Sent to all federal PIs, research associate deans, other academic leaders, and central and departmental research administrators.
Dear Research Colleagues,
On May 1, the National Institutes of Health (NIH) issued an Updated Policy on Foreign Subawards that significantly changes how foreign collaborations will be structured in NIH-funded research. NIH also released this short article that summarizes the new policy and provides additional guidance and resources for investigators impacted by these changes.
This new NIH policy may affect your current or future projects involving international partners.
Key Changes – Effective May 1, 2025
- Existing awards are not currently affected. NIH has stated that ongoing projects with active foreign subawards will not be retroactively impacted unless otherwise notified at this time. No action is needed unless NIH contacts you directly.
- Starting immediately, NIH will not approve new foreign subawards or components under existing grants. Ongoing awards with current foreign subrecipients are not impacted at this time.
- Foreign subawards will no longer be allowed in NIH’s new award structure. Institutions receiving NIH grants will not be permitted to issue subawards to organizations based outside of the United States.
- NIH anticipates that no later than September 30, 2025, it will implement a new award structure in which foreign collaborators will receive their own, separate awards directly from NIH. These awards will be formally linked to the main project but managed and tracked independently. Scientific progress may still be reported through the lead investigator's reporting process.
- The policy applies only to financial arrangements. It does not affect collaborations with foreign consultants or purchases of unique goods or services from international vendors.
What This Means for You
- If your new project includes a foreign subrecipient, this change will require restructuring the collaboration as an independent subproject rather than a subrecipient.
- If your ongoing project includes a foreign subrecipient, a restructuring of the collaboration with the foreign entity will be required at the time of renewal or non-competing continuation.
- NIH has not yet shared details on how the new “parallel award” model will work in practice. No public comment period is expected.
- For studies that rely on international fieldwork or expertise (e.g., infectious diseases endemic to specific regions), replacing foreign components with domestic partners may, or may not, be feasible.
Outstanding Questions Under Discussion Nationally
- How “foreign components” will be identified beyond subawards
- What formal agreements (e.g., CRADAs, MOUs) might be needed to define responsibilities between US and foreign collaborators
- Whether tools such as an FDP agreement template will become available
We understand this is a complex and evolving issue. If you believe your NIH-funded work may be affected, or if you are developing a proposal involving international collaborators, please contact SPA, your research associate dean, and your grants specialist early to plan accordingly.
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