Summary of relevant information from the May ORA RAF meeting
NOT-OD-25-104: Updated Policy on Foreign Subawards
As of 5/1/25 NIH will not issue awards that include a subaward to a foreign site.
New structure will be implemented by 9/30/25, which will award foreign subawards independently from the prime site, but somehow link subawards to the prime.
New structure will eventually apply to domestic subawards.
Policy applies to all monetary foreign collaborations. It doesn’t apply to funds to provide support to foreign consultants, or purchasing equipment or supplies from foreign vendors.
NIH will permit renegotiation of award to remove foreign subawards when the work can be performed domestically. If the project is no longer viable without the foreign subaward, NIH will negotiate termination.
NIH will no longer accept prior approval requests to add monetary foreign subs/foreign components. Prior approval requests for non-monetary foreign components may be considered. Foreign Component = the performance of any significant scientific element or segment of a project outside of the US, whether or not grant funds are expended.
Questions to consider when working on proposals with foreign sites:
Questions to consider when working on your RPPR:
In all cases, PIs should discuss with POs prior to submitting RPPR to discuss options. Keep in mind that even if the PO supports, the GMS may not.
NIH awards issued on or after 4/21/25 are currently on hold at OCGA due to NOT-OD-25-090. This notice requires UCLA to certify that it doesn’t operate any programs that advance DEIA, equity ideology, or boycotts with Israeli companies. It will be several more weeks before UC completes required reviews to be able to certify this new term & condition.
NOT-OD-25-114 grants Early Stage Investigators (ESIs) an eligibility period extension, due to delays impacting proposal submissions, peer review, or award processing between 1/1/25 and 5/31/25. If ESI eligibility ends between October 2024 and July 2025, the extension will allow for the last ESI submission to be October 2025. Updated ESI end dates will appear in eRA Commons by 6/8/25.
Appeals/Litigation update – as of 5/21/25, there have been no successful appeals across the country.
Lawyers are putting together all documents that have to be filed for this case to proceed. If the case is successful, every terminated award named in the case should benefit. It’s possible that if awards have filed separate appeals, these would be excluded from benefitting.
Robert Wood Johnson Foundation Opportunity seeking applications from those with health equity research projects that have lost funding. Visit the foundation site for more details
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