NIH has implemented new procedures for foreign components, as outlined in NOT-OD-25-155. Effective January 2026, proposals with foreign collaborators must use the PF5 Funding Opportunity Announcement for grant applications, the UF5 Activity Code for cooperative agreements, or another complex mechanism activity code that supports international projects. 

Under these new policies, foreign entities will no longer serve as subrecipients. Instead, they will be direct recipients of NIH funding and will collaborate with the University on NIH-sponsored projects. As direct recipients, foreign entities must obtain all required registrations prior to receiving a federal award and ensure compliance with applicable federal requirements, including NIH Grants Policy Statement, certain national policy requirements, reporting requirements, system requirements, and legislative mandates. 

To support the University's foreign collaborators in understanding these requirements, a resource guide that may be shared with foreign entities has been created. The document, "Resource Guide for NIH International Project Components", is available on the OGC A to Z Resources website.

Please contact TK Keith with any questions regarding the document or for additional information about compliance requirements for foreign entities. Questions regarding PF5 proposal requirements may be directed to Xenia. 

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