October 23, 2023
Summary:
Effective 1/1/24. foreign subrecipients must “provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year."
Additional Information:
Per NIH's 9/15/23 update, foreign subrecipients must “provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic” (emphasis added). This updated guidance will be effective 1/1/24. NIH's original Notice was published on 5/19/23; they have revised the timeframe requirement with the September update.
NIH “expects recipients to ask potential subrecipients, at the application stage, to submit language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued.”
Who does this affect?
Per NIH requirements, that Penn State must revise existing foreign subawards within 60 days of the effective date of this notice to include this new requirement. (If you have a foreign subaward or subcontract under an existing NIH grant, the Office of Sponsored Programs will be reaching out to your foreign subrecipient to implement this required revision to the terms and conditions.)