The National Institutes of Health (NIH) is making a major change to how grant recipients can use their funds. The agency plans to end the subaward process that has been under increased scrutiny since the beginning of the COVID-19 pandemic.
The policy will first only impact subaward recipients outside of the U.S., the agency said in a notice published May 1, with the goal of eventually expanding to include domestic subawards as well.
A subaward occurs when a grant recipient redirects some of their received funds to a third party, like a research group at another university, which then carries out part of the grant’s work.
“NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant,” the agency said in the notice.
“This new award structure will include a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution,” according to the NIH. Typically, “the prime” refers to the initial recipient of a grant.
Before the new structure is fully implemented—which is expected by Sept. 30—the NIH won’t issue any new grants that include subawards to foreign institutions. However, the agency “will not retroactively revise ongoing awards to remove foreign subawards at this time,” according to the notice.
Around 15% of NIH grants included a “foreign component” in 2023, according to an April 30 report from Nature, with most ex-U.S. funds going to longtime allies like the U.K., Canada, Germany and Australia.
From 2022 to 2024, 36% of federal grant recipients who passed some funds on as subawards did not completely fulfill reporting requirements, monitor subaward recipient activities or make sure that subaward recipients were eligible to receive federal funds, according to a March 25 report from the Government Accountability Office.
“While grant recipients are responsible for overseeing their subawards, federal agencies are to ensure the grant recipients they make awards to carry out their oversight responsibilities,” a March 25 report from the Government Accountability Office concluded.
The NIH has taken steps to update the agency’s subaward policy in the past. In September 2023, the NIH implemented new requirements for foreign subaward recipients to “provide copies of all lab notebooks, all data, and all documentation that supports the research outcomes” to the primary grant recipient at least once every six months.
At the time the policy was proposed, some researchers raised concerns that the heightened scrutiny would discourage international scientific collaborations, according to a report from Nature.
This isn’t the first new NIH policy affecting foreign research institutions. April 4, the agency banned institutions in China, Hong Kong, Macau, Russia, Iran, North Korea, Cuba and Venezuela from accessing certain databases, including a cancer database used extensively by researchers in China.
Subawards were first put under the spotlight in 2020, when reports surfaced that the Wuhan Institute of Virology (WIV) was a subrecipient of an NIH grant focused on bat coronaviruses. The grant recipient that issued the subaward, U.S. nonprofit EcoHealth Alliance, had its federal funds suspended by the Department of Health and Human Services in May 2024, and both EcoHealth and the nonprofit’s former president Peter Daszak, Ph.D., were prohibited from receiving federal funds for five years in January 2025.
Though the WIV studies coronaviruses and SARS-CoV-2 first emerged in Wuhan, China, the preponderance of scientific evidence points to a natural origin for the virus, given its similarity to other bat viruses and known linkage to Wuhan’s Huanan Seafood Wholesale Market.
Despite the lack of direct evidence connecting COVID-19 and the WIV, the White House recently replaced the federal COVID-19 information website with a page promoting the “lab leak” theory.
The NIH, along with other health agencies, has been extensively targeted by the White House since Trump’s second term began in January. A document leaked earlier this month revealed the administration’s apparent plans to cut the NIH’s budget by about 40%, from $47 billion to $27 billion. The administration has also culled numerous NIH grants, rescinded the agency’s funding to universities like Harvard and fired more than 1,000 NIH staffers.