NIH has recently communicated an important proposal change which may affect submissions in the upcoming cycle. On May 1, NIH released Guide Notice NOT-OD-25-104, which indicated that NIH intended to restructure existing and future awards to directly fund foreign subawardees, eliminating the need for subcontracts. When asked about how this change would affect the structuring of upcoming proposals, NIH has provided the following guidance:
"Applications that were received prior to the issuance of NOT-OD-25-104 will be reviewed as submitted. If the application is considered for funding, the Institute, Center, or Office will contact the applicant to address any foreign subawards in the application.
Applications submitted after the issuance of NOT-OD-25-104 that propose foreign subawards will not be accepted. Applicants planning to propose monetary foreign collaborations should hold until the new award structure is released."
As a reminder, the Guide Notice linked above states that the new award structure will be finalized by Sept. 30, 2025. It should also be noted that this restriction appears to only apply to foreign subawards, not to foreign vendors or contractors.
If you have any questions about how this directive will affect an upcoming submission, please contact federalupdates@brown.edu.