On May 1, the National Institutes of Health (NIH) announced that it will be establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant (NOT-OD-25-104). Under the new structure, expected to be implemented by September 30, 2025, NIH will fund foreign components that are structured as independent subprojects rather than subawards. The new policy will apply prospectively to all NIH grants and cooperative agreements (new, renewal, and non-competing continuations).
Until the details of the new award structure are released, 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.
These changes do not affect awards made directly to foreign institutions, funds to support foreign consultants, or purchases of unique equipment or supplies from foreign vendors.
More information will be coming from NIH in the coming months.