NIH recently issued an updated policy regarding foreign subawards which states that they are establishing a new award structure that will contain “a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report.” NIH anticipates implementing this on or before September 30, 2025.
This policy change applies prospectively to all NIH grants and cooperative agreements made to domestic and foreign entities (new, renewal and non-competing continuation). At this time, NIH is not retroactively revising ongoing awards to remove foreign subawards, and it will apply to all monetary foreign collaborations. NIH has indicated it does not apply to funds provided to support foreign consultants, or purchasing unique equipment or supplies from foreign vendors.
NIH has issued additional information entitled New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight, and National Security of NIH Funded Research:
Effective May 1, 2025, NIH will:
- Not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity.
- No longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.
- Renegotiate new, renewal or non-competing awards to remove subawards to foreign entities, and allow the funds to be rebudgeted for use by the prime recipient when the work can be performed domestically
- Work with the recipient to negotiate a bilateral termination if a project is no longer viable without the foreign subaward, taking into consideration any need to support participant safety and/or animal welfare.
ORA is developing a list of Frequently Asked Questions to help guide the research community during this evolving process change. These will soon be posted the IU Research Website in the Subaward section of Proposal Preparation Tools found within Funding & Proposal Support. Below is a select few that will be included:
Frequently Asked Questions
Q: I have a new/renewal proposal planned for an upcoming submission deadline – should I include the foreign subrecipient as planned?
A: NIH has not yet provided explicit guidance for proposal submissions; therefore, it is at the discretion of the PI/School to move forward with foreign subrecipients.
Q: Will foreign subrecipients already proposed and approved by NIH continue to be drafted by ORA for non-competing awards?
A: At this time, subrecipients already approved by NIH will continue to have their foreign subawards/amendments drafted for awards already in place.
Q: Should I formally remove my foreign subrecipient on a previously submitted proposal that is pending review with NIH?
A: NIH has not yet provided specific guidance on upcoming or pending proposals; however, they have indicated that there is a temporary pause on issuing awards that include a subaward to a foreign entity, and that they will renegotiate new, renewal or non-competing awards to remove subawards to foreign entities, and allow the funds to be re-budgeted for use by the prime recipient when the work can be performed domestically.
Q: Is NIH going to terminate my award because I have a foreign subaward doing work that cannot be done domestically?
A: NIH has indicated that they will work with the recipient to negotiate a bilateral termination if a project is no longer viable without the foreign subaward, taking into consideration any need to support participant safety and/or animal welfare.
Q: Should we notify our foreign subrecipients of these evolving changes?
A: ORA recommends reaching out to active foreign subrecipients to notify them of the current situation.
Q: Do our foreign subawards need to be terminated immediately?
A: No, NIH has indicated it will not retroactively revise ongoing awards to remove foreign subawards, but it is likely to occur before the next budget period is issued.
Q: What is a foreign component?
A: NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. Examples of other grant-related activities that may be significant are:
- collaborations with investigators at a foreign site anticipated to result in co-authorship;
- use of facilities or instrumentation at a foreign site; or
- receipt of financial support or resources from a foreign entity.
Foreign travel for consultation is not considered a foreign component. (See Grants to Foreign Organizations, International Organizations, and Domestic Grants with Foreign Components chapter in IIB).
Q: What if I need to add a foreign component to an existing award?
A: NIH is no longer accepting prior approval requests to add a new foreign component or foreign subaward to an ongoing project
Q: What if I need to request a foreign subrecipient be added to an active award that was not originally proposed?
A: NIH is no longer accepting prior approval requests to add a new foreign component or foreign subaward to an ongoing project
Questions can be emailed to ora@iu.edu.