DrWebNew NIH Announcement Just Made It Easier To Terminate Grant Funding – Forbes.com
New NIH Announcement Just Made It Easier To Terminate Grant Funding
ByBruce Y. Lee, Senior Contributor. Bruce Y. Lee, M.D., MBA, covers health, medicine, wellness and science.
Nov 23, 2025, 07:31am EST, Nov 23, 2025, 09:56pm EST
Editor’s Note: Featured image at top is from WP AI.
So, you’ve put your blood, sweat and tears into a proposal to do some kind of prevent-or-treat-disease and find-ways-to-help-humans project. And somehow against worsening now well-below-10% odds you’ve managed to get your project funded by the National Institutes of Health. What would you most like to hear? How about news that the NIH under the Trump administration has just made it even easier to terminate your research grant at any time?
NIH Issued Updated Terms And Conditions Of Awards
Yep, on November 18, 2025, the NIH issued an “Updated Terms and Conditions of Awards.” These updated terms did include fairly standard language like “By accepting an NIH award, the recipient agrees that continued funding for the award is contingent upon the availability of appropriated funds, recipient satisfactory performance, compliance with the Terms and Conditions of the award.” It’s always been the case that grant funding can be withdrawn if fraud or abuse occur or the recipient isn’t really doing any acceptable scientific work with the funding.
However, there also were two kickers, as in things that could end up kicking you in the behind if you don’t notice it. It’s the combination of two sentences. One reads, “All new NIH Notices of Award will include the following terms.” The second reads, “[The award] may also otherwise be terminated, to the extent authorized by law, if the agency determines that the award no longer effectuates the program goals or agency priorities, in line with 2 CFR 200.340(a)(4).” These may seem like small changes. But sometimes small things can end up causing big issues.
You may have noticed the word “effectuate” at the center of that second statement and be wondering what the eff that means. Well, Dictionary.com does define “effectuate” as “to bring about,” which doesn’t quite effectuate clarity. Effectuate isn’t a word that you necessarily see or use everyday. Like you probably don’t typically tell someone taking your order at a restaurant, “Could you please effectuate for me a hamburger, fries and a fruitcake?” And if you were to tell your significant other, “You are no longer effectuating my priorities,” that might effectuate a middle finger to you.
The other vague thing in the statement is the whole “program goals or agency priorities” thing. How exactly will these goals and priorities be defined? Will they be clearly listed somewhere? How might they change after you get the award? Does this feel a bit like, “We’ll keep funding you as long as we feel like doing so?” I’m reaching out to my contacts at the U.S. Department of Health and Human Services and the NIH to bring about—or, er, effectuate—more clarity on the situation.
Now the combination of the two statements is notable in that based on the 2 C.F.R. § 200.340, in the words on the Holland and Knight law firm website “the government is unable to unilaterally terminate an award for this purpose for grants awarded after Oct. 1, 2024, unless the parties specifically included this as an express termination provision in the grant award itself.” So, now this new NIH announcement is indicating that the whole ”effectuating” thing is going to be baked directly into each actual grant award’s Terms and Conditions.
The New Terms And Conditions May Make Make It Easier For The NIH To Terminate Grants
One big concern is that such vagueness right in the award’s Terms and Conditions might give NIH administrators and whatever Presidential administration happens to be overseeing NIH at the time even more leeway to justify yanking your federal funding at any time. The Trump administration has been doing a lot of the premature termination thing since January 2025, as I’ve described in Forbes. This has included terminating or partially terminating grants that have been producing what the investigators had originally indicated they would produce. The justification often used for such terminations has been that the funded projects no longer matched the priorities of the NIH as guided by the Executive Orders signed by President Donald Trump earlier this year.
Continue/Read Original Article Here: New NIH Announcement Just Made It Easier To Terminate Grant Funding
#BruceYLee #Effectuate #Forbes #ForbesCom #Heathcare #HelpHumans #NationalInstitutesOfHealth #NIH #NIHGrants #November182025 #TerminateGrants #TrumpAdministration
Marco Ciappelli🎙️✨
