NIH Updates Policies and Procedures for Child Care, Public Access, and Foreign Subawards

By: Yvette Seger
Thursday, May 8, 2025
The National Institutes of Health (NIH) continues to update policies and guidance to the extramural research community as part of efforts to align the agency’s activities with administration priorities. Updates announced over the past two weeks can be divided into two focus areas: 1) agency efficiency and 2) research security. 

On April 25, NIH announced updated procedures for childcare costs for Ruth L. Kirschstein National Research Service Award (NRSA) Institutional Research Training Awards. The updates do not change the availability or eligibility for the existing annual childcare costs allowed for each full-time predoctoral or postdoctoral NRSA trainee – it changes the way NIH budgets for these expenses. To minimize unobligated funds at the end of each fiscal year, NIH will budget childcare expenses for 25 percent of the full-time trainee appointment slots as part of new, renewal, or continuation NRSA Institutional awards. Institutions for which more than 25 percent of allotted slots have eligible childcare costs may request administrative supplements to provide trainees with this support.

Touted as a strategy to rebuild public trust in NIH-funded research, on April 30, NIH Director Jayanta “Jay” Bhattacharya, MD, PhD, announced the accelerated implementation of the 2024 NIH Public Access Policy, shifting the effective date from December 31, 2025 to July 1, 2025. As noted in a blog post issued by NIH’s Office of Science Policy, the intent of the updated effective date is to promote transparency and accelerate live saving discoveries; no other updates have been made to the policy issued in December 2024.

As part of agency efforts to enhance research security, NIH introduced an updated policy on foreign subawards on May 1. To address challenges associated with tracking expenditures and outputs of foreign subawardees, NIH will be establishing a new award structure that will prohibit foreign subawards from being nested under a parent grant. The new structure – to be implemented no later than September 30, 2025 – will include a prime grantee with individual awards linked to the prime award. This structure will allow the agency to better track project funds and scientific progress. While this new structure is developed, NIH has halted the issuance of awards that include subawards to foreign entities.