Recently we have been sending out amendments to all foreign subawards of NIH grants. These amendments are a result of NIH updating its Grants Policy Statement, section 15.2. NIH has required us to amend all of our foreign subawards to include this language within 60 days. Review the policy, and be sure to add the following language to each subaward:
“The Subrecipient acknowledges and accepts the provisions of NIH Grants Policy Statement, section 15.2.1, requiring that international subrecipients provide access to copies of all lab notebooks, all data, and all documentation associated with the research described in the progress report to the primary funding recipient and in alignment with the progress report submission requirements, but on no less than an annual basis. Subrecipient may provide access either electronically or physically.”
As this is a requirement by NIH, the sub-recipient must accept this provision or the subaward will need to be terminated.