NIH’s Update to Policy on Subaward/Consortium Written Agreements

Please see the message below from SPARCS Director, Marissa Clarkson, regarding a change to NIH grants effective October. 1, 2023. 

I want to clarify NIH’s update to their policy on Subaward/Consortium Written Agreements effective October 1, 2023.

The foreign subrecipient must provide NCSU copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, no less than quarterly. This will be noted in the Subaward issued by SPARCS.

The policy does not require NCSU to submit the back-up documentation to NIH with our RPPR submissions. However, NIH can request copies of the sub-award as well as relevant supporting documentation. If NCSU fails to provide the requested documentation, NIH can implement remedies for noncompliance and potential enforcement action.

Payments should not be made to a subrecipient if they are out of compliance with the terms of the subaward (i.e. haven’t provided the required documentation).

While the policy doesn’t speak specifically to budgeting for costs associated with this requirement, if they are anticipated, they should be budgeted for at the proposal stage.

Also at the proposal stage, it’s recommended to include language in the foreign subrecipient’s LOI indicating their awareness of these requirements and willingness to comply should an award be issued.