Updated NIH Policy on Foreign Subawards
The Office of Contracts and Grants is providing the below information and guidance in response to the three notices released in the last year by the National Institutes of Health (NIH) related to foreign subawards:听听
NOT-OD-25-104 - 听
NOT-OD-25-130 - 听听
NOT-OD-25-155 - 听
What we know as of now:听
- This remains an evolving policy landscape. Implementation details regarding the three Notices are still being released. We expect continued updates and refinement of requirements and will keep campus updated as we learn more.听听
- The prime (domestic) institution retains key scientific reporting responsibilities. Even under the new structure, scientific progress across all components (including foreign partners) will continue to be reported collectively through the RPPR submitted by the prime recipient.听听
- The full scope of administrative/oversight responsibilities between prime and foreign awardees is still being clarified.听
- Because they receive funding directly, foreign entities are required to be fully registered in SAM.gov.听听
- As of September 25, 2025, NIH no longer accepts new applications that request funds for foreign components using the traditional grant subaward/consortium structure.听
What steps should we follow for now?听
- Coordinate early with OCG.听
- For PF5/UF5 or other complex applications, work closely with your assigned Proposal Analyst to ensure compliance with evolving structure and component requirements.听
- Expect additional documentation (e.g., foreign justification, component structure, registrations) for any international collaboration.听
- Disclose all foreign components clearly and completely (see NIH Notice ).
- Continue to follow NIH requirements to fully disclose any foreign involvement in proposals and RPPRs.
- Closely monitor any and all communication you receive from NIH. If you receive communication directly from NIH regarding a foreign subaward on an active project, please contact your assigned Grant Officer to coordinate a response.听
听NOT-OD-25-104 - 听
- Released on May 1, 2025, this Notice announced a pause on foreign subawards.听
- NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity.听
- Foreign subawards are no longer 鈥渘ested鈥 under the parent grant.听
- The new structure includes a prime domestic award with independent direct foreign awards that are linked to the prime award.听听
- This means that U.S. and international collaborators will be funded separately, with NIH funding foreign partners directly.听
NOT-OD-25-130 - 听
- Released on July 18, 2025, this Notice served as an update on the policy surrounding foreign subawards on active projects and submitted applications.
- This Notice is applicable to applications submitted before May 1, 2025, and projects active on or before May 1, 2025.听
- Gave NIH the option to renegotiate existing award structure with a prime awardee such that foreign subawards are financially removed from the primary award and awarded as administrative supplement awards.听
- Both the primary award and each foreign supplement must submit separate annual Federal Financial Reports (FFRs/SF-425s).听
- Funds cannot be transferred or rebudgeted between the primary award and foreign supplement(s) within a budget period.听
- This supplement approach is an additional option available to NIH Institutes and Centers and does not replace other actions available under NOT-OD-25-104, such as:听
- Moving foreign activities to a domestic organization听
- Removing the foreign component from the project scope听
- Bilaterally terminating the award听
- The supplement mechanism was intended only as a short-term approach for the current competitive segment.听
- This option did not replace the new award framework described in NOT-OD-25-104, which will apply to future applications and renewals.听
NOT-OD-25-155 - 听
- Released September 12, 2025, this Notice announced the new application and award structure for applications requesting funding for foreign component organizations.听
- Impacts on Applications:
- NIH will require competing applications that include one or more foreign components to be submitted under a Notice of Funding Opportunity (NOFO) that utilizes the new PF5 Activity Code for grants, the UF5 Activity Code for cooperative agreements, or another eligible complex mechanism activity code that supports an International Project component.听
- Utilizes NIH multi-component or complex application package (details found ).听
- The primary applicant organization must be a U.S.-based institution. The PF5 leadership team must include at least one PD/PI from the primary applicant organization and at least one individual from each International Project who will serve as the PD/PI for the corresponding Linked International Research Project award.听
- Impacts on Awards:听
- For the merit review process, the technical merit review will be the same as that of other multi-component applications.
- PF5/UF5 applications selected for funding consideration will be disaggregated, with each International Project component separated from the parent application.听
- Each International Project will be assigned its own grant number and awarded under an RF2 (grant) or UL2 (cooperative agreement) activity code.听
- The foreign institution will serve as the applicant and recipient of the RF2 or UL2 award rather than participating as a subrecipient.
- Both the domestic PF5/UF5 organization and the foreign RF2/UL2 organization must separately provide required JIT information, such as:听
- IRB approvals听
- IACUC approvals听
- Current and Pending (Other) Support for key personnel听
- Foreign applicants must ensure they are registered in SAM.gov, Grants.gov, and eRA Commons before award issuance if this has not already been completed.听
- If funded, NIH will issue:听
- A PF5 or UF5 award to the domestic organization听
- An RF2 or UL2 award directly to each participating foreign organization听
- Each award recipient will be responsible for meeting the terms and conditions of its own Notice of Award.听
Additional Resources:听
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