Hundred of millions of dollars grants from different U.S. government agencies are being abruptly … More
With hundreds of millions of dollars of federal grants being abruptly terminated under the administration of President Donald Trump and Elon Musk’s Department of Government Efficiency, you may be wondering whatcha going to do if your grant funding suffers the same fate. After all, if something as innocent as having “women” or “Gulf of Mexico” in your proposal or reports could trigger a re-evaluation of your funding, your federal funding and the projects it supports may feel about as certain as the characters in the TV series Game of Thrones. Well, one thing you could do is curl up in a ball and repeatedly mutter “Bring me to a happy place, bring me to a happy place” amidst all the chaos. Or alternatively you could try to do something about it.
Grant termination used to be a much rarer occurrence, reserved for more extreme circumstances such as some kind of ethical breech or an agency running out of money. After all, researchers need time, leeway and stability to get things done. But during Trump’s first term as President in 2020, the Office of Management and Budget did add a new rule allowing grant awards to be terminated if they “no longer effectuates the program goals or agency priorities.” That new vague stipulation remained in place throughout the Biden Administration and into the second coming of Trump and is now being used as justification to yank grants from many investigators.
This has in turn set a new precedent that may have left you wondering how secure federal grants will ever be in the future and when you may someday face the big T no matter how well your project may be going. Therefore, it’s a good idea to bone up on what to do if your federal funding ever gets threatened in any way. Don’t be like the characters in Scary Movie and simply wait to be picked off one by one. Instead, remember when you can always do the following 10 things:
1. Get your institution or organization involved as soon as possible.
Sure, you may have written the bulk of the grant proposal and done the lion’s share of the work. Sure, you may be able to bring the grant along with you should you move institutions or organizations. But typically, federal grants are awarded to an institution rather than an individual. Therefore, most communications about the contractual status of the grant has to go through the institution.
Plus, the termination of a grant would negatively affect the institution as well. The institution will lose funds for indirect costs, which, as I have detailed previously in Forbes, it may be using for all sorts of things like the salaries of institution leaders and administrators and who knows what else. The institution presumably doesn’t want to see the loss of jobs, infrastructure and capabilities such as any training programs or centers supported by the grant. All of this can also damage the reputation of the institution because few will say, “Let’s go to the institution that lost all those grants.” Therefore, the institution should have more than a little incentive to support your quest to keep your grant.
Naturally, no one would say that they would rather have less support than more support. And institutions tend to have more resources than individuals. For example, your institution may have a grants management office dedicated to, you guessed, grants management. And losing a grant would be kind of a grants management problem. Your institution may also have a lawyers who can help make sure that your don’t put a legal foot in your mouth. On top of all this, no matter how well known you may be, official emails or letters from the institution and its leaders can add that extra oomph and signal to the agency that you are not alone.
So once you know that your grant may in jeopardy, contact your institution’s office of sponsored research as soon as possible. If your institution doesn’t immediately lend its support, you may want to remind the institution’s leaders about all of the above.
2. Document all interactions with the program officer, grants management officer and federal agency in general.
Once you feel that your grant may be under threat in any way, remember the “d” word, meaning documentation. Keep detailed and organized records of all communications with your program and grants management officers. Organize the documentation so that you can readily forward it to others.
Do not meet alone with anyone from the agency who seems hostile to the continuation of your funding, especially not in a dark alley. Instead, make sure that witnesses are present and ask to record all conversations. If that person refuses to allow recording, that in and of itself may be a big red flag. Try then to keep conversations on email so that there is no question about what was discussed.
3. Know your rights and the grants process.
It may be easy to think, “I’m a scientist, researcher or whatever. So I don’t need to know all of this financial and legal stuff.” But that’s sort of like saying, “I want to stay clean and non-smelly but I don’t want to learn to use soap and take a shower.” It’s important to know how the entire grants and funding process works and what your rights are. Otherwise, how the heck can you prevent bad things like grant terminations from happening?
One thing to be aware of is how your grant was awarded in the first place. For example, scientific agencies like the National Institutes of Health and the National Science Foundation have historically relied on reviews from external committees of scientific experts in relevant fields to determine whether to fund a grant application. This external peer-review process was installed to prevent individuals within the agency from exerting their individual biases and agendas on the design and work of the studies being funded. Therefore, in theory, no one in the agency should have the right to re-evaluate the science that you are using as long as you are following what you originally proposed. If, however, you find someone trying to question the science of what you had proposed after the grant was awarded, point this out in writing and emphasize that your proposal did pass through external peer-review.
Another key thing to keep in mind is that a federal agency typically has to go through a formal process and set of procedures to terminate a grant. These are in place to prevent one person whether it is a program officer or politician from unilaterally terminating a grant due to personal bias or political agendas. Below are links to the current funding termination regulations for different federal agencies:
Of course, you can’t dodge or perhaps DOGE the possibility that these regulations may soon be changed. So take screen shots of the current ones in case you need to reference them in the future.
4. Carefully review all communications from the federal agency.
Don’t view communications from federal agencies like you would Instagram messages from your besties. These agencies will rarely say things like, “How are doing? Love your shirt,” when it comes to your funding especially these days. So make sure that you carefully go through any communications from them with a fine-toothed comb. Look for inconsistencies and mistaken information. Also, be on the lookout for little grenades, subtle statements that may be laying the ground for grant termination such statements that they previously warned you about such-and-such. Be wary of attempts to rewrite history like claims that something was or was not done when you know the opposite was the case.
If you have the misfortune of receiving a termination letter, review it carefully along with representatives from your institution. The letter should include details about how to appeal the decision and the timeframe within which it must be done (typically, 30 days after the notice was delivered). The appeal should include documentation of prior relevant communications and any irregularities in the process to date along with descriptions of the negative impact that termination will have on science and society in general.
The termination letter should also include details on what existing expenses may still be covered. If it doesn’t, seek written clarification. Naturally, if you are going lose grant funding, you want to get as much out of it as possible.
5. Be deliberate about your communications with the federal agency and offer any questions and rebuttals in writing.
Remember, once you suspect that your grant may be in jeopardy, every interaction and communication with the agency matters and essentially becomes part of the historical record. Therefore, be deliberate about what you do and how you communicate. You never know when someone might come back and say, “You said you would do this but never did” or “I warned you about such-and-such but you didn’t heed my warning.”
That’s why it’s important to rebut/question any questionable statements made about you and your project. Failure to do so could be taken as agreement with what was said. When communication from an agency has made too many misstatements to reply to each, simply say that and maybe refute just a sample of them as in “Your email contains many statements that we disagree with and are not consistent with our recollection of what happened. Here are some examples.”
Beware of very vague general statements too such as Your such-and such doesn’t seem to work” or “You haven’t provided enough evidence for such-and-such.” This is a tactic frequently used by people who cannot make legitimate criticisms of you or your work. When this happens, push for more specifics in writing such as, “We would be happy to do more or provide more evidence. But it’s difficult to know what to provide without knowing more specifically what your concerns or questions are.”
6. Inquire about the appeals process and request appeals in writing as soon as you can.
Should you be faced with a grant termination or a step that may be leading to a grant termination, ask about the appeal process and put it on written record that you are requesting an appeal. Make sure that you do this promptly and are aware of any time limits (usually 30 days) during which appeals must be made. Even if you don’t get a response, you can always refer to your written request. Consider following up at least once so that it will be difficult for anyone to say that they accidentally missed your request.
7. Consider discussing your situation with many others. Expand your network
Vampires may fear the sunlight. But you shouldn’t. As long as you have been doing everything ethically, don’t be afraid about others finding out about your predicament. In fact, the opposite may be better. Consider telling others about what is going on with your grant funding such as professional colleagues, lawyers, members of the media, advocacy organizations and Congressional, state and local representatives. This can help get you more advice and potentially help.
8. Protect your work.
Grant termination doesn’t mean that you should completely give up that line of work. When an agency terminates a grant, it is the one reneging on an agreement. This in turn limits the rights as to what the agency’s personnel can demand from you. After all, if you were to hire someone to bake you a fruitcake and then after that person has assembled the ingredients, you told that person, “I’m not going to pay you the full amount but I still want a complete fruitcake,” that person would probably offer you no more than some choice f-words with none of them being “fruitcake.” Do what you can to protect your work and keep the option of shopping it to other funders.
9. Keep in mind the long game.
Doing all of the above may save your grant. But that doesn’t mean that the story has to end there. You never know what may happen in the future. Who knows what kind of mass action, legal recourse, media exposes and other things you could have available to you in the future. Moreover, who knows how those complicit in your grant termination may need you in the future. That’s why they say be careful about whom you kick on your way up because those people may end up kicking you on the way down.
10. Stay factual, ethical and patient.
That’s why it is important to act ethically and stay factual all along the way. When someone has been dirty to you, resist the temptation to act dirty in retaliation. That could leave both of you covered in mud and indistinguishable from each other. And those who are used to being dirty are probably far better at it than you.
Finally, be patient. Many federal agencies like the NIH are in disarray right now, meaning that their termination appeals processes may be in disarray as well. At the same time, many universities, investigators, research administrators, lawyers, federal employees, policy makers, businesses and others are still trying to figure out what to do about all these cuts and layoffs and formulating their response strategies. Just because your grant got terminated prematurely doesn’t mean that you should prematurely terminate hopes that things will somehow get better.
