Notice of Information: NIH SBIR and STTR Foreign Disclosure Post-Award Requirements for Active SBIR and STTR Awardees (NOT-OD-25-102)

Effective immediately (April 29, 2025), the SBIR and STTR Foreign Disclosure and Risk Management Requirements described in NOT-OD-23-139 and NOT-OD-24-029 may be applied to all active SBIR and STTR awards regardless of the due date the competing application was submitted. Recipients with active awards that did not undergo foreign risk assessment at the time of their original application may be required to disclose all funded and unfunded relationships with foreign countries, using the Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form. If the recipient reports a covered foreign relationship that meets any of the risk criteria prohibiting funding, NIH may deem it necessary to terminate the award for material failure to comply with the federal statutes, regulations, or terms and conditions of the federal award.