UW Research
Frequently-Asked Questions

NIH FAQs

Updated 8/01/2025

Contents

Limits on Proposals

Q1: Can I use AI in proposal development?
A1: We recommend limited use of AI. Please refer to any guidance your school or department has provided on AI usage.

Update 8/01/2025: NIH FAQs on Supporting Fairness and Originality in NIH Research Applications (NOT-OD-25-132)

Q2: How can I find out how many proposals I have submitted to ensure I don’t have more than 6?
A2: You can use the NIH Application Tracker to review NIH submissions per calendar year, per individual. This report is also available via the RAD Group Reports SharePoint site.

The report includes eGC1s for new, renewal, resubmission, or revisions with NIH deadline dates during the current calendar year. Individuals are listed on the report if they are named as the following roles on the SAGE eGC1: PI, Multiple PI or Application PI. Activity code, such as “R01”, is listed when available in SAGE.

Please note, mentors listed on an NIH application but as a PI in SAGE will not have that application counted as one of the 6 NIH submissions allowed for that individual. Fellows listed as PI in the NIH application but as Application PI in SAGE would have that application counted as one of the 6 NIH submissions allowed for that fellow.

Questions about the report data? Email grantrpt@uw.edu

Follow up on Reinstatements:

OSP prepared and sent customized emails to NIH about award reinstatements. Please review the 7/08/2025 announcement shared with MRAM on this topic.

NIH Terminated Awards – Reinstatement

Q1: My NIH award was terminated and will be reinstated. Do I need to do anything to reinstate my NIH award?
A1: Upon receipt of NIH notification of reinstatement, OSP is setting up a MOD to resume work and send it to the PI/dept. Please review for accuracy and . return to OSP so it can be processed.

Q2: My NIH non competing continuation award is on the list in the court order. When can I resume work?
A2: We are starting to see NOAs for all non competing continuation funding impacted by this court order. Upon receipt of the NOA, an Award Modification (MOD) will be handled according to regular business process.

Q3: Is there a list of UW Awards from the court order that includes the UW AWD number?

A3: Yes, this list of UW Awards listed in court order by AWD#s. This list is a) Only those NIH terminated awards or delayed noncompeting continuation awards that were specifically listed in the Court Order, Exhibit A, and b) we did not have a record of reinstatement or noncompeting continuation as of the date the list was compiled.

This list is provided for reference only, and only available to those with a UW Net ID.

Please also see our initial announcement of the court order and subsequent advance spend guidance.

Advances in Anticipation of NOAs for Delayed NIH Awards

Q1: If my award was part of Phase I litigation, and my Notice of Award has been received, why are you suggesting we request advance spend{link back to 7/21 announcement}?
A1: Most of the NOAs for those listed in the court order have been received but not all are yet processed, due to volume.

Q2: We have a noncompeting award on this Phase II list. Can I carry out purchases or salary costs in anticipation of the reinstatement getting processed?
A2: The Phase II list represents delayed noncompeting continuations with a start day on or after July 1, 2025.
You may resume work , using an advance spend mechanism:

When requesting a Temporary Internal Extension, Advance or Advance Extension in SAGE, include the following comment:
“This NIH award is involved in litigation”. This will streamline processing of the request.

For non-competing continuations that have a foreign subaward involving human subjects work:
If the PI is requesting NIH reissue the foreign subaward as a Type 3 administrative supplement, the NIH will issue the primary award as a Non-SNAP award. For these, you may also request Advance Spend for up to a total of 60 days from date of the request.

Impacted Award Lists

Review the list of Impacted UW awards:

As with all advance spend, expenditures ahead of formal reinstatement pose a risk. The PI will be responsible for any costs that are subsequently not allowed by the sponsor.

Q3: If we already had a 30-day advance for a late/delayed non-competing renewal on the list, can we request another advance extension?
A3: Yes.

No-Cost Extensions

Q1: I’ve been told that NIH no longer allows 1st time no cost-extensions. How do I request additional time?
A1: 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 are 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!

Subawards

Q1: I had a subaward from another institution, where the originating funding was NIH. I was made aware from my colleague at the other institution that their NIH award was reinstated. Can I begin work?
A1: While some pass-through entities (PTEs) will have their NIH awards reinstated as well, if UW was a subrecipient, we must wait for the PTE’s formal re-issuance or formal resume work order of the subaward before we can process a reinstatement and resume work on pass-through NIH funding.

Q2: My NIH award was reinstated. There were two subawards issued under my award, but those were issued a stop-work order when my NIH award was terminated. Do I need to request these be reinstated?
A2: If OSP sent a formal stop-work notice via email, but the subaward was not terminated, OSP will rescind the stop-work order via email without any action by campus. If you have questions, reach out to ospsubs@uw.edu.

Foreign Subawards

Q1: What steps does a PI need to take if they wish to proceed with a type 3 award structure for foreign subawards with Human Subjects? See  7/21/2025 UW guidance and NIH 7/17/2025 guidance on Foreign Subawards for Active Projects (NOT-OD-25-130).
A1: If the PI wishes to proceed with the type 3 award structure:

  1. NIH will require a PHS 398 detailed budget and budget justification for each individual foreign subaward for all remaining years of the project. Submit an OSP/GCA SAGE MOD (with MOD Type Rebudgeting). NIH requires AOR approval and submission.
  2. NIH will review and then if approved, move the confirmed funds from the primary award to the type 3 award.
  3. When the UW receives the reissued award/supplement from NIH, OSP will set up OSP/GCA Award Modifications in SAGE and route them to the PI / department for completion.
    • The primary award and the supplemental award(s) will each have their own SAGE MOD, due to the award numbering convention that NIH will use.
  4. PI/Campus need to route the MOD(s) back to OSP, including the updated SAGE Budgets. In all cases totals must match the Notice of Award from NIH. Review the following guidelines for setting up your SAGE Budget Worksheets:
    • Type 5 (non-competing renewal) Award: make sure SAGE Budget worksheet does not include foreign subaward(s) supplement totals and that the overall total matches the Notice of Award from NIH.
    • Type 3 supplement (foreign subaward): Create SAGE Budget Worksheet under prime Budget worksheet for each foreign subaward being reissued as a Type 3 supplement, with the following:
      • GCA recommends this Budget Worksheet naming convention: Subaward | Foreign Subaward – Subawardee Name -[Insert Federal Award Number with the supplement suffix (i.e. 3R01AA123456-02S1)].
    • Use 0% UW F&A rate on the foreign subaward amount for budget worksheet (foreign subrecipient may receive F&A).displays F&A as 0% with callout to "Use 0%" F&A"
  5. Submit a request to modify the existing subaward in SAGE Subaward Module. Include a note in the Special Instructions section of your Subaward Modification request that indicates the “funds come from an administrative supplement for a foreign component”.

Q2: NIH sent an email directly to our PI requesting additional tracking & monitoring info in the next 2 days.
A2: 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:

  • PI can respond directly
  • A PI should refer to UW’s Statement on Foreign Subaward Assessment, Tracking and Monitoring for important institutional level information and add in the specific project specific monitoring carried out
  • Copy OSP (osp@uw.edu) as Authorized Official
  • Route OSP/GCA SAGE MOD with the email correspondence attached

Q3: 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.
A3: 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.

Q4: What is the benefit, from the NIH perspective, of eliminating the parent to child relationship of foreign subawards?
A4: Please see NIH information on their new NIH foreign subaward structure.

Q5: How are foreign consultants impacted by this guidance?
A5: 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.

Q6: 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?
A6: There are 3 possible scenarios:

  • 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.
  • Current active award budget period end date coming up and needs an NCE on the award first. Please submit an 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.
  • 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.

Q7: 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 e.g. in-country data collection?
A7: 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.

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 vendors. For Uniform Guidance guidance on the distinction, please see the difference between a vendor/contractor and a subrecipient.

Q10: I’ve been asked how we track and monitor foreign subawards at UW. What should I include?
A10: 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.