Sent to all federal PIs, research associate deans, other academic leaders, and central and departmental research administrators.
In May 2025, the National Institutes of Health (NIH) announced that it would no longer be accepting new applications that request funds for foreign components using the traditional grant subaward/consortium structure. (See our May 8 memo on this topic.)
On September 12, NIH issued a Notice on the New Application Structure for NIH-Funded International Collaborations (NOT-OD-25-155) to provide additional direction on how international collaborations will be structured in applications under the new foreign subawards policy. The new policy is summarized below.
New Policy
- NIH will no longer accept foreign component funding through traditional subawards or consortia agreements.
- New applications for funding that include foreign components must follow the PF5 (for grants) or UF5 (for cooperative agreements) Activity Codes, or other complex activity codes that support an International Component, as specified in the relevant Notice of Funding Opportunity (NOFO).
- Foreign components that were previously funded under subawards (e.g., consultants, international travel) can still be supported through other activity codes, unless specified otherwise.
Application Structure
- Applications will require multiple components:
- Overall Component – Addresses the overall project objectives.
- Research Project Component – Details the scientific aspects of the project.
- International Project Component – Describes the role of foreign collaborators.
- Applications with multiple foreign collaborators must include a separate International Project Component for each collaborator.
- The primary applicant organization must be U.S.-based and include at least one PD/PI (Principal Investigator) from the U.S. organization.
Review and Evaluation
- Reviewers will assess the overall project and specific components, including evaluating the uniqueness and relevance of the foreign collaborator’s contributions.
- Each International Project Component will be evaluated based on:
- Whether the project presents special opportunities that are not readily available in the U.S. or that augment existing U.S. resources.
- Whether the proposed project has specific relevance to the mission and objectives of the NIH Institute/Center and the potential for advancing U.S. health sciences.
All PF5/UF5 applications will also undergo advisory council or board review consistent with current procedures for foreign organizations.
Award Structure
- After review, the PF5/UF5 application will be split into separate grants for the U.S. and foreign organizations. The U.S. organization receives a PF5 or UF5 award, and the foreign partner receives an RF2 (Linked International Research Project Grant) or UL2 (Linked International Cooperative Agreement).
- Both the U.S. and foreign organizations will be responsible for meeting the terms of their individual awards.
Note: Disaggregation does not guarantee that all components will be funded; NIH may fund all, none, or some components based on merit, Just-in-Time (JIT) materials, and agency priorities.
Reporting
- NIH is working on updating progress reporting systems (e.g., RPPR) to streamline coordination and reduce administrative burden, with new instructions to be provided in the Notice of Award.
- Financial reporting for each organization will be handled separately.
These changes aim to improve oversight, ensure proper tracking of federal funds, and streamline the management of international collaborations.
For additional questions, contact April Coon at [email protected].
Please continue to visit our SPA Federal Executive Orders and Other Policy Directives website for the most up-to-date guidance.
Sincerely,
April Coon, Director, Sponsored Projects Administration
David Hagen, Director, Office of Cost Analysis