The National Institutes of Health (NIH) has announced a significant change affecting all NIH-funded research involving foreign subawards, with implementation beginning May 1, 2025. Under the new guidance, NIH will no longer allow new or renewed foreign subawards under prime recipient awards. Instead, NIH is temporarily pausing foreign subawards while it develops a new framework, NIH expects to launch in September 2025. 

What This Means for You 

If you currently have a foreign subaward listed in an upcoming Research Performance Progress Report (RPPR), this policy change may impact your ability to proceed under existing arrangements. As a first step, we strongly encourage you to contact your NIH Program Officer (PO) to discuss your specific situation. In the meantime, below are some potential options investigators may consider when revising their proposals or RPPRs: 

Options 

1. Remove the Foreign Subaward 
   Update your proposal’s scope of work (SOW) to reflect the change. 

2. Convert to a Foreign Consultant 
   You may be able to revise the relationship to a consultant, only if the entity meets NIH’s definition of a consultant (i.e., provides expert advice but does not perform programmatic decision-making). 
   

    

   Important Considerations: 

• If uncertain, please consult Thomas Keith before proceeding. 
• NIH is expected to closely review such changes, and there is uncertainty about whether this will trigger additional foreign component review or delay RPPR approval. 
• This change may impact F&A rates and require budget modifications or prior approval. 

3. Identify a U.S.-Based Subawardee 
   Another option is to shift the work to a domestic subrecipient capable of handling the foreign work. While NIH hasn’t explicitly endorsed this solution, it is not currently prohibited. 

4. Keep the Foreign Subaward 
   This approach carries high risk and should only be pursued with direct guidance and approval from your NIH Program Officer. 

We recognize these changes present challenges. If you have questions about your foreign subaward, please reach out to Xenia at [email protected]. For the latest updates, visit NIH’s official announcement: NIH News: Foreign Subaward Structure Update.

For more from the Pre-Award team, click here.