Key Dates

Related Announcements

• May 1, 2025 - Updated NIH Policy on Foreign Subawards. See Notice NOT-OD-25-104.

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

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.

Policy

Taking into consideration concerns for patient safety risks for ongoing projects, NIH recognized the need to identify an alternative approach for removing the foreign subawards from existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) at the foreign site. As a result, NIH Institutes, Centers, and Offices (ICOs) will have the option to renegotiate the award structure with a recipient such that foreign subawards are financially removed from the primary award and awarded as administrative supplement (i.e., Type 3) awards. Each foreign supplement award will only include funds allocated for a single foreign entity, allowing NIH better ability to track obligations to foreign entities.

To ensure NIH's financial management and reporting goals will be met from this structure, both the primary award and foreign supplement(s) will be removed from the streamlined non-competing award process (SNAP) and automatic carryover authority. The primary award and each foreign supplement will be issued with a distinct document number and will need to submit separate annual Federal Financial Reports (FFR, SF-425). There will be no rebudgeting allowed between the primary award and supplements within a budget period, although recipients may use the annual RPPR process as an opportunity to request a reallocation of future year commitments between the primary and foreign supplement awards, provided the total cost across all awards does not exceed previous committed levels.

This supplement option is in addition to, and not in lieu of, the other options outlined in NOT-OD-25-104; namely, ICOs may renegotiate with the primary recipients to move activities to a domestic organization, remove the scope of the foreign component from the overall project scope, or bilaterally terminate the award. Additionally, this supplement option is meant to be a short-term solution, permitted only for the current competitive segment, and it does not replace the new award structure announced in NOT-OD-25-104 that will apply to upcoming applications, including any planned renewals. 

Inquiries

Please direct all inquiries to:

NIH Office of Policy for Extramural Research Administration

[email protected]