What PIs Need to Know: New NIH Guidance on Foreign Subrecipients

 

This training is for NIH PIs and other personnel to learn and ask questions about the NIH’s new enhanced policy on foreign subrecipients. NIH PIs are encouraged to familiarize themselves with the roles and responsibilities to ensure access on project data from subrecipients, based on the requirements outlined in NIH NOT-OD-23-182.

 

The Final Updated Policy Guidance (NOT-OD-23-182) was released on September 15, 2023. Effective January 1, 2024, the National Institutes of Health (NIH) will require award recipients to address the following in subaward agreements with foreign subrecipients to include: “a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.”

 

OSP has updated the subaward agreement template to comply with NIH guidance. NIH is also expecting prime recipients at proposal stage to request foreign subrecipients “to submit language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued.” OSP has updated the subrecipient commitment form.