Update: The National Institutes of Health (NIH) have begun to implement new requirements for outgoing subawards, effective January 1st as set forth in NOT-OD-23-182. The new policy requires that foreign subrecipients clearly commit (at time of proposal) to abide by all requirements set forth in the solicitation, including but not limited to, the requirement to provide the USC PI access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, in alignment with the timing requirements for Research Performance Progress Report submission (but not less frequently than annually). In order to ensure compliance, PI’s and Research Administrators will need to take the following actions for any foreign subawards under NIH funding:
- At Proposal Stage: A letter of commitment and/or a signed Subaward Certification Form signed by an authorized representative of the Subrecipient institution is required at the time of proposal for all named subrecipients. The Subaward Certification Form has been updated to collect the appropriate assurances in order to comply with the new NIH policy. For all Letters of Commitment provided by foreign subrecipients, please ensure that a statement including the following is included in order to ensure compliance with the new NIH policy:
Subrecipient has carefully reviewed the requirements set forth in the solicitation and is aware of these requirements and is willing to abide by all requirements, should an award be issued. The Subrecipient understands that they shall be expected, not less frequently than once per year and/or upon request of the PTE or Prime Sponsor to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report to the primary recipient, in alignment with the timing requirements for Research Performance Progress Report submission but with a frequency of no less than once per year.
- Post-Award Monitoring by PI: Currently, the PI is already required to review and approve all invoices, progress, technical and financial reports provided by subrecipients to verify subrecipient compliance. In order to ensure compliance with the new NIH policy, the PI will also be provided with (and expected to review all) lab notebooks, all data and all documentation that supports the progress/technical reports on foreign subawards, not less frequently than annually.