The Executive Orders Blocking Your NIH Grant

This image was generated by Google AI (Gemini)

Congress appropriated $47 billion for NIH research in fiscal year 2026. The President signed it into law on February 3, 2026. Many researchers assumed the worst was over. Funding was secured. NIH could move forward.

But the grants are being awarded at a super, super slow pace right now, leading many to worry whether the NIH will spend all of its money by the end of the current fiscal year (Oza, 2026).

I spent 22 years as a program official at NIH. I know how the system worked and how it has changed. This essay explains why grant funding has slowed to a crawl, and documents the comprehensive vetting system that most researchers don’t know exists.

To understand the complexity of the situation, it is important to look at the policy changes implemented by the current administration. Between January 20, 2025, and the present, a series of executive orders and policy changes have created a comprehensive system for vetting NIH research grants based on ideological criteria. Many researchers submitting applications may have no idea this system exists.

The Executive Orders

Two executive orders issued in 2025 established the framework for political vetting of NIH research grants.

On January 20, 2025, hours after taking office, President Trump signed Executive Order 14168, “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.” Section 3(g) states: “Federal funds shall not be used to promote gender ideology. Each agency shall assess grant conditions and grantee preferences and ensure grant funds do not promote gender ideology.”

The order defines “gender ideology” as replacing “the biological category of sex with an ever-shifting concept of self-assessed gender identity.” It mandates that all federal agencies use “sex” (defined as “immutable biological classification”) rather than “gender” in policies and documents.

Six months later, on August 7, 2025, the President signed Executive Order “Improving Oversight of Federal Grantmaking.” This order established additional requirements for all federal discretionary grants.

The preamble justifies these restrictions by citing examples of grants the administration considers wasteful: “drag shows in Ecuador, trained doctoral candidates in critical race theory, and developed transgender-sexual-education programs.” It blames NIH for funding “an unsafe lab in Wuhan, China” and claims that “more than one-quarter of new National Science Foundation (NSF) grants went to diversity, equity, and inclusion and other far-left initiatives.”

Section 3 of the August 7 order requires that all agencies designate senior political appointees to review and approve funding opportunity announcements and discretionary grants. These appointees “shall not ministerially ratify or routinely defer to the recommendations of others in reviewing funding opportunity announcements or discretionary awards, but shall instead use their independent judgment.”

Translation: political appointees can override scientific peer review.

Section 4(b) establishes criteria that senior appointees must apply when reviewing grants. Discretionary awards must “demonstrably advance the President’s policy priorities” and “shall not be used to fund, promote, encourage, subsidize, or facilitate” the following:

• Racial preferences or other forms of racial discrimination by the grant recipient

• Denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic

• Harm reduction

• Illegal immigration

• Any other initiatives that compromise public safety or promote anti-American values

These categories are broad enough to encompass substantial portions of NIH-funded research. Health disparities research studying interventions targeted at racial or ethnic groups could be characterized as “racial preferences.” LGBTQ health research could be deemed “denial of the sex binary.” Addiction and overdose prevention research could be classified as “harm reduction.” Research on immigrant health could be considered support for “illegal immigration.” And “anti-American values” is undefined, allowing political appointees to apply it to virtually any research they oppose.

Implementation Through Policy Notices

Executive orders establish broad requirements. NIH policy notices translate them into specific grant conditions.

On July 17, 2025, NIH issued Notice NOT-OD-25-131 revising its policy on inclusion of women and minorities in clinical research. The stated purpose: “to align with Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.”

The revision mandates use of “sex” instead of “sex/gender” in all NIH-funded research. Effective August 16, 2025 (30 days after publication), the policy applies to “all grants, cooperative agreements, contracts, other transactions, and intramural studies.”

Any research on transgender health, gender-affirming care, or LGBTQ health disparities that uses “gender” terminology is now non-compliant with NIH policy.

On November 18, 2025, NIH issued Notice NOT-OD-26-009 implementing the termination provisions required by the August 7 executive order. Effective October 1, 2025, all new NIH awards now include this language:

“Pursuant to 2 CFR 200.340, 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, and 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.”

This applies to new grants, renewals, supplements, and continuation awards. The phrase “agency priorities” is critical because those priorities are now defined by the executive orders and the Unified Strategy, which I will explain shortly.

The notice also includes a remarkable provision: “Any term or condition in this Notice of Award...that NIH is enjoined by court order from imposing or enforcing, shall not apply or be enforced as to any recipient or subrecipient to which that court order applies and while that court order is in effect.”

Translation: court victories only protect the specific institutions that sued. If one university successfully challenges these terms in court and wins, NIH will stop enforcing them against that university but will continue enforcing them against everyone else who has not obtained their own court order.

The Unified Strategy and the Elimination of Paylines

The executive orders establish what NIH cannot fund. The Unified Strategy establishes what NIH will prioritize. Together with the elimination of payline funding criteria, they create comprehensive control over grant decisions.

On August 15, 2025, eight days after the “Improving Oversight of Federal Grantmaking” executive order, NIH Director Jay Bhattacharya issued a statement titled “Advancing NIH’s Mission Through a Unified Strategy.”

The statement establishes NIH research priorities. It also establishes what research NIH will deprioritize. All current NIH funding opportunity announcements now include this language: “Applicants and recipients are strongly encouraged to refer to the NIH Director’s Statement of Priorities, entitled ‘Advancing NIH’s Mission Through a Unified Strategy.’”

On health disparities research, the Unified Strategy states:

“In contrast to research that considers race or ethnicity when scientifically justified...research based on ideologies that promote differential treatment of people based on race or ethnicity, rely on poorly defined concepts or on unfalsifiable theories, does not follow the principles of gold-standard science. Such studies divert resources away from projects that advance the health and longevity of all Americans, including minority populations.”

It continues: “Broad or subjective claims—such as attributing worse health outcomes in a particular population to poorly measured factors like systemic racism—should not be presented as established background facts without clearly defining measurable variables that are part of the research question.”

Research studying structural determinants of health disparities is now characterized as “ideological,” “poorly defined,” and “off-mission.”

On transgender health research, the Unified Strategy states that research “that aims to identify and treat the harms these therapies and procedures have potentially caused to minors diagnosed with gender dysphoria...is more promising” than research on “the use of puberty suppression, hormone therapy, or surgical intervention.”

Only research examining harms of gender-affirming care will be prioritized. Research supporting such care is implicitly deprioritized.

On foreign collaboration, the Unified Strategy states: “All NIH institutes, centers, and offices should consider whether there is a scientific justification for conducting a research program at a foreign site rather than a domestic one. The NIH should prefer the latter over the former when scientifically justified.”

Presumably, this implements the executive order’s prohibition on funding research that advances “anti-American values” by defining domestic research as inherently preferable.

The Unified Strategy is not just a statement of priorities. It has been operationalized into NIH’s funding decision process through the elimination of paylines.

In November 2025, NIH announced a fundamental change to how grants are funded. The agency eliminated reliance on paylines, which were objective score cutoffs that some ICs used to determine which applications received funding based primarily on peer review scores. This new policy is described as Implementing a Unified NIH Funding Strategy to Guide Consistent and Clearer Award Decisions.

According to NIH’s official guidance: “As part of the wider Unified Funding approach, ICOs will no longer employ these cutoff points in overall impact scores to determine which applications to fund...Moving forward, ICOs will consider peer review information in its entirety when assessing scientific merit.”

In practice, this means funding decisions are no longer based primarily on peer review scores. They are now based on “core tenets” that include:

• Alignment with NIH’s mission (as defined by the Unified Strategy)

• ICO priorities (as defined by the Unified Strategy)

• “Broad distribution and geographic balance of funding”

• “The total amount and type of NIH funding already available to each investigator”

• “Actual needs, opportunity costs, and stewardship of taxpayer investments”

This eliminates the objectivity that paylines provided. Previously, if your application scored above the payline, you had a strong likelihood of funding. The decision was based primarily on scientific merit as assessed by expert peer reviewers.

Now, even if your application receives an excellent peer review score, the funding decision depends on whether it aligns with the Unified Strategy priorities, fits the institute’s interpretation of “geographic balance,” and represents appropriate “stewardship of taxpayer investments” in the judgment of IC directors (and/or presumably in the judgement of the NIH Director who may override the IC directors or convince them to change their decisions).

Institute directors—some of whom are political appointees or who report to political appointees—have “delegated authority to decide what is funded,” with peer review recommendations being advisory rather than determinative. However, since so many NIH IC directors have been fired or left, this leaves the agency with many “acting” IC directors who may not feel they have the power to override political appointees’ demands.

The combination creates a second mechanism for rejecting grants. Even if your research does not explicitly violate an executive order prohibition, it can be rejected for failing to “align with agency priorities” as defined by the Unified Strategy.

What’s Now Required in Every NIH Grant Application

All NIH funding opportunity announcements now include identical language establishing new requirements for applicants.

Compliance certification:

“By applying for or accepting federal funds from HHS, recipients certify compliance with all federal antidiscrimination laws and these requirements and that complying with those laws is a material condition of receiving federal funding streams.”

This references the executive orders’ definitions of sex (binary, immutable, determined at conception) and prohibitions on “racial preferences.” By applying for NIH funding, you certify compliance with these definitions. If your research uses “gender” terminology or studies interventions targeted at racial or ethnic groups, you may be violating the “federal antidiscrimination laws” as redefined by the executive orders.

Unified Strategy alignment:

“Applicants and recipients are strongly encouraged to refer to the NIH Director’s Statement of Priorities, entitled ‘Advancing NIH’s Mission Through a Unified Strategy.’”

The Unified Strategy establishes that health disparities research must not study “poorly measured factors like systemic racism” and that only research on harms of gender-affirming care (not benefits) will be prioritized. This “strong encouragement” functions as a requirement when senior political appointees review grants for “alignment with agency priorities.”

Termination provision:

“By accepting an NIH award, the recipient agrees that continued funding for the award is contingent upon...compliance with the Terms and Conditions of the award, and 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.”

“Agency priorities” are defined by the Unified Strategy. “Program goals” can change based on executive orders. Your existing grant can be terminated if NIH decides it no longer aligns, even if the research was approved under previous priorities.

Together, these three provisions create a comprehensive system. You certify compliance with executive order-redefined “antidiscrimination laws.” You are “strongly encouraged” to align with Unified Strategy priorities. Your grant can be terminated if deemed non-compliant with either.

These requirements are being actively enforced in grant funding decisions. According to current NIH staff who spoke on condition of anonymity, program officers are receiving specific feedback that applications they recommend for funding do not align with agency priorities.

For health disparities research, proposals using terms such as “social determinants of health,” “lived experience,” or “neighborhood stressors” are being flagged as insufficiently specific and not meeting the standards outlined in the Unified Strategy. “Social determinants of health” is an established scientific framework with decades of peer-reviewed literature examining how structural factors like poverty, housing, and environmental exposures affect health outcomes. Characterizing such terminology as “vague and non-specific” effectively prohibits research on these topics.

For international collaborations, applications must articulate both a “clear scientific rationale” for conducting research abroad rather than domestically and demonstrate “direct potential to generate knowledge applicable to understanding, improving, or protecting the health of Americans.” This requirement appears in an August 25, 2025 statement from the NIH Director titled “Maximizing and Safeguarding NIH’s Investment in Foreign Collaborations.” The statement emphasizes that “NIH is not a foreign aid organization” and that international research must “deliver both scientific and taxpayer value.”

These review criteria transform scientific evaluation into political screening. Grants are assessed on whether their terminology, geographic scope, and framing align with administratively defined priorities that emphasize domestic benefit and "measurable variables" while excluding research frameworks the administration characterizes as ideological. These political assessments are overriding the scientific recommendations of NIH Program Officials and peer review.

This standard language appears in every NIH funding opportunity announcement now, regardless of research area. It applies to all grant types, all institutes, all mechanisms. Every NIH applicant now operates under these requirements.

Why Non-Competing Continuation Awards Are Being Scrutinized

The termination clause in NOT-OD-26-009 applies not only to new grants but also to “renewal, supplement, or continuation awards issued on or after October 1, 2025.”

This explains why non-competing continuation awards—grants that were already funded and are simply receiving their next year of support—are being scrutinized under the new criteria.

According to current NIH staff who spoke on condition of anonymity due to concerns about professional retaliation, continuation awards are being reviewed for alignment with the executive orders and Unified Strategy priorities. Grants that were approved years ago under different criteria are now being re-evaluated against current political requirements.

“Agency priorities” can change at will. Your multi-year grant could be terminated mid-stream because priorities have shifted, even though your research has not changed and continues to receive strong peer review.

When Courts Strike Down One Mechanism, Others Remain

In February 2025, NIH announced a 15% cap on indirect costs. Universities sued immediately. Courts struck it down as illegal. The Trump administration appealed. Lost again. The deadline to petition the Supreme Court passed in April 2026 without the administration filing (Molteni, 2026). The indirect cost cap is dead.

But look at the August 2025 executive order, Section 4(b)(iii): “All else being equal, preference for discretionary awards should be given to institutions with lower indirect cost rates.”

And Section 5(b): The OMB Director “shall...revise the Uniform Guidance and other relevant guidance to appropriately limit the use of discretionary grant funds for costs related to facilities and administration.”

When the direct approach (the 15% cap) failed in court, the administration shifted to indirect approaches. Senior political appointees now “prefer” institutions with lower indirect costs when reviewing grants. OMB is revising grant guidance to “limit” indirect costs through policy rather than regulation.

Same goal. Different mechanism. Harder to challenge in court because it is buried in grant review criteria and administrative guidance rather than announced as explicit policy.

This is the pattern. When legislative proposals fail (Congress rejected NIH restructuring), implement administratively. When regulations fail in court (15% indirect cap struck down), implement through executive orders and grant vetting.

The executive order contains multiple mechanisms for restricting grants. Strike down one, and the others remain operational.

Why Grants Are Being Delayed Despite Congressional Funding

I keep hearing from researchers and university leaders, such as Vice President for Research (VPR) / Vice Provost for Research types: “Congress funded NIH, so everything is fine now.”

The administration has its own version of this reassurance. In April 2026, an HHS spokesman told The Washington Post that the ‘Democrat-led shutdown’ late last year was responsible for delays and that NIH was ‘catching up.’ The spokesman added that the shift to multi-year budgeting ‘will help sustain long-term research’ by giving researchers ‘more funding stability’ (Johnson et al., 2026).

But this explanation does not account for what the executive orders and policy changes have put in place. The delays are not simply about catching up from a shutdown or adjusting to new budgeting practices. They are the result of a comprehensive vetting system that did not exist before January 2025. Screening tens of thousands of grant applications for ideological compliance for funding approval takes time.

Congress did fund NIH. That is true. The President signed the appropriation. The money exists.

But the grants are not necessarily moving.

The collapse of NIH funding announcements I documented in a previous series of three Substack essays (from 756 NOFOs in 2024 to 17 in 2026 as of mid-March: NOFO essay 1, NOFO essay 2, NOFO essay 3) is explained by Section 3(c) of the August 7 executive order: “agencies shall not issue any new funding opportunity announcements without prior approval from the senior appointee.”

The grants stuck in the funding queue are explained by Section 3(a)(vii): “pre-issuance review of discretionary awards to ensure that the awards are consistent with applicable law, agency priorities, and the national interest.”

The restrictions now appearing in funding opportunities are explained by Section 4(b): the prohibited content list.

This is not accidental. This is the administration policy working exactly as designed.

Most researchers submitting applications right now do not know their grants are being screened for ideological compliance after scientific merit has already been established by peer review and by NIH Program Officials. They do not know their existing grants can be terminated if a political appointee decides they no longer align with “the President’s policy priorities.” They do not know that peer review scores, while still generated, are now advisory rather than determinative.

They do not know because the people who could tell them, such as NIH program staff, dare not say so. Civil servants operate under strict rules governing public statements. Many are aware that whistleblowers in the current political environment have faced retaliation despite formal protections.

How the Vetting System Works

The money Congress appropriated exists. But between appropriation and award, a comprehensive system of political vetting has been inserted.

Two executive orders establish prohibited content and require political appointee approval of all grants. Two NIH policy notices implement these requirements through specific grant terms. The Unified Strategy defines positive priorities and what research is “off-mission.” The elimination of paylines removes objective decision criteria. Standard language in all funding announcements requires compliance with all of the above.

The result is a multi-layered vetting system where grants can be rejected or terminated based on:

• Use of “gender” terminology (Executive Order 14168)

• Research on harm reduction, racial health disparities, or immigrant health (Executive Order “Improving Oversight of Federal Grantmaking”)

• Studying “poorly measured factors like systemic racism” (Unified Strategy)

• Failure to “demonstrably advance the President’s policy priorities” (standard NOFO language)

• Determination by IC directors that the research no longer represents good “stewardship of taxpayer investments” (funding decisions guidance)

Most researchers submitting applications do not know this system exists. They think peer review determines funding. They think Congress funding NIH means grants are being awarded normally. They are operating based on how the system worked before January 2025.

The system has changed. The people who understand most clearly what has changed are the least able to say so.

That silence is what I am trying to break.

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

Sources

Collard, H. (2026, March 20). Facing the new reality of NIH funding. The Scientist. https://www.the-scientist.com/facing-the-new-reality-of-nih-funding-74237

Johnson, C. Y., Sidhom, L., & Svrluga, S. (2026, April 19). Where U.S. science has been hit hardest after Trump’s first year. The Washington Post. https://www.washingtonpost.com/science/2026/04/19/science-research-funding-cuts-trump/

Molteni, M. (2026, April 8). Trump administration drops court fight to cap NIH payments for research overhead costs. STAT. https://www.statnews.com/2026/04/08/trump-administration-drops-nih-indirect-cost-court-battle/

National Institutes of Health. (2025a, July 17). Revision: NIH policy and guidelines on the inclusion of women and minorities as subjects in clinical research (Notice No. NOT-OD-25-131). U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-131.html

National Institutes of Health. (2025b, August 15). Advancing NIH’s mission through a unified strategy [Statement]. U.S. Department of Health and Human Services. https://www.nih.gov/about-nih/nih-director/statements/advancing-nihs-mission-through-unified-strategy

National Institutes of Health. (2025c, November 18). Updated terms and conditions of award – Termination and compliance with court orders (Notice No. NOT-OD-26-009). U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-009.html

National Institutes of Health. (2025d, November 21). Funding decisions. U.S. Department of Health and Human Services. https://grants.nih.gov/grants-process/award/funding-decisions

National Institutes of Health. (2025e, August 25). Maximizing and safeguarding NIH’s investment in foreign collaborations [Statement]. U.S. Department of Health and Human Services. https://www.nih.gov/about-nih/nih-director/statements/maximizing-safeguarding-nihs-investment-foreign-collaborations

National Institutes of Health. (2025, November 21). Implementing a unified NIH funding strategy to guide consistent and clearer award decisions. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2025/11/implementing-a-unified-nih-funding-strategy-to-guide-consistent-and-clearer-award-decisions

Oza, A. (2026, March 17). NIH grant awards are again lagging far behind historical averages, analysis shows: Short on staff, the agency has focused on funding renewals rather than new grants. STAT. https://www.statnews.com/2026/03/17/nih-grant-funding-slowdown-new-awards-training-grants/

Trump, D. J. (2025a, January 20). Defending women from gender ideology extremism and restoring biological truth to the federal government (Executive Order No. 14168). The White House. https://www.whitehouse.gov/presidential-actions/2025/01/defending-women-from-gender-ideology-extremism-and-restoring-biological-truth-to-the-federal-government/

Trump, D. J. (2025b, August 7). Improving oversight of federal grantmaking (Executive Order). The White House. https://www.whitehouse.gov/presidential-actions/2025/08/improving-oversight-of-federal-grantmaking/