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Prior Approval Requirement for Changes to Domestic Subawards

National Institutes of Health (NIH)

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This guide notice updates the NIH requirements for obtaining prior approval for changes to domestic subawards on all NIH grants and cooperative agreements. NIH has a longstanding policy of not requiring prior approval for the addition of domestic subawards to ongoing projects. This makes tracking and oversight of subawards challenging, and NIH needs to be aware of all subawards in order to effectively track compliance with the Federal Funding Accountability and Transparency Act (see NIH Grants Policy Statement 4.1.8). Effective June 1, 2026, all prime recipients are required to obtain NIH prior approval when adding a new domestic subaward to a project post-award, when the arrangement was not originally a part of the peer-reviewed and approved application. The new prior approval requirement...

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