Policy on Foreign Subawards
On May 1st, the National Institutes of Health (NIH) released a policy notice titled "Updated NIH Policy on Foreign Subawards." The notice announces a new award structure for projects that have an NIH-defined foreign collaboration component.
In this new structure, foreign subawards will no longer be listed under the prime institution, but will be awarded as subprojects linked to the prime. The new policy is applicable to all monetary foreign collaborations. It does not apply to funds allocated to foreign consultants or purchasing of equipment and supplies. Many details of the new award structure are not clear at this time. The NIH has stated that further details will be announced and implemented by the end of this government fiscal year (Sept. 30th, 2025). On May 7th, NIH released an additional communication on the policy.
Should you receive a request from an NIH Institute, Center or Office (ICO) to renegotiate or remove a foreign collaboration component on a new or existing award, the PI's response should be submitted to ORSP by routing an Award Change Request (ACR) in e-Research Proposal Management (eRPM). If you receive a request to remove a foreign consultant or other resource that is not a foreign collaboration component, contact the Officer listed in the Project Representative field on the related PAF (proposals) or AWD record (active awards) for guidance.
Additional information from the NIH is expected. ORSP is also communicating with the NIH and will communicate further developments and guidance related to this policy.
2024 Public Access Policy
The final NIH 2024 Public Access Policy was originally scheduled to be implemented on December 31st, 2025. However, in a policy notice published by NIH on April 30th, the agency updated its effective date to July 1st, 2025. The 2024 policy builds on NIH's original public access policy from 2008. Upon its implementation date, all Author Accepted Manuscripts accepted for publication in a journal are required to be submitted to PubMed Central – the NIH's archive of biomedical and life sciences journal literature. When submitting the article to PubMed, PIs must agree to a standard license that explicitly grants NIH the right to make the manuscript publicly available immediately through PubMed Central. The 2008 policy permitted a 12-month embargo period before making NIH-funded research articles publicly accessible, but the updated 2024 policy requires immediate submission to PubMed upon publication. The policy also requires an acknowledgement in the final published article that the project was federally funded.