The Office for Research Administration (ORA) has received several inquiries about the new NIH requirement for foreign subrecipients. We have added sample language on our website for foreign subrecipient investigators to use in their Letter of Support, which ORA strongly encourages units to include in the NIH application. We have also included acknowledgement language by the entity’s Authorized Organization Representative (AOR) in the Subrecipient Letter of Commitment: Foreign Subrecipient on NIH Funded Applications and on the Subrecipient Commitment Form.
Both the foreign subrecipient investigator and the AOR must acknowledge a willingness to abide by NIH’s NOT-OD-23-182 in their Letter of Support and/or Commitment document. These document must be routed to ORA as part of the subrecipient packet, and ORA strongly encourages that they also be attached to the NIH application. An unwillingness by the foreign entity to acknowledge the requirements will result in the institution needing to be listed as To Be Determined (TBD) throughout the proposal documentation.
Proposal requirements for subawards
If your proposal includes a subaward, the Office for Research Administration will need the following from the subawardee institution:
- Budget
- Budget justification or budget narrative
- Statement of work to be performed by subawardee
- A document with an authorizing official signature (usually from the sponsored projects office) illustrating their commitment to the proposal – this can be submitted on Letter of Commitment, Subrecipient Commitment Form, or Sponsor Cover Page
- A copy of the Subawardee's F&A rate agreement or hyperlink to their rate agreement (if applicable)
- NIH applications with foreign subrecipients must include a Letter of Support from the subrecipient PI for with a statement acknowledging their willingness to abide by NIH NOT-OD-23-182 as part of the NIH application. Specifically, we recommend international subrecipients use the following language in their letter of support when they will be included in NIH proposals:
By signing this subrecipient letter of support, [subrecipient PI name] agrees to provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report, to [primary recipient] with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report. Such access may be entirely electronic.
Please contact iuprop@iu.edu with any questions