Updated guidance:
- 08.12.2025 NIH Applications with Foreign Subrecipients Allowed Until 9/24/2025
- 9.25.2025 NOT-OD-25-155 New Application Structure for NIH-Funded International Collaborations
This guidance is still active
NOT-OD-25-130 announces for projects active or submitted before May 1, 2025, NIH may restructure awards involving foreign human subjects research by removing foreign subawards from the main grant and issuing them as separate Type 3 administrative supplements. These supplements will require separate financial reporting, will not allow rebudgeting between awards within a budget period, and are intended as a temporary measure for the current project segment only.
The supplement option is meant to be a short-term solution, permitted only for the current competitive segment, and it does not replace the new award structure announced in NOT-OD-25-104 that will apply to upcoming applications, including any planned renewals.
The Office of Research expanded on this process in the July 24th Research Resource email newsletter. Including the new NIH Foreign Subaward FAQ page.
As a reminder, please visit Updates from the Office of Research for more information including the OoR FAQ document, specifically for NIH Foreign Grant Operations at UCSF.
If you currently have an active NIH award with a foreign subaward and are curious about potential options, please contact the Institute for Global Health Sciences (IGHS).