Key Dates

Related Announcements

• January 21, 2026. NIH Requires Use of the eRA Prior Approval Module for the Submission of ALL Prior Approval Requests. See NOT-OD-26-026. 

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

This guide notice updates the NIH requirements for obtaining prior approval for changes to domestic subawards on all NIH grants and cooperative agreements. NIH has a longstanding policy of not requiring prior approval for the addition of domestic subawards to ongoing projects. This makes tracking and oversight of subawards challenging, and NIH needs to be aware of all subawards in order to effectively track compliance with the Federal Funding Accountability and Transparency Act (see NIH Grants Policy Statement 4.1.8).

Effective June 1, 2026, all prime recipients are required to obtain NIH prior approval when adding a new domestic subaward to a project post-award, when the arrangement was not originally a part of the peer-reviewed and approved application.

The new prior approval requirement is intended to ensure that NIH is aware of all subaward activities for each NIH project, so that NIH can monitor the prime recipient and ensure compliance with subaward monitoring and reporting requirements.

Requests must be submitted in the eRA Commons Prior Approval Module using the “Other Request” type.

As a reminder, effective May 1, 2025, NIH no longer recognizes foreign subawards. Recipients seeking to initiate a new international collaboration must utilize the new application structure for NIH-funded international collaborations (PF5/UF5). 

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration (OPERA)
[email protected]