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NIH Guidance for Foreign Subawards

March 17, 2026

NIH Guidance for Foreign Subawards

In September, NIH posted NOT-OD-25-155 New Application Structure for NIH-Funded International Collaborations announcing that it would no longer be accepting new applications that request funds for foreign components using the traditional grant subaward/consortium structure. Instead, the notice announced a new application and award structure for applications that request funding for foreign component organizations.   

In January, NIH followed up with the funding opportunity announcement for proposals with international collaborators that formerly would have been handled through subcontracts. PA-26-002: NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional) supports international research collaborations by implementing an award structure of prime domestic awards with independent foreign awards that are linked to the prime. 

Highlights from the funding announcement:

  • The first application deadline is May 26, 2026 due to the Memorial Day holiday.
  • All collaborative international research applications must include at least one international subproject. 
  • Applications must use the multi-component structure and be submitted in ASSIST. Guidance in the Multi-Project Instructions Application Guide must be followed, along with the instructions in the PF5 Parent Announcement
  • Applications must include at a minimum an Overall Component, a Research Project Component, and an International Project Component for each funded foreign collaborator(s) institution.
  • Applications must include a letter of support from each foreign organization's authorized organizational representative acknowledging that they will fill the role of recipient organization for the disaggregated award. 
  • Since each foreign collaborative institution will receive their own disaggregated award, instead of a subaward from U-M, neither a subrecipient commitment form or a subaward (SUBK) is required in the PAF.

For more information, visit the NIH Foreign Subaward Policy FAQs.