UW Research
Frequently-Asked Questions

NIH FAQs May 2025

Select Q&A around recent NIH policies.

Q1: NIH sent an email directly to our PI and requesting additional tracking & monitoring info in the next 2 days.
A1: For NIH, in select cases, Program Officers (whether or not GMS included) are approaching PIs to directly submit responses related to foreign subaward participation or tracking, with less than a two day turnaround:

Q2: If we received the Notice of Award (NOA) on April 27 but the award begins May 1, does the new foreign subaward guideline apply? The foreign subrecipient is still listed in the NOA.
A2: We continue to process NOAs as issued by NIH, given NIH NOT-OD-25-104 indicates that the change is applied prospectively to new, renewal and non-competing continuation NIH funding.

Q3: What is the benefit, from the NIH perspective, of eliminating the parent to child relationship of foreign subawards?
A3: Please see NIH information on their new NIH foreign subaward structure.

Q4: How are foreign consultants impacted by this guidance?
A4: NOT-OD-25-104 states that this policy does not apply to funds provided to support foreign consultants. For Uniform Guidance guidance on distinction, please see the difference between a vendor/contractor and a subrecipient.

Q5: Will we be able to provide a no-cost extension (NCE) to existing subawards to foreign awardees (for both SNAP and non-SNAP)? If not, do we need to issue deobligations?
A5: There are 3 possible scenarios:

  1. Current active award budget period end date is out further than subaward end date. Submit a Subaward Request to extend the Subaward end date to no further than the award budget period end date.
  2. Current active award budget period end date coming up and need a NCE on the award first. Please submit a NCE request according to the current NIH instructions and be sure to include description of need to extend the foreign subaward. If NCE approved, you can proceed with submitting a Subaward Request to extend the Subaward.
  3. UW receives NOA for next year of funding after 5/1, without foreign subrecipient included. Subrecipient work must end as of prior budget period unless renegotiation with NIH specifically allows work to continue. Without specific approval from the NIH, we cannot issue an NCE to our subrecipient for future work.

Q6: For projects renewing May-Sept that aren’t viable without the international collaborator – could we potentially rebudget all funding to the UW prime, and then enter into a set of smaller, short-term procurement-only contracts for specific functions eg. in-country data collection?
A6: NOT-OD-25-104 states that this policy does not apply to funds provided to support foreign consultants. Also see Uniform Guidance distinction between Subrecipient v. Contractor found at CFR 200.331. The policy also states that NIH will allow Institutes, Centers and Offices (ICOs) to renegotiate awards, whether new, renewal or non-competing, to remove subawards to foreign entities and, where the work can be performed domestically, allow the funds to be rebudgeted for use by the prime recipient (domestic or foreign) or a domestic subrecipient. With this in mind, prepare a Change in Scope/Rebudget request describing rebudgeting funds for prime recipient (UW) to reallocate for use to carry out programmatic portions in the U.S. but will be securing the assistance of the foreign entity for in-country non-programmatic work such as data collection. Please recognize this may fit the description of a foreign component. If it does, emphasize this is not a NEW foreign component. Be sure to follow policy guidelines when preparing the request.

This recommendation also applies to those submitting an RPPR shortly.

Q7: I’ve submitted my RPPR. How do I revise to “renegotiate” with NIH?
A7: Likely, the RPPR will need to be revised, or a follow-up Change request submitted to the GMS. We are seeking further information from NIH on this.

Q8: Since NOAA also uses eRA Commons, should NOAA follow this same new NIH process for no-cost extensions?
A8: As far as OSP is aware, a NOAA Revision Request for a “No Cost Extension – Prior Approval Waived (Research Terms and Conditions)” remains available and has not been disabled.

Q9: What about Foreign Consultants, Services or other procurement activity?
A9: NOT-OD-25-104 states that this policy does not apply to funds provided to support foreign consultants, or purchasing unique equipment or supplies from foreign vendor. For Uniform Guidance guidance on distinction, please see the difference between a vendor/contractor and a subrecipient.

Q10: I’ve been asked to rescope for future years. What should I do?
A10:  In the absence of further direction from NIH, we recommend that the “Change in Scope” submitted reflect continued work without the foreign subrecipient, if possible, but include information on how we wish to include the foreign entity under the future new award structure to fully effectuate program goals.

Q11: I’ve been asked how we track and monitor foreign subawards at UW. What should I include?
A11: Please see UW’s Statement on Tracking & Monitoring Foreign Subawards. PIs can use this information to help address requests from sponsors, however in responding the PI must also include the steps they have taken to monitor progress (such as reports, site visits, calls, etc.) and how the PI decides on invoice approval in accordance with progress and consistency with the budget and sponsor policy on allowable costs.

Q12: I’ve been told that NIH no longer allows 1st time no cost-extensions. How do I request additional time?
A12: eRA Commons No-Cost Extension functionality is temporarily disabled. All no-cost extensions (NCE) requests must be submitted as a prior approval.

Planning to request an NCE on an NIH award?
Complete UW’s NCE form as a prior approval request & include all required documents with OSP/GCA MOD in SAGE.

  • Progress Report
  • Budget Documentation
  • Justification for the NCE request

NIH NCEs already in OSP without this documentation is being returned.

If eRA Commons prior approval path is not yet enabled, we are submitting to GMS. Do not wait until after the end of project period!!