Updated NIH Requirements for Foreign Subaward Agreements

The NIH has updated its grant policy guidance for foreign subaward agreements (NOT-OD-23-182). Effective January 1, 2024, agreements for foreign subawards must contain a provision requiring foreign subrecipients to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient (Boston University) with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report (RPPR) submission. Such access may be entirely electronic.

To comply with this requirement the following changes will go into effect immediately for NIH funded foreign subrecipients:

  • Amendments are currently being issued to all affected subawards to include this new NIH requirement.
  • New foreign subawards issued with effective dates on or after January 1, 2024, will contain this requirement.
  • Foreign Subrecipients to BU must include this acknowledgement in their letters of intent provided at the time of proposal:

The Subrecipient is aware of and accepts the provisions of NIH GPS 15.2.1 requiring that international subrecipients provide access (electronic access permissible) to copies of all lab notebooks, all data, and all documentation associated with the research described in the progress report to the primary funding recipient and in alignment with the progress report submissions requirements, but on no less than an annual basis.

If the Subrecipient does not have their own letter of intent template that includes this acknowledgement, BU has created one that can be shared with them which can be found in the Forms & Policies Library and here.

Please note, this new LOI template should not be used when BU is the subrecipient. The BU subrecipient LOI remains unchanged.

  • As part of the subaward set up process, the BU Principal Investigator will be asked if there is a preferred method for the subrecipient to make the data available (e.g., SharePoint, Teams, Box, etc.).

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