UG, F&A, and Other Cost Issues: October 2026 Navigating the Storm

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Discussion Prompts:

Uniform Grants Regulations (UGR)
•How are institutions approaching strategic planning around the proposed UGR? Have you begun institutional conversations about what implementation could mean for your research enterprise, and which offices or leaders are involved? If UGR moves forward, what decisions, operational changes, or contingencies are you preparing for? Where would additional guidance or coordinated advocacy from COGR be most valuable?

•As institutions consider the possibility that certain research-related costs, such as publication expenses, may no longer be recoverable through federal awards, are you exploring alternative approaches to funding these activities? What funding models, allocation strategies, or institutional policies are being considered, and what financial or operational challenges are emerging?

F&A & Other Cost Issues
•Is your institution preparing for changes in F&A reimbursement and/or overall funding reductions?

•Financial impact mitigation

•Administrative changes?

•Which F&A costs traditionally reimbursed through application of the IDC rate would be most practical to directly charge to sponsored awards?

• If your institution’s Indirect Cost Rate or Fringe Benefit rate has expired or were to expire:

•If expired or soon expiring, what has been your experience with your Cognizant Agency for Cost (CAS or ONR) If expired, how long ago?

•What challenges with sponsors have you faced?

•Have you received requests for additional data or justification?

•Would you consider including your calculated and submitted fringe benefit rates that have not yet been approved

:•In proposal budgets if calculated is lower? If calculated is higher?

•In charges to awards if calculated is lower? If calculated is higher?

Issues with drawdowns and invoices

•Have you changed your process for PMS draws since HHS announced a new requirement effective 10/1/2026 to explain “how the cost or activity supports the objectives and goals of the award”?

•Have you received any requests for “clarification” from PMS or the funding agency, or any other delay in payment?

•Was additional project-specific justification required to resolve and receive payment?

•Are there other continuing issues with Defend the Spend (DTS) and other requirements for expenditure reimbursement justifications. See Points to Consider for Reimbursement of Expenses Under Active Grants.

•Other federal reimbursement issues? 

•Given current conditions, is your institution taking action to mitigate financial risks related to federal awards?

•For example, are you limiting allowable spending while waiting for continuations that do not arrive prior to the end of the current funded budget period?

•Have you experienced receipt of termination after the end date of the last funding increment? •Are you considering closer monitoring and/or assigning financial risk to managing units (e.g. departments)?

•Other?