Actually, I am wrong on the timing … footnote came before Senate hearing (but maybe he had advance draft)

GOP has squawked but not convincingly, so I mostly expect Vought to go forward. He is pissed about Senate FY26 appropriation bill (eg, timing of footnote-I don’t like what Senate just did & will make NIH pay). No reactions described in The Hill seem like they would deter Vought. Hope I am wrong!

That was his first attempt to defund the NIH - that wasn’t a pocket rescission. Pocket rescission is sent to Congress, like the one for USAID & CPB, which was a practice run. Vought can freeze funds for 45 days, even if Congress rejects the rescission, by which time it will be too late to release $

Pocket rescission by Vought 45 days before end of FY25

Pocket rescission (Vought has stated intent to use, which would be 45 days before the end of FY25)

We’ll get the bill text after the hearing - just glad they are aware for now … looking forward to reading the text

Big highlight was Senator Baldwin calling out the NIH MYF “policy”

Several ICs are, & some started earlier either as planned or to help spend their FY25 appropriation in time (vs achieve 50%), but they haven't updated their financial plan to reflect the rationale. NIAID MYF awards seem to be all (or mainly) in July, suggesting adoption of FY26 CJ "policy" language.

Exactly. IC staff have no desire to enable this (esp. with no written guidance), but NIH leadership does. NCI is leaderless, so not surprised they were first to formally adopt the FY26 CJ language for FY25. NINDS could be next (Aug 7 Council mtg) - or NIAID (based on leadership)

Well, not "any" language, of course, but guidance on how appropriations are to be spent.

Congress can slip any language they want into a CR, so if the Senate especially is alarmed by all this, they could and might.

Yes, they can add language stopping altogether or lengthening the transition period to (ie, <<<50% of RPGs) a requirement for MYF. Senate Appropriations Committee considers Labor-HHS-Ed Thurs morning, so contacting Senators about MYF “policy” harms is important (& House Reps, too)

“In addition, NIH has recently implemented a new policy requiring that at least one-half of the remaining funds for competing research project grants (RPGs) in FY 2025 be used to upfront fund RPG competing awards. …”

I didn’t see anything obvious in CFR other than multiyear awards cannot exceed 5 y (not a CFR expert though) … but Congress should have questions about an unpublished “policy” with such significant impact

OMB was very intentional in adding this to the CJ (ditto for pretending 15% F&A rate is established). Probably similar to paylines: ICs do not need to set/publish these, so JB/HHS/DOGE can get away with enforcing (as part of award approval?) as if established policy despite never being communicated

Yes - not commonly used in the past, but more so in recent years, either as RF1 or simply a multi-year budget period for traditional activity codes (R01, R21, R03, etc).

Nothing in the Federal Register, NIH Grants Policy Statement, NIH Policy Manual, or the NIH Guide. As far as I can tell, there is no FY25 "multi-year funding policy". Another question for your Rep & Senators when you reach out per Don's great advice.

The NIH has not written down nor disseminated a policy of any type regarding a requirement for multi-year funding of half of all RPGs. This sprang into existence when the FY26 Congressional Justification documents were released (see p 5 plus each IC CJ): officeofbudget.od.nih.gov/pdfs/FY26/br...

donmoynihan.substack.com/p/the-nih-bu...