Foreign Subawards - NIH Updates
NIH has changed how it manages foreign collaborations in NIH-funded research. These updates affect how money is awarded, how foreign partners are tracked, and how ongoing projects involving foreign sites are handled. The goal is to ensure NIH can clearly track where federal research dollars go, especially when foreign institutions are involved.
As of January 20th, 2026, one NOFO (Notice of Funding Opportunity) has been released that allows for the inclusion of funded foreign collaborations (previously issued as subawards) under the new structure.
NOT-OD-25-104 – May 1, 2025 – Updated NIH Policy on Foreign Subawards
NOT-OD-25-130 – July 18, 2025 – Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects
NOT-OD-25-155 – September 12, 2025 – New Application Structure for NIH-Funded International Collaborations
❗️Why NIH Made These Changes
Federal law requires reporting any subaward of $30,000 or more. NIH found that many foreign were not being reported correctly, leading to:
- Gaps in financial transparency
- Difficulty tracking federal spending
- National security concerns
- Risks in projects involving human subjects at foreign sites
To address these issues, NIH is restructuring how foreign collaborators receive funding and how ongoing projects are managed.
🔄 Major Change: New Structure for Foreign Collaborations
NIH is moving away from the old system where foreign subaward funding was embedded inside a U.S. institution’s main grant.
Under the new structure:
✔️ Foreign subawards will no longer be part of the U.S. institution’s main award
✔️ NIH will issue separate but linked awards directly to foreign collaborators
✔️ The U.S. institution will still submit one combined scientific progress report
🧭 What Happens to Ongoing Projects?
For projects already underway—especially those involving human subjects research at foreign sites—NIH created a temporary approach to avoid disrupting patient care or clinical work.
🔧 Administrative Supplements (Type 3 Awards)
NIH Institutes and Centers may:
- Remove the foreign subaward from the main grant
- Reissue it as a separate administrative supplement
- Create one supplement per foreign institution
📊 Financial Rules for These Supplements
- No SNAP (Streamlined Noncompeting Award Process)
- No automatic carryover
- Each supplement receives its own award number
- Each must submit its own annual Federal Financial Report (FFR)
- No rebudgeting between the main award and supplements within the same budget year
- Future year adjustments may be requested through the RPPR
🛑 Restrictions
- NIH will not issue new, renewal, or continuation awards that include a foreign subaward
- NIH will not approve adding new foreign components to existing projects
- NIH may renegotiate awards to:
- Remove foreign subawards
- Shift work to U.S. institutions
If a project cannot continue without the foreign subaward, NIH may work with the institution to end the award while protecting patient safety and animal welfare.
🌍 Who These Policies Apply To
- All NIH grants and cooperative agreements
- U.S. and foreign institutions
- New, renewal, and noncompeting continuation awards
Important clarifications:
- Existing awards will not be retroactively changed to remove foreign subawards
- NIH will continue to fund direct awards to foreign institutions
- The policy applies only to monetary foreign collaborations
- It does not apply to foreign consultants or purchases of specialized equipment
📑 Impact on NOFOs
Any NOFO (issued prior to January 20, 2026) that previously allowed foreign components is now overridden by these policies referenced above. As announced in the RAC memos of January 12 and January 21, the first NOFO PA-26-002 has been released that allows for the inclusion of funded foreign collaborations (previously issued as subawards) under the new structure. Please read the linked NOFO carefully.
A few key points:
- Please see the NOFO for all deadline dates. The earliest submission date under this NOFO is April 25, 2026.
- Please continue to use UMB's current F & A rate agreement for budget preparation. The NOFO references calculating indirect costs on the first $50,000 of domestic subawards. UMB’s current rate agreement only allows for F&A on the first $25,000 of subs and the new $50,000 limit should not be used at this time.
- It is critical that applicants follow the Multi-Project (M) Instructions in the How to Apply - Application Guide, except where instructed to do otherwise (in the NOFO or in a Notice from the NIH Guide for Grants and Contracts).
- Contact SPA-Proposals to alert the team of your submission as proposals will need to be created and submitted via NIH ASSIST. Route the proposal in Kuali Research following standard procedures and internal deadlines.