January 17, 2024

NIH & International Subawards Requirements for Proposals & Awards

UPDATE 2/13/2026 See:

NIH recently released a policy clarifying their stance on requirements for subrecipient agreements on NIH awards. See .
These clarifications for international subrecipients include:

  • Expectations for international subrecipients acknowledgement of requirements at proposal stage in letters of support.
  • Provide access to all lab notebooks, all data, and all documentation that supports the research outcomes. May be electronic access.

What is OSP doing?

  • Updating subaward templates to include requirements from .
  • Modifying existing subaward agreements to communicate the requirements & expectations to our subrecipients.
    • You do not need to initiate these modifications.

OSP is on track for NIH鈥檚 March implementation deadline.

What do our international subrecipients need to do?

At the time of Proposal:

UPDATE 2/13/2026:聽Please note NIH is no longer accepting proposals that include international subawards. See聽

During the award:

  • Communicate requirements to their staff and Principal Investigators.
  • No less than once a year, share copies of all lab notebooks, data, and documentation that supports the research outcomes described in research progress reports with the 91探花PI. Access may be entirely electronic.

What do you need to do?

  • Answer your subrecipient鈥檚 questions.
  • Maintain records of the documentation provided by subrecipients.

NOTE: OSP does not receive or maintain this documentation.

Resources

This message was sent to 91探花MRAM subscribers. A separate message was also sent directly to those individual PIs and SAGE subaward preparers identified as having a current international subaward funded by an NIH award. Please share this information with any who may be impacted.