Announcing New Application and Award Structure for NIH-Funded International Collaborations (Replacing Foreign Subawards)

NIH announced a new application and award structure last week for applications that request funding for international component organizations. Effective for due dates on or after January 25, 2026, competing applications must be in response to a funding opportunity using a new grant type when requesting NIH funding for one or more foreign components (NOT-OD-25-155).

This new award structure addresses a longstanding challenge related to transparency into NIH funding for international research, enhancing its integrity, accountability, oversight, and national security. We will continue to fund foreign components, as long as they are structured as independent subprojects. We will no longer support traditional foreign subawards.

We remain committed to supporting international scientific collaboration with foreign scientists, when conducted in a secure, justifiable, and responsible way. NIH takes very seriously proper stewardship of federal funds as well as any issues related to maintaining national security.

Our new international collaboration award structure continues to foster these goals, including aligning with the NIH Director Dr. Jayanta Bhattacharya’s fundamental principles guiding international collaborations. Amongst other points, he explains that “knowing exactly where every dollar is going and to whom is of paramount importance” so that our supported research continues to benefit the American public.

Recent History:

• May 2025: Effective with the next NIH award cycle, all NIH-funded research involving foreign subawards must be structured as subprojects directly linked to the prime award. See NOT-OD-25-104 and this NIH Extramural Nexus article.
• July 2025: Short-term solution implemented that allows recipients to remove a foreign subaward involving human subjects from an existing award and renegotiate it as an administrative supplement. See NOT-OD-25-130 and this NIH Extramural Nexus article.

Below are highlights on what this new structure means for the application and award processes:

• Applications:
  • Will use a new comprehensive multi-project funding opportunity (see Grants.gov forecast, funding opportunity expected to be issued by November 25, 2025).
  • Identify distinct principal investigators for the domestic applicant and at least one per international organization.
  • Foreign organizations must submit a letter of support saying they will fill the role of recipient organization for the disaggregated award.
• Peer Review:
  • Applications reviewed as a whole consistent with existing procedures.
  • Provides the project’s Overall Impact score (per this section of the NIH Grants Policy Statement).
  • Includes comments on the specific review criteria for each individual component.
• Awards:
  • Separates the International Project components from the domestic portion.
  • Each has distinct grant numbers available in RePORTER (PF5 or UF5 for domestic and RF2 or UL2 for foreign organizations.
• Oversight:
  • Follows the standard terms and conditions of award outlined in the NIH Grants Policy Statement.
• Reporting:
  • Coordination between partners to demonstrate progress towards meeting the project’s scientific aims.
  • Instructions aimed at streamlining and reducing the associated time, effort, and possible duplication with annual progress reporting.

We remain committed to supporting innovative research ideas within our mission, and recognize the need for continued international projects. From basic to clinical and translational studies, this step is not intended to limit any particular area of collaborative international activities or eligible organizations. Rather, it helps us ensure accountability for American taxpayer support in a thoughtful and proactive manner. Because the linked direct foreign award will have a separate award number and HHS Payment Management System subaccount for transparent financial reporting, we will have a clearer picture of the research being supported by all involved organizations. 

The prime applicant must be a domestic organization, which will help ensure the proposed projects advance the health of Americans. though foreign organizations cannot apply directly to this new funding structure, they may continue to apply using our traditional applications and instructions for other grant types if they meet the eligibility requirements. And, funding opportunities allowing foreign components may continue to accept applications with unfunded international collaborations or foreign components.

We appreciate the research community’s continued partnership throughout this process, which is pivotal for strengthening our combined oversight of foreign collaborations and research investments in support of the NIH mission. Please watch for additional information such as FAQs, trainings, and other resources.

Descriptions for the new grant types are on the NIH Activity Codes webpage:

• PF5: Collaborative International Research Project (awarded directly to domestic organization)
• UF5: Cooperative Agreement Equivalent
• RF2: Linked International Research Project (awarded directly to the foreign organization)
• UL2: Cooperative Agreement Equivalent