NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (NOT-OD-23-133)


This notice updates the NIH Grants Policy Statement (NIHGPS), Section 15.2, which outlines the requirements for consortium/subaward agreements on NIH-funded grants. These updates will be incorporated into the GPS in the FY24 publication. This updated guidance is effective October 1, 2023. A Federal Register Notice announcing the updates will be posted in the coming weeks.

2 CFR 200.332(a)(5) states that subaward agreements must include, “a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part.” In response to HHS Office of Inspector General and Government Accountability Office audits, NIH has determined that to assure that this requirement is met, NIH finds it necessary to impose a requirement that foreign subrecipients turn over all records to the primary recipient at an agreed upon frequency (e.g., once a quarter, once a month). Therefore, section 15.2 is updated as follows (changes are bold and italicized)

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Last Updated on May 23, 2023