On July 18, 2025, the National Institutes of Health (NIH) issued an update to its foreign subaward policy through Guide Notice NOT-OD-25-130, expanding on the previously released NOT-OD-25-104. This update provides important implementation guidance for NIH-funded projects that were active or had applications submitted prior to May 1, 2025.
As a reminder, the NIH will no longer issue new, renewal, or non-competing continuation awards to domestic or foreign institutions that include subawards to foreign entities. This updated guidance expands on how NIH may handle foreign subawards on existing awards, particularly in the context of human subjects research.
To maintain accurate financial tracking while minimizing disruptions to ongoing research, NIH Institutes, Centers, and Offices now have the additional option to financially remove foreign subawards from the primary award and instead fund them via separate administrative supplements (Type 3 awards). Each supplement will be limited to a single foreign entity and will be issued as a standalone award with its own document number.
Please note the following important characteristics for these awards and supplements:
- Both the primary award and foreign supplement(s) will be excluded from SNAP and automatic carryover authority.
- Each award will require its own annual Federal Financial Report (FFR, SF-425).
- No rebudgeting is allowed between the primary award and supplement(s) within a given budget period.
- Future year reallocations may be requested through the annual RPPR, as long as the total cost does not exceed previously committed levels.
This administrative supplement approach is in addition to the other options listed in NOT-OD-25-104 and intended as a short-term solution for the current competitive segment only. Other options previously outlined remain available, including:
- Shifting foreign activities to a domestic institution
- Removing foreign components from the scope of work
- Bilateral award termination
For additional details, refer to the full guide notice here: NOT-OD-25-130.