Per NIH Guide Notice NOT-OD-25-104, the National Institutes of Health (NIH) is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant for all new, renewal and non-competing continuations.
Until further notice, CWRU principal investigators (PIs) must not include foreign subcontracts in their grant applications as we do not have clear guidance on how to submit proposals following the new regulations.
Key points of the new policy:
- The new award structure will be implemented no later than Sept. 30, 2025, prior to Fiscal Year 2026.
- NIH will not retroactively revise ongoing awards to remove foreign subawards at this time.
- NIH will not issue new, renewal or non-competing continuation awards to domestic or foreign entities that include a subaward to a foreign entity.
- NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.
- This change does not apply to funds provided to support foreign consultants, or purchasing unique equipment or supplies from foreign vendors.
- Until the details of the new foreign collaboration award structure are released, 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.