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  • 1.  NOT-OD-25-104 Updated NIH Policy on Foreign Subawards

    Posted Fri May 02, 2025 12:19

    Hi everyone, 

    I'm sure many have seen the updated NIH policy on foreign subawards (expected to be expanded to domestic subawards as well), posted yesterday. NOT-OD-25-104: Updated NIH Policy on Foreign Subawards. 

    Have your institutions released guidance for how to handle proposals recently submitted with foreign subs? Are your PIs planning to revise out these subawards? 

    Nih remove preview
    NOT-OD-25-104: Updated NIH Policy on Foreign Subawards
    NIH Funding Opportunities and Notices in the NIH Guide for Grants and Contracts: Updated NIH Policy on Foreign Subawards NOT-OD-25-104. NIH
    View this on Nih >

     

    Thanks for any insights, 

    Emily 



    ------------------------------
    Emily Shortt
    Administrative Lab Manager
    Whitehead Institute for Biomedical Research
    Cambridge, MA
    (617) 258-5059
    ------------------------------


  • 2.  RE: NOT-OD-25-104 Updated NIH Policy on Foreign Subawards

    Posted Mon May 05, 2025 17:32

    Hi, Emily.

    As we consider the effects the Updated NIH Policy on Foreign Subawards (NOT-OD-25-104) will have, I sent the following question to the NIH (OPERAleadership@...) today to ask for clarification. The notice states: "Effective with the date of this notice and until the details of the new foreign collaboration award structure are released, NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity." 

    My question is: When the policy states "will not issue awards," is that referring to the issuance of notices of award or the issuance of payments for award reimbursement?

    I'm hoping for the former, which would allow us to wrap up our open obligations. 

    Does anyone have any insight?

    Thanks!

    Sue



    ------------------------------
    Susan Pugl, CRA
    Director of Grant Administration
    Loyola University of Chicago
    Health Sciences Campus
    Maywood, IL
    708-216-8537
    ------------------------------



  • 3.  RE: NOT-OD-25-104 Updated NIH Policy on Foreign Subawards

    Posted Thu May 08, 2025 06:50
    Edited by Barbara Vianello Thu May 08, 2025 07:18

    Hi everyone,

    I don't understand one thing of this notice. We applied and were granted a R61/R33 (as foreign subawardees). We are at the end of the 1st year of the R61: our prime recipient (US) will not be allowed to make for us (foreign institution) a subaward for the second year of the R61? Even if the notice states "NIH will not retroactively revise ongoing awards to remove foreign subawards at this time"?

    And if the project cannot be implemented without us, will it be terminated?

    Thank you so much for your help in interpreting this notice,

    Barbara



    ------------------------------
    Barbara Vianello
    Research Manager and Administrator
    University of Padua
    Padua
    0498271948
    ------------------------------

    Original Message


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