Dear Colleagues:
Below is a summary of several recent NIH policy notices. Please review the notices and forward it to faculty, researchers, and staff, as appropriate. Sponsored Projects is working with stakeholders on campus and at the Office of the President to better understand the impact of the notices. We will be sharing more information as soon as it is available.
Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects
This Guide Notice addresses the implementation of the NIH Policy on Foreign Subawards (See NOT-OD-25-104) for applications submitted before May 1, 2025, and projects active on or before May 1, 2025.
NIH Institutes, Centers, and Offices (ICOs) will have the option to renegotiate the award structure with a recipient such that foreign subawards are financially removed from the primary award and awarded as administrative supplement (i.e., Type 3) awards. Each foreign supplement award will only include funds allocated for a single foreign entity, allowing NIH better ability to track obligations to foreign entities.
Additionally, this supplement option is meant to be a short-term solution, permitted only for the current competitive segment, and it does not replace the new award structure announced in NOT-OD-25-104 that will apply to upcoming applications, including any planned renewals.
Supporting Fairness and Originality in NIH Research Applications
NIH will not consider applications that are either substantially developed by AI, or contain sections substantially developed by AI, to be original ideas of applicants. If the detection of AI is identified post award, NIH may refer the matter to the Office of Research Integrity to determine whether there is research misconduct while simultaneously taking enforcement actions including but not limited to disallowing costs, withholding future awards, wholly or in part suspending the grant, and possible termination.
NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year. This policy applies to all activity codes except T activity codes and R13 Conference Grant Applications.
NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements
This Guide Notice announces a new policy requirement that requires NIH recipients to provide training to all faculty and researchers identified as Senior/Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form). The new requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see NIH Grants Policy Statement (GPS), Section 2.5.1 “Just-in-Time Procedures”) in order to provide a comprehensive plan in the area of disclosure requirements for recipients. This update will be included in the FY2026 version of the NIH GPS as part of NIH’s standard processes.
Effective October 1, 2025, recipients must implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.
Regards,
Jeff Warner
Senior Director, Sponsored Projects
Office of Research
University of California Irvine
949-824-7654