Updates and Reminders on NIH Policy Pertaining to Grants to Foreign Institutions, International Organizations and Domestic Grants with Foreign Components

Notice Number: NOT-OD-09-010

Key Dates
Release Date: October 8, 2008

Issued by
National Institutes of Health (NIH), (http://www.nih.gov)


NIH awards grants to foreign institutions, international organizations and domestic institutions with foreign components. The purpose of this Guide Notice is to announce policy and restate and clarify existing policies, highlighting some of the unique features pertaining to this cohort of NIH grantees.

Announcing Policy on the Allowability of Minor Alterations and Renovations (A&R) Costs

Revised DHHS policy now states that costs for minor A&R (<$500,000) are generally allowed on grants made to foreign organizations or to domestic institutions with foreign components, unless prohibited by the governing statute or implementing program regulations. For applications submitted to NIH minor A&R costs may now be included and justified in any detailed budget of a competing application. Further, rebudgeting to accommodate minor A&R is now also allowable; however, this does require NIH prior approval of the Grants Management Officer (GMO). This policy is effective immediately for all active grants. 

Costs for major A&R (>$500,000) remain unallowable.

A&R is defined as work that changes the interior arrangement or other physical characteristics of an existing facility.  This does not include the configuration of shell space (space constructed to meet future needs and unfinished inside) for initial use. It is important to note that the NIH Grants Policy Statement (Part II; Subpart B:  Terms and Conditions for Specific Types of Grants, Grantees, and Activities; Construction Grants; Alteration and Renovation Projects under Nonconstruction Grants) has policies that must be followed to use funds for alterations and renovations costs.


Application Review Criteria for Grant Applications for Foreign Institutions and International Organizations
Applications from foreign institutions and international organizations are evaluated and scored during the initial review process using the standard review criteria. In addition, the following is assessed as part of the review process and award decision: 1) whether the project presents special opportunities for furthering research programs through the use of unusual talents, resources, populations, or environmental conditions in other countries that are not readily available in the United States or that augment existing U.S. resources; and, 2) whether the proposed project has specific relevance to the mission and objectives of the NIH Institute/Center (IC) and has the potential for significantly advancing the health sciences in the United States and the health of the people of the United States. Note these additional criteria are not applied to applications from domestic institutions with foreign components.

Requirement for Detailed (Non-modular) Budgets
All competing grant applications from foreign (non-U.S.) institutions must include detailed (non-modular) budgets. (See NIH Guide Notice NOT-OD-06-096). This does not apply to applications submitted by domestic institutions with a foreign subaward; those institutions must follow existing NIH policy to determine whether a detailed or modular budget should be submitted. Note, a detailed subaward/consortium budget component is required only when the prime grantee is submitting a detailed budget.  The Notice of Award will indicate if a detailed budget is required in the future years of the project.

Generally, NIH pays foreign institutions and international organizations by U.S. Treasury check issued by the NIH Office of Financial Management (OFM) on a predetermined quarterly advance basis, usually in four equal installments. Foreign grantees are strongly encouraged to use U.S. banks to ensure that payments arrive on time. Grantees are required to maintain grant funds in an interest bearing account; however, interest earned in excess of $250 per year in the aggregate on advances of Federal funds must be returned in U.S. dollars by reimbursement check to the NIH Office of Financial Management at the address below, or reflected on the annual Financial Status Report.

National Institutes of Health
Office of Financial Management
Government Accounting Branch
Attention: Joyce Lee
2115 East Jefferson Street MSC 8500, Suite 4B432
Rockville, MD 20852

Annual Financial Status Reports
Foreign institutions and international organizations must submit financial status reports (FSRs) annually. All FSRs must be submitted electronically using the electronic FSR system located in the eRA Commons (See NOT-OD-07-078). FSRs must be submitted in U.S. dollars and must be in English. The currency rate in effect at the time the FSR is prepared should be used in preparing the report.

For the final FSR, NIH requires grantees to reimburse the U.S. government for funds not spent. Mail reimbursement checks in U.S. dollars to the OFM at the address noted above. The OFM will process the final FSR along with the final reimbursement check.

Transfer of Grant or Grant Component
All change of grantee organizations, require NIH prior approval.  The transfer of a grant to a foreign organization or between foreign organizations requires the additional approval of the National Advisory Council/Board of the awarding NIH IC.

Grantees adding or changing a foreign performance site within a funded grant award must obtain approval from the GMO before work can be performed at the added or changed foreign site. 

Allowable Facilities & Administrative (F&A) costs
NIH provides limited F&A costs (8 percent of modified total direct costs less equipment) to foreign institutions and international organizations to support the costs of compliance with DHHS and NIH requirements including, but not limited to, protection of human subjects, animal welfare, invention reporting, financial conflict of interest and research misconduct. NIH will not support the acquisition of, or provide for depreciation on, any capital expenditures, or support the normal, general operations of foreign and international organizations. Other administrative costs may be requested and justified as direct costs.

Unallowable Costs

Audit Requirements
Foreign grantees are subject to the same audit requirements as for-profit organizations (specified in 45 CFR 74.26(d) and in the section Grants to For-Profit Organizations in the NIH Grants Policy Statement).

Intellectual Property Rights and Obligations
Regarding intellectual property, NIH allows foreign grantees to have the same rights and obligations regarding invention ownership as U.S. grantees. NIH allows foreign entities to retain rights in intellectual property developed under NIH funding agreements (grants, cooperative agreements, contracts and subcontracts), consistent with current NIH policies and any other terms and conditions of the specific funding agreement awarded. NIH believes that the current policy protects the U.S. public's interest while not unduly compromising productive research and intellectual property relationships. (See NIH Guide Notice NOT-OD-06-005).

All foreign grantees, contractors, consortium participants, and/or subcontractors are reminded that they must comply with Bayh-Dole invention reporting requirements. Information on reporting requirements and policy, as well as electronic systems to fulfill reporting requirements may be found at Interagency Edison http://www.iedison.gov, as well as at http://inventions.nih.gov.

Further information on grants to foreign institutions, international organizations and domestic grants with foreign components is found in the NIH Grants Policy Statement.


Grant-specific inquiries should be addressed to the Grants Management Specialist and/or Program Official assigned to the grant. 

General inquiries about policies for grants to foreign institutions or international organizations may be directed to:

Division of Grants Policy
Office of Policy for Extramural Research Administration
National Institutes of Health
6705 Rockledge Drive, Suite 350
Bethesda, MD 20892
Telephone: (301) 435-0938
Email: GrantsPolicy@od.nih.gov

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