NIH Notice NOT-OD-25-104 – Updated NIH Policy on Foreign Subawards was released on May 1, 2025, with a follow-up article New NIH Foreign Subaward Structure Enhances Integrity, Accountability, Oversight and National Security of NIH Funded Research today, May 7, 2025. 

New NIH Award Structure:  NIH is planning to establish a new award structure that prohibits foreign subawards from been “nested” under the parent award.  Instead, NIH will enter into a relationship directly with the foreign subrecipient.  This new structure will allow a prime award to the U.S. institution, which will be linked to an independent foreign “subaward/subproject”, enabling separate financial tracking.  Scientific reporting will remain consolidated in the annual RPPR to be prepared and submitted by the Prime Recipient. 

Implementation Timeline:  The new award structure is anticipated to be implemented by no later than September 30, 2025 (before the government’s FY26 begins)

Applicability: 

• The policy applies prospectively to all NIH grants and cooperative agreements to domestic and foreign entities (new, renewal, and non-competing continuations).  
• The policy does not apply retroactively, i.e., existing awards will not be revised to remove foreign subawards during their current active budget period.
• Effective May 1, 2025, and until the details of the new foreign collaboration award structure are released:
• NIH will not issue awards to domestic or foreign entities (new, renewal, or non-competing continuations) that include foreign subawards.
• NIH will no longer approve requests to add new foreign components / subawards to ongoing awards
• NIH Institutes, Centers and Offices (ICOs) may renegotiate awards (new, renewals, or non-competing continuations) to either:
• re-budget funds to domestic partners or Prime Recipient, if work can be done domestically, OR
• negotiate a bilateral termination of the project, if foreign work is essential and cannot be relocated domestically, taking into consideration any need to support patient safety and/or animal welfare.

Exceptions:  The policy does not apply to:

• Foreign consultants
• Purchase of unique equipment or supplies from foreign vendors
• Direct foreign awards (still supported).

Additional Guidance:

• This policy supersedes existing Notices of Funding Opportunities (NOFOs) that allow foreign components / subrecipients.
• NIH is planning to revise NOFOs to reflect the new award structure. 
• Awards for proposals already submitted, that include foreign subawards, may not be issued until after the new NIH structure is in place.  The PI(s) should be aware that they may need to rescope the project to remove the foreign subaward OR find a domestic subrecipient that could perform the work in place of the foreign one.
• It is not yet clear how proposals to be submitted to NIH now and in the new future will be handled if they include foreign subawards.  For now and until further guidance is provided by NIH, if foreign subawards are to be included in a proposal, we strongly recommend that the PI discusses the concept with their Program Officer.  If the Program Officer allows the inclusion of a foreign component / subrecipient in the proposal, the PI should prepare a very strong justification as to why the foreign entity was chosen over a domestic one.  In all other cases, the PIs are discouraged from including foreign components / subrecipients in their proposal(s).
• If an award (new, non-competing continuation, or renewal) has already been issued on or prior to May 1, 2025, and includes foreign subaward(s), the issuance of such subaward(s), or their modification, can be processed only for this active budget period.  However, please be aware that at the time of the next budget period (non-competing continuation), NIH may required negotiations to either:
• remove the foreign subaward(s), if a domestic partner can be found instead, OR
• the subaward to the foreign entity will be handled based on the upcoming new NIH award structure.

Institutional Guidance:

• If NIH requests rescoping of a pending award involving foreign subawards, you must notify your RSP GS immediately.

Further information / clarification will be provided once it becomes available.