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National Institutes of Health

Updated policy guidance for subaward/consortium written agreements with foreign institutions

Beginning January 2, 2024, the National Institutes of Health will require that foreign subrecipients provide the primary recipient access to copies of all lab notebooks, data and documentation that supports the research outcomes described in the progress report.

This was outlined in NOT-OD-23-182 NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreements. Access, which can be electronic, must be provided at least once per year, in alignment with the timing requirements for Research Performance Progress Reports (RPPR).

Two important issues to be aware of:

  1. The access requirement applies to all foreign subawards, both new and active.
  2. For all proposals submitted on or after January 2, NIH expects applicants to ask potential subrecipients to submit language in their letters of support indicating their awareness of these requirements and their willingness to abide by all requirements should an award be issued.

While this additional requirement will impact a relatively small number of investigators, it does present challenges that will take time and resources to implement. To support affected investigators, the Office of Sponsored Programs (OSP) is working to develop guidance documents and revised subaward agreement and letter of support language, which will be provided in the coming weeks.

Meanwhile, contact Laurie Rosenberg, OSP subaward lead, with questions at