Washington Update

NIH Announces Short-Term Procedure for Supporting Foreign Subawards

By: Yvette Seger
Thursday, July 24, 2025
On July 18, the National Institutes of Health (NIH) issued updated implementation guidance for applications and awards with foreign subawards. These updated guidelines apply to applications submitted before and projects active on or before May 1, 2025, the date NIH announced a pause in funding foreign subawards. The updated guidance applies to projects involving human subjects research at the foreign site.

The new option is intended to enhance financial management and reporting for projects engaging researchers based outside the United States. Rather than subawards within the primary grant, these collaborations will be funded as foreign supplements, with each receiving a distinct document number and being required to submit annual Federal Financial Reports. Project progress will continue to be documented through a single Research Performance Progress Report submitted by the primary awardee as indicated in the updated notice of award. 

Additional information about the short-term supplement model for projects involving human subjects can be found on the NIH Grants and Funding webpage. Frequently Asked Questions about NIH’s foreign subaward policy are also available.