UW Research

January 17, 2024

NIH & International Subawards Requirements for Proposals & Awards

NIH recently released a policy clarifying their stance on requirements for subrecipient agreements on NIH awards. See NOT-OD-23-182.
These clarifications for international subrecipients include:

  • Expectations for international subrecipients acknowledgement of requirements at proposal stage in letters of support. See UW sample language.
  • Provide access to all lab notebooks, all data, and all documentation that supports the research outcomes. May be electronic access.

What is OSP doing?

  • Updating subaward templates to include requirements from Chapter 15 NIH Grants Policy Statement.
  • Modifying existing subaward agreements to communicate the requirements & expectations to our subrecipients.
    • You do not need to initiate these modifications.

OSP is on track for NIH’s March implementation deadline.

What do our international subrecipients need to do?

At the time of Proposal:

International subrecipients should include this UW Sample Language in their Letters of Support/Intent.

During the award:

  • Communicate requirements to their staff and Principal Investigators.
  • No less than once a year, share copies of all lab notebooks, data, and documentation that supports the research outcomes described in research progress reports with the UW PI. Access may be entirely electronic.

What do you need to do?

  • Answer your subrecipient’s questions.
  • Maintain records of the documentation provided by subrecipients.

NOTE: OSP does not receive or maintain this documentation.


This message was sent to UW MRAM subscribers. A separate message was also sent directly to those individual PIs and SAGE subaward preparers identified as having a current international subaward funded by an NIH award. Please share this information with any who may be impacted.