________________________________________________________

Joyce H. Ferland, MBA, CRA

Executive Director of Research, Enterprise Radiology

Department of Radiology, Mass General Brigham

Mobile: 401-225-6459  xxxxxx@mgh.harvard.edu

Visit our website at http://radresearch.mgh.harvard.edu/

You forgot non-competing continuations where the federal fiscal 2025 NOGA hasn’t been issued yet in your bullets. From: Ferland, Joyce - jferland1 at mgb. org (via resadm-l list) <xxxxxx@ lists. healthresearch. org> Sent: Monday, May 5,

Dear Colleagues,

Here is my interpretation of the updated NIH policy on foreign subawards  NOT-OD-25-104

Effective immediately, NIH will no longer issue new, renewal, or non-competing continuation awards that include a subaward to a foreign entity. While this change is not retroactive, it may impact future funding tied to existing awards.

Key takeaways:

• Existing NIH awards with active foreign subawards may continue under current terms unless NIH reaches out directly.
• NIH will not approve any new foreign subawards or additions to ongoing projects.
• For future submissions (e.g., renewals), if a foreign subaward must be removed, NIH may allow those funds to be re-budgeted to support domestic collaborators or the prime institution.
• NIH intends to implement a new award mechanism for foreign collaborations by September 30, 2025.

I would be very interested to hear if others are interpreting this differently. Some of my PIs have indicated that their NIH Program Officers are offering guidance that appears inconsistent with this policy.

Thank you,

Joyce

________________________________________________________

Joyce H. Ferland, MBA, CRA

Executive Director of Research, Enterprise Radiology

Department of Radiology, Mass General Brigham

Mobile: 401-225-6459  xxxxxx@mgh.harvard.edu

Visit our website at http://radresearch.mgh.harvard.edu/

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