Effective May 1, 2025, NIH has updated their policy on foreign subrecipients (NOT-OD-25-104). The policy states that “NIH will not issue awards to domestic or foreign entities (new, renewal or non-competing continuation), that include a subaward to a foreign entity. Additionally, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.” NIH has indicated that they “will not retroactively revise ongoing awards to remove foreign subawards at this time,” and that they will allow institutions to rebudget, identify an alternate domestic collaborator, or negotiate a termination if no alternate is feasible.