NIH Policy Updates
Pre-Award
Sep 18, 2025New NIH Application Structure for International Collaborations - NOT-OD-25-155
The NIH has announced a major policy change for applications involving foreign components - defined as any significant scientific activity conducted outside the U.S. by the recipient or a foreign organization.
Current subaward structures have not met federal oversight needs, raising concerns about tracking federal funds abroad. To address this, NIH will no longer accept new applications requesting funds for foreign components through traditional subaward/consortium structures.
New Activity Codes:
- PF5 for grants
- UF5 for cooperative agreements
Application must include:
- Overall Component - project objectives
- Research Project Component - scientific direction
- International Project Component - foreign collaborator's role
- Each foreign collaborator requires a separate International Project component.
Key Requirements: The primary applicant must be a U.S.-based organization. Leadership must include at least one PD/PI from the U.S. and one from each International Project. NIH will issue a Parent NOFO with detailed guidance.
Review & Awards
- Applications will undergo multi-component review with an Overall Impact Score.
- If selected for funding, NIH will disaggregate awards:
- U.S. organization: PF5/UF5
- Foreign organization: FR1 (grant) or UL2 (cooperative agreement)
- Both organizations must meet independent compliance and reporting requirements.
Reporting & Resources: NIH is developing streamlined reporting mechanisms and will provide FAQs and training soon. As more data about this is released we will keep updating this article.
NIH Releases New Notices on Research Integrity and Security
NIH has released two important policy updates that will impact how institutions and researchers manage disclosures and research security. These changes aim to enhance transparency, accountability, and compliance across the research enterprise. As we move closer to the January 2026 deadline for NOT-OD-25-154, additional guidance and resources will be provided. Please watch this article for future updates.
NOT-OD-25-133: Enhancing Transparency in Other Support Disclosures
- Effective Date: October 1, 2025
- Who’s Affected: All NIH-funded institutions and Senior/Key Personnel
- Requirement: Annual training on NIH’s Other Support disclosure policies
- Goal: Ensure accurate reporting of all active and pending support, including foreign affiliations
- OGC Website: More will be provided regarding this in the coming weeks on the OGC site
NOT-OD-25-154: Implementing Research Security Programs in alignment with federal mandates.
- Effective Date: January 25, 2026
- Who’s Affected: Institutions receiving >\$50M/year in federal research funding
- Requirements:
- Establish a Research Security Program covering:
- Cybersecurity
- Foreign travel security
- Export control
- Research security training
- Annual certifications by institutions and Senior/Key Personnel
- Prohibition of participation in Malign Foreign Talent Recruitment Programs (MFTRPs)
- Establish a Research Security Program covering:
Comparison of the Two Notices
| Feature | NOT-OD-25-133 | NOT-OD-25-154 |
| Primary Focus | Disclosure of Other Support | Research Security Policies |
| Scope of Training | Other Support disclosure requirements | Cybersecurity, foreign travel, export control, research security |
| Target Audience | All NIH-funded institutions | Institutions receiving >$50M/year |
| Certifications Required | Institutional enforcement only | Individual and institutional certifications, at submission, JIT and RPPR |
For more from the Pre-Award team, click here.