Effective January 1, 2024, NIH will require the following:

Foreign Subawards

• For foreign subrecipients, a provision in subaward agreements 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. 

At Proposal Stage

• Subrecipients must include 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.

Effective January 1, 2024, the NIH Grants Policy Statement, section 15.2, Administrative and Other Requirements, will be updated to include the clarifications.

Read the NIH notice NOT-OD-23-182