Updated NIH Policy on Foreign Subawards (NOT-OD-25-104)

Issued May 1, 2025. Prospectively updates NIH policies and practices for utilizing foreign subawards. Per the notice, 'NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime [with independent linked awards] that will allow NIH to track the project's funds individually while scientific progress will be reported collectively by the primary institution under the Research Performance Progress Report.' NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026. The policy continues to support direct foreign awards and plans to expand this policy to domestic subawards in the future, for consistency.