The National Institutes of Health (NIH) has again updated requirements for foreign subrecipients on NOT-OD-23-182.
Key Changes
- New Start Date: January 1, 2024, a change from October 1, 2023.
- Updated Frequency: All research data (lab notebooks and other documentation) must be shared with UNC once per year in line with Research Performance Progress Reports (RPPR) requirements. This is a change from the previous requirement of every 3 months.
Guidance – Coming Soon
The Office of the Vice Chancellor for Research (OVCR) is currently working to develop guidance for the research community with the below parameters on roles and responsibilities.
OVCR Responsibilities:
- Office of Sponsored Programs (OSP) and Research Science and Security (RSS) will work to finalize guidance documentation
- OSP and RSS will serve as the primary point of contact with NIH for general compliance inquiries.
- OSP will coordinate and be responsible for agreement language and any requests concerning agreements from NIH.
- Updated Outgoing Sub LOI Form with a version date of 10/1/23 remains in effect and should be currently used for all upcoming proposals or revisions submitted after October 1, 2023.
PI and Research Team Responsibilities:
- Ensure progress reports and all other required lab notebooks and data are consistently and completely uploaded in LabArchives or otherwise collected, maintained, stored, and provided to NIH upon request.
- Sharing, when appropriate, draft language with foreign subrecipients to include in their letter of support.
- Working collaboratively with OSP and RSS to maintain subrecipient relationships including assisting in explaining the purpose and source of these new requirements.
Resources
- OVCR Updates on NIH Policy for Subawards
- CFR 200.332: Requirements for pass-through entities
- Availability of Research Results: Publications, Intellectual Property Rights, and Sharing Research Resources
- Recipient Reporting of Subrecipient Data and Executive Compensation Information for FFATA
For questions or concerns on this new requirement, please contact Quinton Johnson at quinton@unc.edu.
For questions related to specific proposals, please get in touch with your department’s OSP Sponsored Projects Specialist or School of Medicine Sponsored Programs Office Grants Analyst.
For all other general inquiries, email SponsoredPrograms@unc.edu.