Updates on Federal Actions Related to Research
The Office of the Vice President for Research and Innovation (OVPRI) continues to monitor federal executive orders and other federal actions related to research. Those updates are posted on a separate page. Click the resources for researchers link below.
This page is updated monthly to include critical updates associated with federal funding. Updates will include a note indicating when they were added and will be removed after six months.
Institutional Updates
New Authorized Organization Representative on Proposals as of August 10, 2026
Proposals with due dates on or after August 10, 2026, must list our new Vice President for Research and Innovation, Bethany D. Jenkins, Ph.D., on the Authorized Organization Representative (AOR) line of each application. All other address information will remain the same. (posted August 2026)
IRB Forms Are Getting a Refresh for Accessibility
As part of our ongoing commitment to inclusivity and user experience, Research Compliance Services (RCS) is overhauling our documentation to make forms and guidance documents more accessible. During the next couple of months, all forms and guidance will be updated. See the Human Subjects Applications, Forms and Guidance webpage for the most recent versions.
- Improved accessibility: The new forms are optimized for screen readers and utilize a clean layout to ensure a smoother experience for everyone.
Similar content, new look: While the page counts are longer due to formatting changes, the actual content remains largely the same and has even been streamlined in some cases. (posted August 2026)
Expedited Research Contracts Review Request Form now available
If an agreement for a sponsored project requires expedited review, please submit an Expedited Review Request Form available on the SPS Forms webpage. Expedited review requests may be approved if:
- The agreement start date has already passed.
- The agreement end date has already expired.
- An invoice is due while the agreement is still under review.
- An amendment is received before the base agreement has been finalized.
Please note that expedited reviews are subject to approval. Review timelines may still be affected by factors such as negotiations with the sponsor or incomplete documentation. (posted July 2026)
Revised UO Policy on Allegations of Research Misconduct/Research Integrity
The University of Oregon has revised Policy II.06.02, Allegations of Research Misconduct, to align with updated federal regulations. The revised policy has been approved by the UO Senate and is undergoing review by the federal Office of Research Integrity (ORI) to ensure compliance with current requirements.As recipients of federal research funding, institutions must maintain a compliant research misconduct policy, adhere to federal regulations, and meet annual reporting requirements to maintain their assurance with the U.S. Department of Health and Human Services.
For additional information, please visit the Allegations of Research Misconduct webpage. (posted July 2026)
Dropbox updates July 1
Starting July 1, 2026, UO Dropbox users will receive a baseline amount of 2 TB of individual storage for free, which can be increased for a yearly fee through team storage. That 2 TB baseline accommodates the vast majority of users—so nearly everyone can simply keep using Dropbox as they do today. Learn more about the upcoming Dropbox updates.
These updates were announced last spring as part of the UO’s digital storage transformation. Explore the UO’s evolving storage options with the Data Storage Finder. (posted June 2026)
RAP Quick Tip and Reminder: Closing Human Subjects Research
For studies previously reviewed and approved by the UO’s Institutional Review Board (IRB) or determined exempt, the study must be closed once human subject research activities conclude and prior to the study expiration date. It is the principal investigator’s (PI) responsibility to close the study (or the faculty advisor if the PI is a student and has left the university). The Research Administration Portal (RAP) sends automated reminders until your study expires. Once it has lapsed, those reminders are no longer sent.
Please take a few minutes to review the studies where you are listed as a team member. This will allow you to review and assess whether any action is required for studies where you are listed as the PI or faculty advisor. These studies can be found by clicking on the “IRB” tab at the top of the RAP webpage, then by clicking on the “Active” sub tab. (posted June 2026)
Guidance for Researchers Returning from Abroad with UO-Owned Laptops
Some institutions have reported that U.S. Customs and Border Protection (CBP) agents have questioned returning researchers about their laptops and research data after international travel.
Please remember to log all travel into Concur. Researchers traveling to higher-risk destinations will be issued a loaner laptop and provided guidance on how to respond to CBP questions about electronic devices.
Key information
- You are legally required to unlock laptops and other electronic devices if requested by a federal agent.
- If a federal agent asks about your laptop AND you are using a loaner laptop, you may explain that:
- The University of Oregon provided the laptop for your international travel.
- No data was stored on the device at the time of issuance.
- The laptop contains standard antivirus software and Microsoft 365.
- The laptop will be returned to UO Information Security User Support Services to review and wipe upon your return.
If CBP asks questions about your device or research data, please notify exportcontrols@uoregon.edu and gcounsel@uoregon.edu. (posted May 2026)
Revised UO Policy on Allegations of Research Misconduct/Research Integrity
Due to changes in federal regulations, the UO Policy II.06.02, Allegations of Research Misconduct, was revised. Now approved by the UO Senate, our revised institutional policy will next receive review by the federal Office of Research Integrity, which oversees the Public Health Service regulations under the U.S. Department of Health and Human Services (HHS), to ensure compliance with the revised regulations. Institutions that receive federal funding for research must have a compliant, written research misconduct policy and follow federal research misconduct regulations, as well as report annually to renew their assurance with HHS. Please visit the Allegations of Research Misconduct webpage for more information. (posted May 2026)
The UO’s Approach to “Gold Standard Science”
Last year, the White House released an executive order, “Restoring Gold Standard Science,” and the Office of Science and Technology Policy (OSTP) issued guidance outlining the nine tenets identified as Gold Standard Science. OVPRI has long been a champion of the key indicators identified in the Gold Standard documents, including activities to support scientific inquiry, reproducibility, transparency, interdisciplinary collaborations, and mitigate conflicts of interest. OVPRI now shares “Gold Standard Science at the University of Oregon” expressing its ongoing commitment to these tenets and exemplifying its further integration into research excellence at the UO. (posted May 2026)
Subawardees Using UO’s Conflict of Interest in Research Policy Must Submit Disclosure Prior to Proposal Submission
Effective April 1, 2025, subawardees who do not have their own enforced conflict of interest policy compliant with federal regulations and UO policy, and who thus need to use the UO’s policy, will need to submit a conflict-of-interest disclosure prior to proposal submission. This process adjustment more closely aligns with federal regulations. All other requirements will remain the same.
Sponsored Projects Services (SPS) Pre-Award SPAs will indicate in the collaborator tab of the Electronic Proposal Clearance System (EPCS) when a subawardee will need to use the UO’s policy, and the Conflict of Interest Office will follow up with the subawardee. Each subawardee researcher responsible for the design, conduct, and reporting of the sponsored research must submit a disclosure. Subawardees will continue to submit disclosures via Qualtrics.
All other components of the process will remain the same and researchers can learn more about the process on our website. (posted March 2026)
Institutional Review Board (IRB) Revised Forms
Research Compliance Services (RCS) recently overhauled several of the forms commonly used by researchers for IRB review. The changes were aimed at reducing redundancy, adding/revising questions to better capture information needed, and providing resources for researchers. Our goal is that these updated forms will facilitate and streamline the review process for researchers who use them.
- Appendix B (Investigational Devices)
- Completed when researchers are studying a medical device for safety or effectiveness
- Exempt Determination Form (a.k.a. Exempt Application)
- Completed when applying for exempt review (or modifying an existing exempt study)
- Initial Review Application Form
- Completed when applying for initial non-exempt review (expedited or full board)
Researchers preparing new IRB submissions should use the updated versions of the forms. The links on the Applications, Forms, and Guidance website and the Research Administration Portal (RAP) have been updated. We always recommend that researchers pull documents from the Applications, Forms, and Guidance website to ensure they have the most recent versions.
In most cases, researchers working on previously approved research will be able to continue using the previously approved versions of the above forms without making changes. However, when modifying topics related to the updated aspects of the above forms (e.g., genetic testing/information, biospecimens, international research including bulk research, indigenous research, adding/changing investigational devices), researchers are asked to use the updated versions of the forms. (posted March 2026)
LCNI Screening Questionnaire Update
The Lewis Center for Neuroimaging (LCNI) provides resources for UO researchers conducting MRIs and the surrounding community. When participants come to LCNI to receive an MRI, they undergo a screening to minimize risks and ensure they are eligible to receive an MRI (see LCNI Standard Operating Procedures for more information). LCNI recently updated its MRI Safety Screening Questionnaire (LCNI Screening) to clarify and update the exclusion criteria and other details reviewed during screening to reflect best practices and account for factors that may impact a participant’s ability to safely receive an MRI. Researchers are encouraged to work with LCNI staff while designing their studies to ensure they will be in alignment with LCNI requirements.
See the updated LCNI Screening Questionnaire and a Summary of Changes for the LCNI Screening in the RAP Library. Also see the LCNI website for more details.
Researchers should also consider whether they want to pre-screen/screen potential participants using the LCNI Screening Questionnaire or other tools before scheduling an MRI at LCNI. RCS would generally recommend that researchers do not attach the questionnaire to their IRB submissions unless the researchers are also using the questionnaire themselves before participants go to LCNI (e.g., as a pre-screening/screening tool) or are using it to collect data for their research. Please note that a modification will be needed to update the materials in the RAP if the questionnaire is used for purpose of data collection.
If researchers are not using this tool as a pre-screening/screening and/or research data collection tool and are merely sending participants to LCNI for a standard screening, the LCNI Screening Questionnaire does not need to be included in the IRB submission.
If researchers have any questions about this screening update, they are encouraged to reach out to LCNI at lcni@uoregon.edu. (posted March 2026)
LCNI Standard Operating Procedure (SOP) Update
The Lewis Center for Neuroimaging (LCNI) provides resources for UO researchers conducting MRIs and the surrounding community, and the Center operates Siemens 3T Skyra and Prisma MRI systems. Some research involving MRIs sometimes involves participants looking at visual stimuli while in the MRI device such as videos, fast moving pictures and/or moving lights. As most glasses contain metal, it is often not possible for participants to wear their glasses during the MRI. If participants feel it is necessary to wear glasses in the MRI, they will be offered MRI-safe glasses that they can wear while in the MRI. The vision range available for these MRI safe glasses runs from +4.00 to -6.00. To date, at least one participant reported feeling dizzy or nauseous while viewing visual stimuli in the MRI, which might have been related to the MRI safe glasses that differed from their prescription, combined with the visual stimuli in the research. As a result, LCNI and RCS developed some possible risk language for consent forms that researchers can use when applicable.
The new risk language lets potential participants know that they might want to consider wearing contacts during the MRI session if possible and to provide information about the MRI safe glasses option and possible risks and discomforts for those participants (e.g., may not be able to see as well as you usually do with your own glasses, or you might feel dizzy or nauseous while viewing the visual stimuli in the MRI). The updated risk language only needs to be included when applicable to a study and won’t apply to all LCNI MRI studies. In most cases, this language will only be applied to new studies submitted after the LCNI SOP update. However, researchers can choose to incorporate this language into their existing studies when applicable. In some cases, the IRB may require updated risk language when necessary to ensure approval criteria are met. The updated risk template language can be found in the updated Lewis Center for Neuroimaging Standard Operating Procedures. (posted April 2026)
Federal Guidance and Critical Sponsor Updates
Multiple Agencies
Research and Partnership Opportunities with the Naval Air Warfare Center Weapons Division (NAWCWD)
Join us Thursday, September 3 from 12:00–1:15 p.m. to learn how NAWCWD partners with universities to address critical research challenges and advance innovation. NAWCWD program officers and staff will discuss research focus areas, available funding opportunities, and pathways for engagement with faculty, postdocs, and graduate students. Priority areas for potential research collaboration include materials science, physics, computer science, math, and chemistry. Lunch will be provided. Please RSVP by Wednesday, August 19.
Agency Requirements for Co-Authors with Foreign Affiliations and UO Form to Assist – NIH, DOE, DOD, USDA, NASA
There have recently been new federal agency requirements regarding co-authorship with researchers who have foreign affiliations.
- NIH now considers co-authorship with authors who have foreign affiliations as evidence of a foreign component that requires the agency’s pre-approval. (See NOT-OD-26-084.)
- NSF, DOE, USDA, and DOD prohibit researchers from collaborating with others who appear on specific prohibited entity lists maintained by the federal government. (See NSF Dear Colleague Letter, DOE entity of concern prohibition, DOD risk matrix, and USDA updated award terms and conditions.)
- NASA researchers have been prohibited from bilateral cooperation with China-based entities since 2011, under the Wolf Amendment. No funds need to be exchanged in order to be considered cooperation. (See NASA GCAM, page 30)
Researchers with NSF, DOE, USDA, and DOD funding would not know if their collaborators have affiliations that appear on those restricted lists unless they ask.
In response to help researchers navigate these new federal requirements, Export Controls and SPS have co-launched a form that would begin the screening process for DOE, USDA, and DOD researchers and also begin the pre-approval process for NIH researchers. Please submit this form before co-authoring a publication with another researcher who has a foreign affiliation.
Our goal is to keep the form as simple as possible to reduce the administrative burden on researchers while also trying to navigate these newly emerging federal requirements.
The form is not required by UO. However, 1) NIH absolutely requires the pre-approval process that UO must initiate if a researcher wants to co-author with another who has a foreign affiliation; and 2) not requesting screening could significantly impact a researcher’s ability to maintain or secure their federal awards if they unknowingly co-author with another researcher who has an affiliation with an entity on a prohibited list. (posted July 2026)
National Institutes of Health (NIH)
National Institutes of Health Replacing Letters of Support with Letters of Collaboration
The National Institutes of Health (NIH) has issued a notice to the research community that it is replacing letters of support with letters of collaboration to reduce administrative burden. Currently, letters of support for NIH applications may come from a variety of stakeholders, including collaborators, institutions, potential users of a resource, or any other interested parties, and can be a page or more in length. This change aligns with requirements with the formant of letters of collaboration currently used by the National Science Foundation. This new rule will begin with the implementation of Forms J guidance starting in the federal fiscal year of 2027. (posted August 2026)
NIST 800-171 Compliance Certifications
PIs and researchers requesting access to Adolescent Brain Cognitive Development (ABCD) and Healthy Brain and Child Development (HBCD) study data through the NBDC Data Hub (NIH Brain Development Cohorts) are now required to certify the following statement:
“By checking this box, I, as the PI requesting access to this data, attest that data will be secured, at a minimum, in accordance with NIST SP 800-171 or the equivalent ISO/IEC 27001/27002 standards as stipulated by the NIH Security Best Practices for Users of Controlled-Access Data. Institutions with Plans of Action and Milestones (POAMs) to mitigate security risks will be considered compliant.”
Prior to signing or checking the box on this attestation or any similar attestations requiring NIST SP 800-171 compliance, you must have a POAM in place to ensure the data is secured.
Please contact your Post Award sponsored projects administrator (SPA) who will be serving as the signing official on the data use certification. Post Award will also connect you with the UO IT Security Risk & Compliance (ISRC) team for their assistance with putting a POAM in place. We recommend you reach out as soon as you know you will be renewing or requesting data access to allow adequate time for this process. (posted March 2026)
MFTRP Certification Required at NIH RPPR Submission
NOT-OD-26-018 introduces an Annual Malign Foreign Talent Recruitment Program (MFTRP) certification requirement for all Senior/Key Personnel. This applies to Research Performance Progress Report (RPPR) submissions on or after January 25, 2026. The certification must be uploaded as a separate PDF for each individual in RPPR Section G.1. If you have questions about this requirement, please contact your Post Award Team. (posted March 2026)
National Science Foundation (NSF)
U.S. Department of Health and Human Services (HHS)
Department of Energy (DOE)
New Conflict of Interest Requirements for Department of Energy Researchers
Effective August 2026, the U.S. Department of Energy (DOE) issued a final rule for its Conflict of Interest (COI) Policy for Financial Assistance, under 2 CFR Part 200 Subpart C. There are important differences in the DOE COI Policy from other agencies:
- Researchers must update their COI disclosures in the Research Administration Portal (RAP) within 15 days of acquiring a new Significant Financial Interest or changing in an existing one.
- Researchers must disclose in the RAP reimbursed or sponsored travel of any amount unless the travel is funded by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with a U.S. institution of higher education.
- Researchers must disclose in their current/pending (other) support document gifts provided without terms and conditions if that gift supports or relates to their professional research (including basic and fundamental research), development, demonstration, and/or deployment efforts.
- The UO must manage apparent conflicts of interest for DOE researchers. An apparent conflict occurs when a conflict may appear to exist to a reasonable outside observer even if there is no actual or potential conflicts.
- Researchers must complete COI training every two years, and the DOE will accept research security training that addresses conflicts of interest and commitment. UO researchers already complete research security training annually, which serves as a refresher course to meet the DOE requirements. Researchers must still complete required financial conflict of interest in research training every three years under the UO’s Financial Conflict of Interest in Research Policy.
- The UO must review each researcher’s Significant Financial Interests disclosed in the RAP against the sponsored project at the time of proposal. Conflicts that the UO cannot manage or any conflict with a foreign entity must be disclosed in the proposal itself.
- Subawardees on DOE projects must have an enforced conflict of interest and conflict of commitment policy or they must use UO’s Financial Conflict of Interest in Research Policy and the conflict of commitment requirements of the UO’s Conflict of Interest, Conflict of Commitment, and Outside Activities Policy.
Questions about these new requirements? Email coi@uoregon.edu. (posted August 2026)
Department of Defense (DOD)
Requirements for Working with Foreign Entities Under USDA and DOD Funding
Foreign entities listed on U.S. government restricted party lists may not receive USDA or DOD funding. If you are a UO researcher who holds USDA or DOD funding, ensure that all agreements with foreign parties are reviewed through a central office, such as:
- Purchasing and Contracting Services
- Industry, Innovation, and Translation
- Sponsored Projects Services
The Office of Export Controls reviews foreign counterparties on agreements processed through these offices and will identify any potential matches on restricted party lists. If your collaboration or agreement with a foreign entity does not go through a central office, you must request a restricted party screening before beginning the engagement. To do so, email exportcontrols@uoregon.edu or complete the online form. (posted June 2026)
Anthropic’s Claude AI Not Allowable on Department of Defense Projects
Effective September 2, 2026, Anthropic, the company that builds and sells Claude (a generative AI platform), cannot be used in conjunction with projects sponsored by the Department of Defense (DOD) nor purchased with DOD funds.
If you have DOD funding and are using Claude on another project, you must ensure adequate segmentation between the DOD-sponsored project and the project using Claude. Claude cannot access DOD systems, infrastructure, or data. (posted April 2026)
Department of Defense’s Updated Decision Matrix and Its Impact on Researchers
DOD has issued an updated decision matrix to inform fundamental research proposal mitigation decisions. The matrix may directly affect researchers’ eligibility for funding or require mitigation for those who have certain international collaborations or co-authors.
Most notably, risk factors that now require mitigation measures include:
- Within the past five years, the researchers’ co-authors on publications are affiliated with an entity on a prohibited entity list at the time of grant review.
- Within the past five years, the researchers’ co-authors on publications are participants in a malign foreign talent recruitment program.
DOD researchers should email exportcontrols@uoreogn.edu to request a compliance check or complete the compliance check request form prior to co-authorship to ensure their co-authors do not appear on any prohibited lists.
As a reminder
- When submitting academic work for publication, cite only grants that supported the conduct of the study and if the work was in-scope.
- If a student, postdoctoral scholar, or visiting scholar has subsequently moved to another institution, cite the (home/grantee) institution where the work was conducted and not the current affiliation of the co-author. Otherwise, if the current affiliation is on a Prohibited Entity List, this will impact the risk assessment of your proposal, including with other agencies. However, if the work was conducted at another institution, that must be cited.
- Performance of significant elements of a federally funded project outside the U.S. must be disclosed and approved by the funding agency in advance. (posted April 2026)
Other Sponsor Updates
USDA Rules Limit Agreements with Foreign Countries of Concern Effective June 2026
USDA recently revised their general award terms and conditions.
Effective June 3, 2026, USDA PIs and senior/key personnel may not enter into an agreement with a person or entity located in a foreign country of concern or under the ownership, control, or influence of a foreign country of concern.
A foreign country of concern includes China, Russia, Iran, and North Korea.
The USDA also prohibits PIs, senior/key personnel, and the UO from provide any form of direct benefit (material or non-material) through work conducted under, in direct support of, or otherwise reasonably related to the USDA award to any foreign adversary, foreign country of concern, or any person or entity known to be under the ownership, control, or influence of a foreign country of concern.
This prohibition applies to agreements researchers may have individually in an outside activity and also to agreements that go through the UO related to the USDA research.USDA researchers who currently have any form of agreement, whether individually or through the UO, with a person or entity in a foreign country of concern, please email exportcontrols@uoregon.edu right away.
In addition, USDA may periodically identify unallowable costs due to national security concerns. Currently, items on the unallowable cost list due to national security concerns include 3D printers and drones manufactured in China. As a reminder, drones manufactured in foreign countries of concern, including popular DJI and Autel drones, may not be used in conjunction with federal research, regardless of the federal sponsor. (posted July 2026)
USDA Restricts Foreign Publication and Data Hosting for Federally Funded Research
On April 7, 2026, the U.S. Department of Agriculture (USDA) published a new policy, “Public Access to Scholarly Publications and Digital Scientific Research Data.” This policy places restrictions on where USDA-funded research can be published and where related data can be stored. Under the policy, researchers may not publish USDA-funded work in journals that are owned, managed, controlled, or operated (physically or virtually) by entities based in a designated “foreign country of concern.” In addition, any data repositories used to store or share research results must not be hosted, funded, or controlled by organizations located in these countries. The USDA currently defines “foreign countries of concern” as China, North Korea, Russia, and Iran. These requirements are intended to limit the involvement of certain foreign entities in the dissemination and storage of federally funded research. (posted June 2026)
Federal Awards with Cybersecurity Requirements: NIST 800-171, CMMC, CUI DFARS 242.204-7012
We are beginning to see more requests for proposals that include requirements to meet:
- NIST 800-171
- Cybersecurity Maturity Maturation Certification (CMMC)
- Controlled Unclassified Information (CUI)
- DFARS 252.204-7012
Currently, the UO can comply with CMMC Level 1 requirements.
Compliance with CMMC Level 2, NIST 800-171, CUI, or DFARS 252.204-7012 will require a more in-depth assessment to determine whether the UO can comply. In most cases, the project will need to budget the costs of compliance with the increased cybersecurity requirements. UO cannot comply with CMMC Level 3 requirements at this time.
The Office of Export Controls monitors Department of Energy and DOD proposals in EPCS to help identify these requirements in requests for proposals. However, if departmental grant administrators (DGAs) or principal investigators (PIs) find these terms in their requests for proposals, please email exportcontrols@uoregon.edu as soon as possible so there is adequate time to determine whether the UO can comply and the impact on the project budget. (posted April 2026)
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