Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects (NOT-OD-25-130)

Issued July 18, 2025 as a follow-up to NOT-OD-25-104. This updated guidance creates an alternative, short-term approach for existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) with foreign sites. The alternative approach involves removing a foreign sub-award from the primary award and having it issued as a foreign supplement award.