New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight, and National Security of NIH Funded Research

Effective with the next NIH award cycle, all NIH-funded research involving foreign subawards must be structured as subprojects directly linked to the prime award. Foreign subawards are prohibited from being nested under the parent grant.

Guide Notice NOT-OD-25-104 prospectively updates NIH policies and practices for utilizing foreign subawards. This step helps us enhance the tracking of foreign subawards, consistency across reporting systems, and protect national security of the biomedical research enterprise. Reports from the U.S. Government Accountability Office, concerns raised by Congress, and internal system inconsistencies further highlight the need for this policy change.

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.

This is a temporary pause for foreign subawards, while NIH finalizes the implementation of the new award structure (expected no later than September 30, 2025). The clearer structures and safeguards seek to enhance transparency, trackability, and protect national security in the areas of both monetary and non-monetary foreign collaborations.

What this means going forward?

We remain committed to supporting international scientific collaboration with foreign scientists, when conducted in a secure, justifiable, and responsible way. We will continue to fund foreign components, as long as they are structured as independent subprojects rather than subawards. Applicants may reapply for future awards with subproject structures as well.

We encourage recipients and their researchers prepare. Options could include moving research to the U.S. if possible, pause on-going research and reapply under the new subproject structure, or begin winding down the project. Keep in mind that continuing these awards under the current subaward model is not an option.

And for research involving human participants or laboratory animals that may be affected, we will provide funds for safe and orderly shutdowns at foreign sites to maintain participant safety and privacy or animal welfare.

We appreciate the research community’s continued partnership throughout this process, which is pivotal for strengthening our combined oversight of foreign collaborations and research investments.

Resources:

• NIH Director’s statement
• Subawards: NIH Grants and Funding website
• Information for Foreign Grants: NIH Grants and Funding website