Dear Colleagues,
For this month’s ReSearch ReSource, I want to provide the latest information on the NIH foreign subaward policy changes.
UCSF has 142 active foreign subawards impacted by the May NIH notice halting all awards with foreign subawards because of concerns in subrecipient reporting and the need to maintain national security (NOT-OD-25-104). The guidance was for researchers to remove the foreign sub-component, or restructure and resubmit their research awards for full scientific review under a new administrative process to be developed by late summer or fall 2025. NIH is not currently accepting new applications that propose foreign subawards.
Last week, the NIH issued a second notice (NOT-OD-25-130) providing an expedited process for the restructuring of awards with foreign subawards involving human subjects. This is a welcome development, as most of UCSF’s impacted awards involve human subjects. We are hopeful that NIH institutes will quickly implement this process.
For non-human subjects-related awards, however, the options remain completely removing the foreign subawards or planning to resubmit the research for scientific review under a new NIH policy, to be released in the next few months.
I encourage impacted investigators to work with their program officer and departmental grants administrator to navigate this issue. A flow chart of options is available to assist with decision-making. Please contact the Office of Sponsored Research (OSR) if you received guidance on restructuring your foreign subaward from the NIH, or if you have questions pertaining to a specific award or submission. The NIH FAQ page is also a resource for questions you may have. Contact the Institute for Global Health Sciences (IGHS) to discuss strategies for managing operations and budgeting under the new policy.
Investigators who are planning to submit a new proposal that includes a funded foreign collaboration should wait to submit until after the new award structure has been determined and guidance is provided.
Thank you to all PIs and their teams who are working with OSR and IGHS to navigate these changes.
Please reach out to [email protected] with any questions or feedback.
Yours,
Hal
Harold R. Collard, MD, MS
Vice Chancellor for Research
Professor of Medicine and Health Policy