Policy Library

NIH Policy on Foreign Subawards

Effective Date: May 1, 2025
Updated: August 15, 2025 
Notice Number: NOT-OD-25-104 & NOT-OD-25-130
PDF

UPDATE - August 2025

NIH has temporarily reversed course and will continue to accept applications with foreign subawards for due dates on or before September 24, 2025. If your application is considered for funding, the relevant NIH Institute, Center, or Office will contact the University to address foreign subawards as described in NOT-OD-25-104 and NOT-OD-25-130. If a negotiated agreement regarding foreign subawards cannot be reached, the award will not be issued. 

At this time, it remains unclear how long foreign subawards will be permissible in proposal submissions beyond the current date. Therefore, when appropriate and possible, we recommend considering the inclusion of foreign collaborators as vendors, consultants, or unpaid collaborators rather than subawardees. 

Please contact URA Pre-Award if you have questions or need assistance with your proposal planning. 

ORIGINAL POLICY NOTICE

Key Changes: 

NIH will no longer allow foreign subawards under parent NIH grants. Instead, foreign entities will receive their own award linked to the main (prime) grant, to increase transparency, accountability, and national security. 

Policy Overview 

  • Recipients must not include foreign subawards on NIH proposals. Applications with outgoing foreign subawards will be withdrawn by NIH without further review. 
  • Foreign organizations will receive separate awards directly from NIH, linked to the primary (prime) grant. 
  • The prime (domestic) institution will still report project progress collectively. 
  • This new approach ensures NIH can easily track spending by each entity. 

Applicability 

  • Applies to all new, renewal, and non-competing continuation NIH grants and cooperative agreements (domestic and foreign entities). 
  • Does not retroactively affect current or ongoing awards, unless extended due to the addition of funding or time. 
  • Direct foreign awards (where a foreign institution is the primary recipient) are still allowed. 
  • Applies only to international monetary collaborations, not to hiring consultants or purchasing goods/services from foreign vendors. 
  • May be expanded to domestic subawards in the future. 

Implementation Timeline 

  • Full transition to the new award structure by September 30, 2025. 
  • No new awards or approval of new grants with a foreign subaward will be issued between now and full implementation. 
  • No approval for adding foreign subawards to ongoing projects. 
  • Ongoing awards can be renegotiated to: 
    • Remove foreign subawards, redirecting funds domestically, or 
    • End the project if continuation is not viable without a foreign subaward (NIH will facilitate responsible closeout). 

Procedures and Guidance 

At Proposal and/or JIT Stage 

  • Proposals must not include outgoing foreign subawards. 
  • NIH may request budget revisions to remove outgoing foreign subawards.  
  • For any planned paid foreign collaboration or questions at pre-award stage, contact the URA Pre-Award Team for guidance. 

At Award Stage 

For Competing Applications submitted before May 1, 2025: 

  • NIH will negotiate with applicants to: 
    • Remove foreign subaward activities (funds may be reduced). 
    • Allow the main recipient or a U.S. institution to perform the work (funds may be rebudgeted). 
    • For human subject projects: Possibly use a separate Type 3 supplement award for the foreign entity, with strict financial tracking. 
    • For any foreign collaborations or questions at post-award stage, contact the URA Post-Award Team for guidance. 

For Non-Competing Continuations & No Cost Extensions: 

  • NIH may: 
    • Remove all foreign subaward activities (associated funds are restricted and cannot be rebudgeted). 
    • Allow the prime or a domestic subrecipient to complete the work (funds may be rebudgeted, with additional F&A if applicable). 
    • In select human/clinical research cases: Issue a separate administrative (Type 3) supplement award directly to the foreign entity to facilitate NIH’s distinct financial tracking. Both the primary award and Type 3 supplement will be removed from SNAP and automatic carryover authority. 

Special Considerations for Human/Animal Subjects: 

  • Up to 6 months permitted for phaseout of human subject research (extensions require strong justification). 
  • Up to 60 days permitted for animal studies. 
  • If agreement cannot be reached, NIH may terminate the award, preserving limited funding for responsible closeout and subject welfare. 

Other Notes 

  • Notices of Funding Opportunities (NOFOs) involving foreign components are now superseded; NIH will update NOFOs to reflect these changes. 
  • Policy applies only to monetary subawards (not foreign consultants or vendors). Consultants are paid for services and are not responsible for project aims. Vendors provide goods and services and do not pursue scientific aims.  

Examples of Allowable and Unallowable Activity 

Allowable 

  • Paying an overseas company for lab reagents or sequencing (vendor) 
  • Inviting an international expert to give a seminar (consultant) 

Not Allowed 

  • Issuing a subaward to a foreign university to conduct a specific scientific aim of the NIH parent award 

Key Points 

  • Any applications to NIH submitted after May 1, 2025, with foreign subaward budget lines will be administratively withdrawn prior to review. 
  • Under no circumstances should a foreign subaward be released under a proposal submitted after the effective date—even when prior written approval has been obtained. 
  • Reach out to your colleagues in University Research Administration before engaging any foreign entity. 

Need Help? 

  • Contact your URA Pre-Award or Post-Award Teams for guidance on paid foreign collaborations. 
  • Refer to official NIH updates for all future guidance and forms. 

Source: NIH Notice NOT-OD-25-104 | For institutional use only.