 

#  NIH International Subaward/Consortium Announcement 

 





November 01, 2023

 

 

 Dear Colleagues,

 On September 15, 2023 the National Institutes of Health (NIH) issued its Final Updated Policy Guidance for Subaward/Consortium Written Agreements ([Notice Number: NOT-OD-23-182](https://grants.nih.gov/grants/guide/notice-files/NOT-OD-23-182.html)), effective January 2, 2024. The final Notice includes some modifications from the original announcement released on May 19, 2023, but the main provision remains intact. NIH has provided additional information regarding the foreign subaward provision in a [blog post](https://nexus.od.nih.gov/all/2023/09/15/further-clarifying-nihs-foreign-subaward-agreement-policy-addressing-community-feedback/) and in [FAQs](https://grants.nih.gov/faqs#/subawards.htm?anchor=4304).

 In addition to the current requirements under NIH Grants Policy Statement (NIHGPS), [15.2 Administrative and Other Requirements](https://grants.nih.gov/grants/policy/nihgps/HTML5/section_15/15.2_administrative_and_other_requirements.htm), all active and new foreign subawards (NIH funded) must include:

- *A provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic*.
- *NIH also expects recipients to ask potential subrecipients, at the application stage, to submit language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued*.

 Harvard University Sponsored Administrative Leadership Committee’s Executive Committee (SALC-EC) has convened a University-wide Ad-hoc Working Group to develop policy and detailed guidance on the new requirement. Additional information will be provided as the documents are finalized.



 

 

 



 

 See also:- [ Alerts ](/blog-categories/alerts)
- [ NIH ](/blog-tags/nih)
- [ NIH announcement ](/blog-tags/nih-announcement)