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16.8 Collaborative International Research Awards

16.8.1 General

This chapter highlights the policy requirements applicable to collaborative international research awards. To enhance transparency, strengthen financial oversight, protect U.S. national security interests, and ensure consistency across NIH and federal reporting systems, NIH utilizes a dedicated award structure for research grants and cooperative agreements that involve international collaborations. Unlike domestic collaborations supported through subrecipient agreements (see Consortium Agreements chapter), the Collaborative International Research Awards allow NIH to have a direct legal relationship with both the domestic and foreign collaborating organizations. Unless otherwise specified in this chapter, all policies contained in IIA, including the requirements of 2 CFR Part 200, also apply to collaborative international research awards.

16.8.2 Collaborative International Research Award Structure

The Collaborative International Research Awards will leverage the complex, multi-project application structure, where a single collaborative application will include separate application components (i.e., subprojects) for the domestic (U.S.-based) applicant and any international organizations. NIH will utilize designated activity codes (i.e., PF5 for grants, UF5 for cooperative agreements) to identify these multi-project applications and primary awards.

Prior to award, all international subprojects will be disaggregated and funded as separate RF2 grant awards (or UL2 cooperative agreement awards), in lieu of a foreign subaward. To manage compliance and track international funding, the NIH will award the RF2 directly to the foreign organization.

The original complex application (PF5/UF5) will be retained for the domestic applicant organization and any domestic subrecipients. The primary PF5/UF5 award and any disaggregated RF2/UL2 awards will maintain a link in NIH systems, allowing for collaborative reporting of scientific progress and programmatic oversight.

This approach allows NIH to adequately track funds to international organizations individually, which protects national security, while scientific progress is reported collectively.

16.8.3 Applicability

All research grants and cooperative agreements involving NIH-funded international collaborations must be submitted in response to a NOFO that is specifically designated for Collaborative International Research Awards. With this application and award structure in place, NIH no longer recognizes foreign subawards.

This requirement does not apply to foreign consultants, purchasing unique equipment or supplies from foreign vendors, or projects with non-monetary international collaborations, including use of equipment at a foreign site, or any foreign component that would not result in a foreign subaward.

16.8.4 Application Review and Award

Applications submitted under Collaborative International Research Award NOFOs will undergo peer review as a single integrated application. Because the international subproject components are intended to be funded as direct foreign awards, PF5/UF5 applications must be reviewed and approved by the IC The NIH organizational component responsible for a particular grant program or set of activities. The terms "NIH IC," or "awarding IC" are used throughout this document to designate a point of contact for advice and interpretation of grant requirements and to establish the focal point for requesting necessary prior approvals or changes in the terms and conditions of award. National Advisory Council or Board (see 16.3 Application Review .)

The primary PF5 or UF5 award and each linked RF2 or UL2 award will receive separate Notices of Award (NoA Notice of Award: The official, legally binding document, signed (or the electronic equivalent of signature) by a Grants Management Officer that: (1) notifies the recipient of the award of a grant; (2) contains or references all the terms and conditions of the grant and Federal funding limits and obligations; and, (3) provides the documentary basis for recording the obligation of Federal funds in the NIH accounting system.) and PMS subaccounts for financial tracking. To ensure timely and accurate information is received to address award requirements, NIH will utilize the Just-in-Time NIH policy allows the submission of certain elements of a competing application to be deferred until later in the application process, after review when the application is under consideration for funding. Within the Status module of the eRA Commons, users will find a feature to submit Just-In-Time information when requested by the NIH. Through this module, institutions can electronically submit the information that is requested after the review, but before award. See Completing the Pre-Award Process-Just-In-Time Procedures for additional information. Process for both the PF5/UF5 domestic organization applicants and RF2/UL2 foreign organization applicants (see 2.5.1. Just-in-Time Procedures for more information).

16.8.5 Public Policy Requirements

Upon disaggregation of the linked international subprojects, the RF2/UL2 awards will be treated as foreign grants. Therefore, the public policies requirements pertaining to all foreign grants, referenced in section 16.4 Public Policy Requirements and Objectives, apply to RF2 and UL2 awards. A complete listing of public policy requirements and applicability to domestic prime and linked international recipients is included in IIA (see section 4.1 Public Policy Requirements, Objectives, and Other Appropriation Mandates).

16.8.6 Allowable and Unallowable Costs

Collaborative international research awards are subject to NIHGPS Chapter 7 Cost Considerations, and the cost principles The government-wide principles, issued by OMB (or, in the case of commercial organizations, the Federal Acquisition Regulation [48 CFR 21], or, in the case of hospitals, 45 CFR 75, Appendix IX, "Principles For Determining Costs Applicable to Research and Development Under Grants and Contracts with Hospitals"), on allowability and unallowability of costs under federally sponsored agreements. See Cost Considerations-The Cost Principles for additional details. set forth in 2 CFR Part 200, Subpart E, with the exceptions for international subprojects provided under NIHGPS section 16.6 Allowable and Unallowable Costs.

For collaborative international research awards, the interaction between the domestic and international partners is not a subrecipient relationship. Therefore, costs associated with the international collaboration may not be included in MTDC when calculating indirect costs Necessary costs incurred by a recipient for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of F&A (indirect) costs. F&A (indirect) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived..

16.8.7 Administrative Requirements

Reporting

All activities supported by the collaborative international research award must be reported through the Research Performance Progress Report (RPPR) process. While both the primary domestic recipient and international recipient(s) will submit RPPRs, information does not have to be repeated. The primary domestic recipient will provide an attestation of support within the international recipient's RPPR confirming collaborative goals are being addressed. NIH will be responsible for monitoring the RPPRs to ensure consistency.

Each linked international award uses a distinct document number/PMS subaccount and is required to submit separate Federal Financial Reports (FFR). Rebudgeting of awarded funds is not permitted between the prime and linked international awards. Unless otherwise specified in the NOFO and/or Notice of Award "The official, legally binding document, signed (or the electronic equivalent of signature) by a Grants Management Officer that: (1) notifies the recipient of the award of a grant; (2) contains or references all the terms and conditions of the grant and Federal funding limits and obligations; and, (3) provides the documentary basis for recording the obligation of Federal funds in the NIH accounting system.", collaborative international research awards, including any linked awards, will be excluded from automatic carryover.

Both the prime domestic and linked international awards will be expected to complete the closeout requirement detailed in 8.6 Closeout .

Access to Records

• Linked international award recipients are required to provide access to copies of all lab notebooks, all data, and documentation that supports the research outcomes as described in the progress report, to NIH upon request, in accordance with 2 CFR 200.337.

Written Agreement

Collaborative research projects require planning and coordination to ensure that all parties can meet the goals and objectives of the research. Therefore, organizations working together on a collaborative international research project must establish written agreements prior to award. At a minimum, this agreement must include the following:

• Identification of roles and responsibilities of the individual(s) who will serve as the senior/key personnel at each site, as well as any other individuals responsible for elements of the research activity.
• Procedures for directing and monitoring the research effort.
• Procedures for managing disputes between the collaborative organizations and individuals on the project.
• A provision addressing ownership and disposition of data produced under the collaborative research award. This includes whether cell lines, samples or other resources will be freely available to other investigators in the scientific community or will be provided to particular investigators only.
• Expectations for authorship and co-authorship on publications.
• A provision requiring the linked international award recipients to provide access to copies of all lab notebooks, all data, and documentation that supports the research outcomes as described in the progress report, to the domestic (PF5/UF5) award recipient with a frequency of no less than annually, in alignment with the reporting requirements for the RPPR. Such access may be entirely electronic.

While the framework for the collaborative international research written agreements may leverage elements of consortium written agreements, because the domestic institution will not be serving as a pass-through entity, terms implementing the financial and administrative oversight requirements of subrecipients by pass-through entities, as detailed in 2 CFR 200.332, is not appropriate to include in the collaborative international research award agreement.