NIH UPDATE: Applications with Foreign Subrecipients Allowed Until 9/24/2025

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NIH has updated questions number 6 and number 7 on the Frequently Asked Questions (FAQ) on Foreign Subaward Policy Page. Both reiterate an application can be submitted with foreign subawards, and if it is considered for funding will be applicable to negotiation.  

6. Can applicants still propose foreign subawards under the Updated Foreign Subaward Policy (NOT-OD-25-104 and NOT-OD-25-130)? Updated

NIH will continue to accept applications that propose foreign subawards for due dates on or before September 24, 2025. If the application is considered for funding, the Institute, Center, or Office will contact the applicant to address any foreign subawards in the application, as outlined in NOT-OD-25-104 and NOT-OD-25-130. If negotiation is not possible, the award will not be made.

7. How will NIH handle applications that were submitted prior to the issuance of the Updated Foreign Subaward Policy? What about applications submitted after the policy change? UPDATED

Effective for due dates on or after September 25, 2025, application that propose foreign subawards will not be accepted and will be administratively withdrawn.

Applications that are received for due dates prior to September 25, 2025, will be reviewed as submitted. If the application is considered for funding, the Institute, Center, or Office will contact the applicant to address any foreign subawards in the application as outlined in NOT-OD-25-104 and NOT-OD-25-130. If negotiation is not possible, the award will not be made.

If you are planning to submit an application which includes a foreign subaward please contact your OSR Staff Representative.

Please direct inquiries to [email protected].