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NIH Updates for Subaward/Consortium Written Agreements

September 20, 2023

On Friday, September 15, 2023, NIH announced its final Policy Guidance for Subaward/Consortium Written Agreements, based on feedback after public comment. 

Effective January 1, 2024, NIH will require that international subrecipients 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. 

NIH will not support any agreement that does not meet the minimum requirements outlined in this notice. 

The Office of Contract Administration (OCA) and the Office of Research and Sponsored Projects (ORSP) have worked together to update the subrecipient form / letter of commitment (LOC).  

The ITS Safe Computing site has resources to help U-M researchers navigate IT security compliance and ensure their research data is appropriately protected. The Data Storage Finder is designed to help you find storage solutions (such as Turbo or Data Den) to meet your storage needs .

Questions on working with subrecipients should be directed to

(Last updated 10/10/2023.)