Dear Colleagues,
This Blog Post is in follow-up to the November 1, 2023 Blog Post, where the National Institutes of Health’s (NIH) Final Updated Policy Guidance for Subaward/Consortium Written Agreements (Notice Number: NOT-OD-23-182) was shared with the Harvard University research community. As a reminder, this new policy requires that “subaward agreements must stipulate that foreign subrecipients will 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 with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission.” In response, Harvard University has developed a new policy on Access to Foreign Subrecipient Records Funded by NIH Grants/Cooperative Agreements, which will take effect January 1, 2024.
Proposals and new subaward consortium agreements:
- Statement of Intent templates have been updated with the new, required language and are available from OSP, HMS ORA, and HSPH SPA.
- Letters of Support from foreign subrecipient PIs are expected by NIH to acknowledge the NIH policy requirements and sample language is provided in the Harvard University Policy.
Ongoing subaward consortium agreements:
- Existing subaward agreements with foreign subrecipients that will be active on June 30, 2024, must be amended to comply with the NIH Policy by June 30, 2024.
NIH has provided additional information regarding the foreign subaward provision in a blog post and in FAQs that we encourage the impacted research community to review. Access may be entirely electronic and must include only the data that supports the research outcomes reported in the yearly Research Performance Progress Report.
If you have any questions about this new policy or its implementation, please refer to the resources section of the policy on Access to Foreign Subrecipient Records Funded by NIH Grants/Cooperative Agreements for contact information.