Changes to the NIH grant system - Jan 2025 to Aug 2026

I compiled this information for a webinar last month, and I thought it might be of interest to my readers here on Substack, so here you go!

This slide is my "greatest hits" list of changes at NIH since January 20, 2025. It is by no means a complete list.

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The point of this slide is to show the sheer volume of policy changes. In 22 years at NIH, I never saw anything close to this quantity, scale, and scope of change in such a short period of time. Each card in the above slide is one dated entry from a list I tabulated (you will find the full annotated list at the bottom of this article).

The chaos started with EO 14168 and the OMB Memo and cascaded from there. Dashed cards became known through internal memos or press reporting rather than formal notices, such as the NOFO forecast requirement, revealed to staff in an internal memo; the priority-alignment text scanning of grants, reported by Science in December 2025; the foreign co-author directives; and the narrowed scope excluding policy research, which Director Bhattacharya began describing publicly in June 2026.

Gray cards are policies struck down, like the indirect cost cap, or the 2025 grant terminations that went through litigation and Supreme Court action.

Orange cards are pending proposals.

One theme in this timeline is the presence of OMB right from the jump. That first memo was the basis for thousands of grant cancellations challenged in court. When courts shut that down, OMB tried again, first with EO 14322 and then with a proposed rule. Through fierce activism, the OMB was rule blocked through December 11, 2026, by a continuing resolution. But that fight is not over. Russell Vought is persistent, and I expect he will try again.

This slide below rearranges the same tiles by the part of the grant process they affect. No part of the process has been spared.

List of Changes at NIH

1. January 20, 2025, hours after taking office, President Trump signed Executive Order 14168, “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.”

2. January 27, 2025 OMB Memorandum M-25-13 - Financial assistance should be dedicated to advancing Administration priorities, focusing taxpayer dollars to advance a stronger and safer America, eliminating the financial burden of inflation for citizens, unleashing American energy and manufacturing, ending “wokeness” and the weaponization of government, promoting efficiency in government, and Making America Healthy Again. The use of Federal resources to advance Marxist equity, transgenderism, and green new deal social engineering policies is a waste of taxpayer dollars that does not improve the day-to-day lives of those we serve.

3. February 7, 2025, NIH announced a 15% cap on indirect costs in NOT-OD-25-068. Universities sued immediately. Courts struck it down as illegal. The Trump administration appealed. Lost again. The deadline to petition the Supreme Court passed in April 2026 without the administration filing (Molteni, 2026). The indirect cost cap is dead (for now).

4. February 13, 2025, President Trump signed Executive Order 14212 titled “Establishing the President’s Make America Healthy Again Commission. It created a cabinet-level advisory commission on chronic disease, with an initial focus on children.

5. Late February 2025 - The first wave of explicit NIH grant terminations hit, heavily targeting programs associated with LGBTQ+ issues, gender identity, and diversity, equity, and inclusion (DEI).

6. March 2025 - Broader NIH grant cancellations scaled up, including high-profile institutional cuts (such as $250 million in canceled grants at Columbia University).

7. February–August 2025: A cumulative total of over 2,200 active NIH grants were terminated or frozen during this primary window before subsequent legal challenges and Supreme Court action shifted the status of the cuts. Although cuts occurred across all regions and institution types, statistical patterns show that early-career investigators—assistant professors, postdoctoral scholars, trainees, and graduate students—were disproportionately affected, as were women (source: https://pmc.ncbi.nlm.nih.gov/articles/PMC13037894/).

8. March 6, 2025 NIH centralizes peer review – Eliminated IC specific review panels. CSR typically managed the peer review process for more than 78% of NIH grants, while the remaining 22% were reviewed in study sections within 23 ICs. The consolidation eliminated the IC-based study sections.

9. April 1, 2025 NIH Internal memo announced a new HHS Forecast Requirement for all Notices of Funding Opportunities (NOFOs). This policy was never formally announced to the public. Internally, the policy ordered NIH to comply with a new HHS/ASFR policy to no longer use the NIH Guide and instead use grants.gov and enter all new NIH NOFOs as a “forecast” first with a minimum 6 months lead time for political review. HHS would use the Forecast data from Grants.gov to compile a report for the Immediate Office of the Secretary and Office of Management and Budget (OMB) to review and identify NOFOs for additional Departmental and/or OMB clearance. NOFOs identified by OMB will have a separate clearance process. The earliest public notice about any changes to NIH NOFOs were not made public until August 14, 2025 with NOT-OD-25-143 NIH Will Stop Posting Notices of Funding Opportunities in the NIH Guide for Grants and Contracts in FY2026; however, the issue of forecasts was not mentioned.

10. May 1, 2025 NIH issued Updated NIH Policy on Foreign Subawards NOT-OD-25-104 - NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity. Additionally, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project. If a project is no longer viable without the foreign subaward, NIH will work with the recipient to negotiate a bilateral termination of the project.

11. May 23, 2025 Executive Order 14303 Restoring Gold Standard Science sets a government-wide standard for how federal agencies produce, use, and communicate scientific information, and it puts the process for judging whether agency science meets that standard under the control of political appointees.

12. July 17, 2025, NIH issued Notice NOT-OD-25-131 revising its policy on inclusion of women and minorities in clinical research. The stated purpose: “to align with Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.” Revisions are focused on promulgating the use of the term “sex” instead of “sex/gender” which are no longer allowed.

13. August 7, 2025, the President signed Executive Order 14332 “Improving Oversight of Federal Grantmaking.” This order established additional requirements for all federal discretionary grants.

14. August 14, 2025 Announcement NOT-OD-25-143 NIH Will Stop Posting Notices of Funding Opportunities in the NIH Guide for Grants and Contracts in FY2026. This Notice informs the extramural community that, beginning in fiscal year 2026, NIH will no longer post NOFOs in the NIH Guide. Grants.gov will serve as NIH’s single official source for grant and cooperative agreement funding opportunities. The NIH Guide will continue to be used for policy and informational notices.

15. August 15, 2025, eight days after the “Improving Oversight of Federal Grantmaking” executive order, NIH Director Jay Bhattacharya issued a statement titled “Advancing NIH’s Mission Through a Unified Strategy.” NIH Director wrote this strategy in response to the President’s direction to guide efforts to better combat chronic disease in America and improve the health of all Americans through “gold-standard science.”

16. August 25, 2025 statement from the NIH Director titled “Maximizing and Safeguarding NIH’s Investment in Foreign Collaborations.” The statement emphasizes that “NIH is not a foreign aid organization” and that international research must “deliver both scientific and taxpayer value.”

17. September 12, 2025 – NIH announced New Application Structure for NIH-Funded International Collaborations in NOT-OD-25-155 - For grants requesting NIH funding for one or more foreign components, NIH will require that competing applications submit applications to a Notice of Funding Opportunity (NOFO) that supports the new PF5 Activity Code for grants, new UF5 Activity Code for cooperative agreements, or another complex mechanism activity code that supports the International Project component type.

18. November 18, 2025, NIH issued Notice NOT-OD-26-009 implementing the termination provisions required by the August 7 executive order. Effective October 1, 2025 grants may be terminated if the agency determines that the award no longer effectuates the program goals or agency priorities.

19. November 21, 2025, NIH announced a fundamental change to how grants are funded. The agency eliminated reliance on paylines, which were objective score cutoffs that some ICs used to determine which applications received funding based primarily on peer review scores. This new policy is described as Implementing a Unified NIH Funding Strategy to Guide Consistent and Clearer Award Decisions.

20. December 03, 2025 NIH Issued NOT-OD-26-019 - Updated Application Policies: NIH Administrative Burden Reduction Effort – Removal of Requirements for Letters of Intent and Unsolicited Applications Requesting $500,000 or More in Direct Costs.

21. December 12, 2025 NIH Reviewing Grants for Priority Alignment - ICOs must first conduct an evaluation using a computational text analysis tool to scan for terms that may potentially be associated with misalignment with the agency’s priorities.

22. January 20, 2026 – NIH posted PA-26-002 NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional) to Grants.gov - This opportunity specifically implements an award structure of prime domestic awards with independent foreign awards that are linked to the prime. This structure provides NIH with oversight capacity for international collaborations, and allows NIH to track international funding, as identified in NOT-OD-25-104. The first receipt due date was May 25, 2026, with earliest start date of April 2027.

23. March 23, 2026 “NIH’s Path to a Simpler Funding Opportunity Landscape” states that NIH is streamlining the landscape for Notices of Funding Opportunities (NOFOs, or funding opportunities) and the application process. NIH is placing greater emphasis on investigator-initiated science rather than asking researchers to align their work with highly specific funding opportunities. Also, NIH intends to cut the number of Notices of Funding Opportunity by 50%.

24. April 20, 2026 NOT-OD-26-074 Notice of Information: Policy Changes to SBIR and STTR Foreign Disclosure and Risk Management. The purpose of this notice is to inform HHS Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) applicants of recent policy changes to Foreign Disclosure and Risk Management.

25. May 27, 2026 NIH felt compelled to issue NOT-OD-26-084 Reminder – Definition of Foreign Components after news reports raised questions. NIH has recently received questions regarding whether there has been a change in the definition of a foreign component, and whether a foreign co-author on a publication that cites an NIH grant award automatically results in a foreign component.

26. May 29, 2026 Proposed OMB Rule titled “Regulation for Federal Financial Assistance” announced to exert political control over the grant making process with a projected October 1, 2026. With pressure from the public, Congress put this rule on hold until December 11, 2026.

27. June 8, 2026 NIH issues NOT-OD-26-086 Request for Information: Proposal to Cap the Number of Simultaneous Research Project Grants per Principal Investigator to Support More Researchers and Maximize Scientific Productivity and Innovation. Comment deadline August 03, 2026.

28. August 11, 2026 NIH limits funding for research on the health effects of public policy. US biomedical agency no longer considers policymakers ‘mission relevant’, leaving dozens of grants in limbo. “Policymakers are not considered a stakeholder group within the scope of NIH’s mission,” the internal documents say. “NIH-funded research must empower decision-making by NIH mission-relevant stakeholder groups”, which the documents list as including patients, health-care workers, hospitals and scientists. The change has not yet been formally announced, and there is a lack of clarity inside the agency about how it will be implemented, say NIH officials, who requested anonymity because of the risk of retaliation.

29. August 12, 2026 NIH announced changes to K awards with NOT-OD-26-098 which includes the prohibition of clinical trials in K awards.

30. August 12, 2026 NIH issues NOT-OD-26-095 Request for Information (RFI): Input on Potential NIH Funding Approaches to Support the Development of Future Clinical Trial Investigators.” Deadline September 30, 2026.

31. August 14, 2026 NIH issues NOT-OD-26-088 Request for Information (RFI) on Proposed Changes to Reporting Outcomes from NIH Peer Review - describes intention to no longer report peer review impact scores to PIs, institutions, or to NIH Program staff. Deadline October 13, 2026.

This article is part of my ongoing Substack series documenting and analyzing recent changes to the NIH extramural funding system. My perspective is shaped by 22 years of public service as an NIH Program Official (2003–2025). Throughout my career as a strategic research and innovation leader, I focused on building large-scale scientific programs at the intersection of emerging technology, ethics, and public impact.

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