Guidance of NIH Policy on Foreign Subawards for Active Projects

Fri, 25 Jul 2025 17:02:48 -0400

-- Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects

Notice Number: NOT-OD-25-130

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-130.html

Purpose

As previously noted in NOT-OD-25-104, NIH must ensure it can transparently and reliably report on each dollar spent on foreign collaborations. The current subaward structure does not allow for consistent reporting and accurate tracking; therefore, NIH will not issue awards to domestic or foreign entities (new, renewal, or non-competing continuation) that include a subaward to a foreign entity. This Guide Notice updates the policy concerning existing projects and submitted applications.

Applicability

This Guide Notice addresses the implementation of the NIH Policy on Foreign Subawards (See NOT-OD-25-104) for applications submitted before May 1, 2025, and projects active on or before May 1, 2025.

Please refer to the full notice linked above for further details.

Should you have any questions, please contact the Office of Sponsored Programs.

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-- Updated NIH Policy on Foreign Subawards

Notice Number: NOT-OD-25-104

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html

Purpose

This Guide Notice updates NIH policies and practices utilizing foreign subawards. NIH recognizes that some recipients do not accurately report on subawards consistent with Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements (NIH GPS 8.4.1.5.5), which state that recipients must report on all subawards/subcontracts/consortiums equal to or greater than $30,000. This includes awards that are initially below $30,000 but subsequent grant modifications result in an award equal to or greater than $30,000. This lack of transparency is particularly concerning in the case of foreign subawards, in which the United States government has a need to maintain national security.

In an effort to maintain strong, productive, and secure foreign collaborations in support of the NIH mission, NIH must ensure it can transparently and reliably report on each dollar spent. Therefore, NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report. NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026.

Please refer to the full notice linked above for further details.

Should you have any questions, please contact the Office of Sponsored Programs.