “best practices” to mitigate risk (e.g., programs open to all, documented non-discriminatory rationales). While the memorandum is non-binding, we recommend a programmatic review of recruiting, training, and affinity activities. Above all, do the analysis and date a memo to file—your best defense in an audit is showing you thought it through.

Near-term compliance: other support & foreign subawards.

Institutions face training and policy requirements tied to “other support” disclosures; align these with broader research security programming where feasible. New NIH guidance on foreign subawards keeps collaborations possible but adds substantial documentation— treat each foreign subaward almost like a mini-application, with heightened attestations and tracking.

“Do the analysis and date a memo to file—your best defense in an audit is showing you thought it through.”

What to do next.

1. Know your terms and conditions and track agency-specific updates.

2. Scenario-plan for termination-for-convenience risk in multi-year awards.

3. Document decisions—legal and compliance analyses, dated and retained.

4. Communicate early with investigators and finance teams about what’s changing and what isn’t.

Uncertainty is real, but so are the tools to manage it. With disciplined documentation, measured planning, and vigilant monitoring of agency actions, research administrators can keep projects moving—even as the ground shifts beneath us. N

The full recording and slides for this and all of NCURA’s Navigating Change Conversation Series can be found under the Changing Federal Landscape tab at www.ncura.edu.

Your trusted partner to help you navigate and adapt to change With the significant—and often unpredictable—changes rippling through the regulatory landscape, making sense of the evolving Indirect Cost Rate policies can seem daunting.

Attain Partners is here to help you navigate the impacts and implications of this new landscape.

Visit attainpartners.com/flat-rate.

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NCURA Regional Corner REGION I New England

REGION II Mid-Atlantic

www.ncuraregioni.org

www.ncuraregion2.org

www.facebook.com/ncuraregioni

www.facebook.com/groups/ncuraregionii

By the time you are reading this, fall is in full swing here in New England.

We had a fantastic annual meeting in Washington, D.C. in August. For those who attended, it was a wonderful gathering filled with informative workshops, engaging sessions, and fun networking events. We are all looking forward to the annual meeting next year in New York City!

I would like to extend big congratulations to our newly elected Region I Leadership team, who will begin their terms on January 1, 2026: • Chair-Elect: Geraldine Pierre, Boston Children’s Hospital • Secretary-Elect: Jennifer Lech, Woods Hole Oceanographic Institution • Treasurer-Elect: Robert Prentiss, Yale University • Board Representative: Denise Rouleau, Tufts University We wish each of them the very best as they step into these roles. Many thanks as well to Jill Mortali and the Governance Committee for their excellent work in preparing this year’s election slate.

Looking ahead, mark your calendars for upcoming events: • FRA/PRA Meetings: March 2026, in San Juan, Puerto Rico — keep an eye out for travel award information.

• Region I Spring Meeting: May 3–6, 2026, at Water’s Edge Resort & Spa in Westbrook, CT. The program committee is already hard at work developing engaging sessions for all levels of learning, along with some fun activities for attendees. We hope to see you there!

As always, Region I thrives because of its volunteers. Whether you are interested in speaking, assisting with registration, helping decorate for the banquet, or simply evaluating sessions, we welcome your participation. If you would like to get involved, please email vc@ncuraregioni.org.

Until next time, enjoy the holiday season with your families, and thank you for being part of Region I! Stacy Riseman, MBA is the 2025 Chair of Region I and serves as Director, Office of Sponsored Research at the College of the Holy Cross. She can be reached at sriseman@holycross.edu.

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Happy Halloween! Region II is just about to hold our 2025 Virtual Fall Meeting, and we’re excited to share and learn from the presenters and attendees! Thank you to all who helped make our meeting a reality! The pivot from in-person to virtual brought some challenges, but we’re happy with how it turned out.

The 2025 Region II election came to an end last month. Thank you to all nominated candidates for their willingness to serve the region and thank you to everyone who participated! We had our largest voting turnout to date. Please join us in congratulating and welcoming the 2026 members of the Region II Leadership Team who will serve the region beginning January 1, 2026: Region II Chair-Elect: Cynthia Kane, Lehigh University Region II Treasurer-Elect: Shelly Liang, NYU Langone Health Region II Secretary: Erin Grady, George Washington University The 2025 book club selection is Say More About That: ...And Other Ways to Speak Up, Push Back, and Advocate for Yourself and Others by Amber Cabral. The first brown bag book discussion session will be on November 12. Watch your email for the link to this session or check the Region 2 website for more information.

Watch for announcements on the Region II website, Facebook, Collaborate and in e-blasts and the quarterly newsletter. Please reach out to me if you have any suggestions for programming, networking opportunities or events/activities. We are here for YOU! Cassie Moore is the 2025 Region II Chair and serves Assistant Director at the Office of Research Administration at the University of Maryland, College Park.

She can be reached at cmoore17@umd.edu.

REGION III Southeastern

REGION IV Mid-America

www.ncuraregioniii.com

www.ncuraregioniv.com

www.facebook.com/ncuraregioniii

www.facebook.com/pages/Ncura-Region-IV/ 134667746605561

Happy fall semester to our flamingo family! We hope that our members, friends, and families are looking forward to the necessities: cooler temperatures, spooky season, pumpkins, and fall beverages!

Region III would like to thank the NCURA national staff and the AM67 program committee for putting together a fantastic conference of Forward Focused Priming for Change with our research administration family.

Eight Region III members served on the program committee for this year’s meeting: • Leah Acajabon (Attain Partners) - Financial/Post Award • Candice Ferguson (Georgia State University) - Discovery & Innovation Showcase • Kathleen Halley-Octa (Attain Partners) - Systems, Data and Artificial Intelligence • Danielle McElwain (University of South Carolina) - Departmental • Carpantato "Tanta" Myles (Georgia Institute of Technology) Medical/Clinical/Industry • Scott Niles (Georgia Institute of Technology) - Pre-Award/Research Development • Lisa Stroud (University of Florida) - Systems, Data and Artificial Intelligence • Shannon Sutton (Georgia State University) - NCURA Vice President With AM67 complete, it’s time to shift our focus to Region III’s Spring Meeting at the Embassy Suites by Hilton Myrtle Beach Oceanfront Resort in Myrtle Beach, South Carolina. The meeting will be held May 3 – 6, 2026.

Information about our program committee and theme are coming soon!

In August, Region III held an election for Chair-Elect. We would like to thank all our candidates for their service to the region and congratulate our newly elected official: Chair-Elect, Erika Cottingham (Auburn University).

Did AM67 inspire you to lend a hand to help your flock? Fill out our volunteer survey (www.ncuraregioniii.com/volunteer) and one of our coordinators will reach out to talk about opportunities.

Lastly, Region III Professional Development Committee is thrilled to announce the very first cohort of the LEAP (Learn. Engage. Aspire. Present.)

Program! LEAP is an 8-month pilot leadership and professional development journey designed for research administrators across Region III. Inspired by the growth of the nautilus shell, LEAP encourages participants to build layer upon layer of purpose, vision, confidence, and skills.

Until next time, stay in touch and keep up with the latest regional news by connecting with Region III on Facebook, Twitter, and Instagram or joining the RIII Collaborate Community. You can also find up-to-date information on our website.

I think it is very true to say that after attending an NCURA meeting we are more energized and thankful for the roles we are in. The collaborative thinking and learning we share moves us forward into our future with hope and excitement. I surely felt this way after attending the Annual Meeting and a strategic planning meeting with NCURA leadership.

Region IV had a great presence at AM67. 218 members from our region, of which 70 were first-time attendees, made it to DC to present, learn, and share what we know about the profession. In the August issue, I thanked those who were track leads for the meeting, but I made a major faux pas and failed to give Kathy Durban (Marquette University) a shout out for co-chairing AM67. Kudos to Kathy for organizing an outstanding meeting. Thank you to all who volunteered at the meeting. Special thanks to Jennifer Foley (Medical School of Wisconsin) creating the cow games.

Congratulations to those that received national awards. Roger Wareham (University of Wisconsin – Green Bay) received the Julia Jacobsen Distinguished Service Award and Kim Lammers (University of Toledo) and Madelyn Heskett (Ball State University) were awarded the Emerging Excellence in Research Administration Award.

In September, four members of our Board (me, Kelly Andringa, Matt Morgan, and Lauren Gee), joined members from other regions, and the National Board to take part in a two-day summit to “reimagine” NCURA. I was awed at the creativity, honest sharing, and future forward thinking.

Check out the article in this issue for more.

At the AM67 business meeting I challenged members to get involved with NCURA. The Reimagining Community Summit sought ideas about new ways to engage members. Ideas shared will take time to implement. This made me wonder, what can we do now? One way was to add an event and calendar page to the region’s website. Liz Grinstead (Communication Committee Co-Chair) created an awesome page. A LinkedIn page was created, www.linkedin.com/company/ncura-region-iv, to compliment the Region’s Facebook, Instagram, and NCURA Collaborate Community. By the way, only 192 of over 1600 regional members use it. I challenge you all to make that number grow. Here’s the tip sheet to how to join.

Drum roll please; our April 19-22, 2026, Spring Meeting theme is A Confluence of Ideas! Join us in St. Louis, MO. Sandy Fowler is the 2025 Chair of Region IV and serves as the Assistant Dean for Research for the College of Agricultural and Life Sciences at the University of Wisconsin – Madison.

She can be reached at sandy.fowler@wisc.edu.

Rebecca Wessinger is Region III Secretary and serves as the Director of Research Operations, for the University of South Carolina, Molinaroli College of Engineering and Computing. She can be reached at RRWessinger@sc.edu.

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Regional Corner continued REGION V Southwestern

REGION VI Western

www.ncuraregionv.com

www.ncuraregionvi.org

www.facebook.com/ncuraregionv

www.facebook.com/groups/729496637179768

Howdy, Region V! Sessions have been scheduled, food ordered, contracts signed, and we loved seeing y’all at the Region V Fall 2025 Meeting at the Embassy Suites

by Hilton San Marcos Hotel Conference Center!

Thanks to YOU - our incredible Region V members - this year’s fall meeting was more than just another professional development conference.

It was a chance to engage in meaningful connection, constructive collaboration, and leadership opportunities.

I’d like to take the occasion to highlight some champions of the Fall Meeting, unsung heroes who have done an incredible job supporting background items that ensure the meeting proceeds without a hitch: • Mona Bisase, Meeting App guru, ABC Chair, and At-Large Member • Nicole Babilya, Sponsorship Committee and At-Large Member • Greg Chu, Dietary Restrictions contact and At-Large Member • Patricia Foster, Accessibility Needs contact and At-Large Member • Maegan McKerrow, Volunteer Coordinator and Volunteer Extraordinaire Thank you so much to these incredible volunteers. You can learn more about all of the Region V Fall 2025 Meeting details on the NCURA Region V Website.

I’d also like to thank our tireless Travel Awards Committee for selecting our Annual Meeting and Region V Fall 2025 Meeting travel award winners.

Thank you Sheleza Mohamed (American Heart Association), Susan Hurley (Sam Houston State University), Robyn Cooper (American Heart Association), and Alexa Hites (Sam Houston State University).

You’ve done a tremendous job selecting amazing awardees.

And don’t forget—our Region V programming continues year-round!

Join us for our Virtual Lunch & Learns every second Wednesday at noon CT. We’ve got some terrific programming coming up in November with Scott Davis from University of Oklahoma Health Science Center presenting on “The Research Administrator’s Guide to Work-Life Balance” and in December Sheleza Mohamed from American Heart Association presenting on ”Audits 101: From Panic to Preparation.” These sessions are always free to sign up and provide a bite size, accessible form of continuing professional development.

Be sure to stay connected with our Region V community through the NCURA Collaborate platform and on LinkedIn. Let’s continue to recognize The Power of Y’all!

Liz Kogan, CRA, is the 2025 Region V Chair and serves as the Director of Research Administration, College of Education, at the University of Texas at Austin. Liz can be reached at liz.kogan@austin.utexas.edu.

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Fall is officially here—how has 2025 flown by so quickly? As we reflect on the past year, it’s clear that we’ve achieved so much together, even amidst ongoing challenges and a constantly evolving research landscape.

It’s exciting to look ahead to what 2026 will bring for both our region and the broader NCURA community.

Our Education and Professional Development Committee continues to shine, offering valuable programming through the ever-popular lunchtime series. Be sure to check our website regularly for the latest updates and upcoming sessions!

At AM67, we had the honor of celebrating Rosemary Madnick from The Lundquist Institute, who was named a Distinguished Educator Award recipient. Additionally, Shu Lin from the University of California, San Diego, was awarded the National Conference Travel Award representing Region VI. Congratulations to both!

We’re thrilled that our Fall Regional Meeting in Costa Mesa, CA is finally here! For those attending, we look forward to connecting with you. The Program Committee has curated a rich and diverse agenda, and we’re especially excited to welcome our keynote speaker, Dr. Dequina Nicholas, Assistant Professor at the University of California, Irvine. Her talk, “From Pieces to Masterpiece: Reconstructing Research Administration for the Current Challenges,” promises to be both inspiring and thought-provoking.

A big congratulations to our Regional Travel Award recipients: • Judy Guo, University of Alaska Fairbanks • Sarah Sanders, Cal Poly Humboldt • Emily Johnson, University of Washington Finally, it is with heavy hearts that we share the passing of Sinnamon Tierney. A deeply committed member of NCURA, Sinnamon dedicated her career to advancing the research community. She served as Chair of Region VI in 2017 and was a mentor and friend to many. I still remember meeting her at my very first NCURA event—her warmth and welcoming spirit made me feel instantly at home. Sinnamon’s legacy will live on in the countless lives she touched. We invite you to continue sharing your memories and honoring her by carrying forward the values she exemplified.

Matt Michener is the Region VI Chair and serves as Associate Director of the Office of Research Support and Operations at Washington State University. He can be reached at mich9311@hotmail.com.

REGION VII Rocky Mountain

REGION VIII International

www.ncuraregionvii.org

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Greetings, Jackalopes!

By the time you read this, we’ll all likely be arriving at the beautiful Westin South Coast Plaza for the 2025 Region VI and VII meeting in Costa Mesa, CA! The RM25 Program Committee has curated a robust program that is sure to enable attendees to return to their institutions better equipped to navigate our evolving landscape. Let’s “Build the Future of Research Administration” together!

In other news, we are excited to announce our newly elected slate of regional officers for 2026: • Chair-Elect: Betty Rasmussen, University of Colorado, Boulder • Treasurer-Elect: Eric Everett, University of Idaho • Secretary: Kathryn O’Hayre, Colorado State University • Member-At-Large: Alex Hartvigsen, Utah Valley University Congratulations to all and thank you for volunteering to serve!

Our mentoring program will be accepting applications for this year’s cohort soon. LEAD Me is a one-year collaborative program between Region VI and Region VII designed to cultivate and expand the pool of new and emerging leaders within both the research administration profession and NCURA at the regional and national levels. Now entering its 16th year, the program provides selected participants (mentees) with focused educational and professional development experiences to prepare them for leadership roles at their home institutions and within NCURA. Throughout the year, mentees work on a Personal Best Leadership Project, which they present at the regional meeting. The program is guided by dedicated mentors who share their expertise and help shape the next generation of leaders.

We invite your participation as a LEAD Me Program Mentee or Mentor in the 2026 cohort. Application criteria and format can be found at: www.ncuraregionvi.org/leadmeprogram under Forms and Resources.

Join us in Costa Mesa as we celebrate the LEAD Me Class of 2025!

Stay connected to the Region: Join our Facebook page and the Region VII community on NCURA Collaborate or visit our regional website: www.ncuraregionvii.org.

Want to volunteer? Contact Volunteer Coordinator Betty Rasmussen (betty.rasmussen@colorado.edu). Betty will be able to advise on the various opportunities available.

As the seasons begin to change, I would like to take a moment to reflect on the 67th Annual Meeting held in August in Washington, D.C. For those who attended, I hope you returned home with valuable insights, best practices, fresh ideas, new connections, and perhaps even a bit of renewed energy, despite the jet lag! We were proud to welcome 54 international attendees, both familiar and new faces. Many of us kicked off the weekend by attending the AI Symposium on Saturday, followed by a variety of pre-conference workshops on Sunday. The meeting officially began on Monday, which also marked our regional business meeting. During the meeting, we shared updates on our membership (currently at 226), introduced our officers, and discussed past and upcoming initiatives at both the regional and national levels. Monday evening brought us together for a regional dinner at Lauriol Plaza, where we enjoyed delicious Mexican cuisine. Later, we gathered at the NetZone, co-organized with Region V, just like last year. A heartfelt thank you to our wonderful colleagues in Region V for their continued collaboration and support of our region. On Tuesday night, we hosted our very own Region VIII limbo game. Special thanks to Jonathan Gray and Anna Pavlitski from LEES for volunteering and making it a fun event!

Volunteering comes in many forms, whether it's lending a hand at the registration desk, helping organize an event, or stepping up to lead the region. I’m thrilled to share that we have multiple candidates for the 2026 open positions: Chair-Elect, Secretary, Treasurer-Elect, and Region VIII Board Member. Stepping forward takes courage and commitment, and I sincerely thank each candidate for their willingness to serve. The elected candidates will be announced in the next edition of the Magazine.

Region VIII participated in the Leadership Summit held in Washington, D.C., on September 9–10, 2025. The purpose of the meeting was to collaboratively envision the future of NCURA to serve you the best we can. One key takeaway was clear: the international dimension of research administration remains a central and enduring focus. Thank you, Ellen Thompson, Joey Gaynor, Patricia Gigliuto, and Alan Yee, for representing Region VIII. Looking ahead, we plan to host an online discussion on the new NIH model for foreign subawards in October. Stay tuned for more info on our next educational Tine Heylen is the 2025 Region VIII Chair and serves as Senior Advisor, European and International Projects at KU Leuven. She can be reached at tine.heylen@kuleuven.be.

Brigette Pfister is the 2025 Region VII Chair and currently serves as the Financial Compliance Manager in the Office of Sponsored Programs at Colorado State University.

She can be reached at Brigette.Pfister@Colostate.edu.

NCURA Magazine

I Oct/Nov 2025

71

UF HEALTH: Timing, Consistency of Activity Linked to Better Fiitness

S

ome people spring into action at dawn, while others prefer a slower start to their day. Whether you rise with a grin or a groan, scientists say your internal clock—known as the circadian rhythm —might influence that behavior and much more.

These biological clocks regulate not only sleep-wake cycles but also a wide range of daily physiological and metabolic functions. A growing body of research suggests that circadian rhythms are fundamental contributors to health and resilience.

Now, a new University of Florida Health study, funded by the National Institute on Aging, or NIA, shows that the timing and consistency of your daily activity might be associated with improved cardiorespiratory fitness and walking efficiency—two key indicators of healthy aging. The NIA is a part of the National Institutes of Health.

The study found that older adults with earlier and more consistent daily activity patterns had better heart and lung fitness compared with those with later or more irregular schedules.

“While we’ve long known that being active supports healthy aging, this study reveals that when you’re active may also matter,” said Karyn Esser, Ph.D., senior author and professor and chair of the UF College of Medicine’s Department of Physiology and Aging. “The circadian mechanisms that generate daily rhythms in our system are important for our well-being.”

Published in April in Medicine & Science in Sports and Exercise, the study does not prove causation, Esser emphasized. While the results are promising, more research is needed to determine whether adjusting activity timing can lead to health improvements and whether these findings extend to younger populations, she said.

Researchers enrolled about 800 independent older adults in the study with an average age of 76. Participants wore wrist devices that continuously monitored activity for seven days. They then underwent cardiopulmonary exercise testing to obtain a comprehensive assessment of their heart and lung health.

Key findings include: • Higher-amplitude activity and rest cycles—this reflects greater activity during the active part of the day relative to the rest period—were associated with better cardiorespiratory fitness and walking efficiency.

• Earlier daily peak activity—defined as the time of day when individuals were most active—was linked to improved cardiorespiratory fitness and walking efficiency.

• Greater consistency in daily activity patterns, such as having the peak activity occur at the same time each day, was also associated with better outcomes.

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Activity includes all daily movement—walking, gardening, cleaning or shopping—not just formal exercise.

The body’s internal clock helps align physiological functions, such as hormone release, blood pressure and core temperature, to the natural cycle of day and night. Disruptions to this rhythm, such as those experienced during jet lag or shift work, can have negative consequences for sleep, mood and physical functioning.

Esser emphasized that although her study suggests a link between earlier, consistent activity and better health, it doesn’t prove that following such a schedule will improve health and fitness.

Still, the findings open intriguing possibilities for personalized medicine, she said. Because circadian rhythms vary from person to person, future health strategies could include tailoring activity and treatment schedules to an individual’s internal clock.

“Each of us has a chronotype—a biological tendency to be more alert in the morning or evening—and that variation may play a significant role in our health,” Esser said. “We’re moving toward a future where understanding and respecting our individual rhythms can help guide medical care and daily living.”

Scientists use an easy shorthand to describe whether someone is a morning or an evening person. An early riser is a “lark,” the name taken from the bird whose song is often heard around dawn. The late risers are “owls,” named, of course, after the bird that hunts at night and sleeps in the day.

In case anyone is wondering, Esser is a lark.

“The morning chronotype, that’s me,” she said. Lest anyone think all scientists share this trait, Esser notes, “I have a number of colleagues who are truly owls and don’t like mornings at all.” N

For the complete article visit

https://ufhealth.org/news/2025/uf-health-timing-consistency-ofactivity-linked-to-better-fitness#for-the-media

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NCURA Calendar of Events

TRAVELING WORKSHOPS • Export Controls & Research Security November 17-18, 2025 New Orleans, LA • Financial Research Administration November 19-21, 2025 New Orleans, LA • Level I: Fundamentals of Sponsored Projects Administration November 19-21, 2025 New Orleans, LA • Level II: Sponsored Projects Administration-Critical Issues in Research Administration November 19-21, 2025 New Orleans, LA

VIRTUAL WORKSHOPS • Level I: Fundamentals of Sponsored Project Administration Part I: Pre-Award November 12-13, 2025

ONLINE TUTORIALS—10 week programs • A Primer on Clinical Trials • A Primer on Federal Contracting • A Primer on Intellectual Property in Research Agreements • A Primer on Subawards NATIONAL CONFERENCES • Financial Research Administration Conference March 19-20, 2026 San Juan, Puerto Rico • 4th AI Symposium March 21, 2026 San Juan, Puerto Rico • Pre-Award Research Administration Conference March 22-23, 2026 San Juan, Puerto Rico • Annual Meeting August 1-4, 2026 New York City, NY

• Contract Negotiation & Administration Workshop December 1-4, 2025

REGIONAL MEETINGS • Region VI (Western)/Region VII (Rocky Mountain) November 2-5, 2025 Costa Mesa, CA

For further details and updates visit our events calendar at www.ncura.edu.