Announcement: The National Institutes of Health (NIH) has announced a significant update regarding foreign subawards, as detailed in Notice NOT-OD-25-104, released on May 1, 2025. This change aims to enhance transparency and align with federal reporting requirements, particularly concerning national security considerations.
Key Highlights:
- Development of a New Award Structure: NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report. NIH anticipates implementing the new award structure by not later than September 30, 2025, prior to Fiscal Year 2026.
- Scope and Applicability: The policy applies prospectively to all NIH grants and cooperative agreements to domestic and foreign entities (new, renewal and non-competing continuation). NIH will not retroactively revise ongoing awards to remove foreign subawards at this time. The policy excludes funds allocated for foreign consultants or the procurement of unique equipment or supplies from foreign vendors.
- Prohibition of Foreign Subawards in New, Renewal or Non-Competing Continuation: Effective May 1, 2025 and until the details of the new foreign collaboration award structure are released, NIH will not issue awards (new, renewal or non-competing continuation), that include a subaward to a foreign entity. Additionally, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.
- Ability to Renegotiate Scopes: In all cases, NIH will allow Institutes, Centers and Offices (ICOs) to renegotiate awards, whether new, renewal or non-competing, to remove subawards to foreign entities and, where the work can be performed domestically, allow the funds to be rebudgeted for use by the prime recipient (domestic or foreign) or a domestic subrecipient. If a project is no longer viable without the foreign subaward, NIH will work with the recipient to negotiate a bilateral termination of the project, taking into consideration any need to support patient safety and/or animal welfare.
Next Steps for Researchers:
Please review current and planned collaborations with foreign entities to determine if a scope re-negotiation might be necessary. If so, please reach out to your DCG officer and they will assist in submitting a revised scope of work. DCG will also be reaching out to affected schools and faculty with currently active international subawards under NIH funding to provide guidance and assist.
Questions? If you have any questions, please feel free to contact your DCG Officer.