Effective January 1, 2024, the NIH Grants Policy Statement, section 15.2, Administrative and Other Requirements, will be updated to enhance monitoring, documentation, and reporting requirements for recipients with foreign subrecipients.

To implement the policy update at the University of Iowa, the Division of Sponsored Programs (DSP) has established the following procedures for subaward agreements with foreign recipients.  

At Proposal Stage

Foreign subrecipients must include language in their letters of support indicating their awareness that they must provide access to all records that support 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. Records may include:

• All lab notebooks
• All data
• Any documentation that supports the research outcomes as described in the progress report

 Note that access to records may be entirely electronic.

At Subaward Agreement Stage

• The recipient and subrecipient PIs will establish arrangements for meeting the updated requirements related to research records.
• DSP will add a provision to subaward agreements with foreign subrecipients formalizing the arrangements for meeting the updated requirements.

Existing Subaward Agreements

• DSP will contact PIs and departmental research administrators to amend existing subawards with foreign recipients to include the updated requirements related to access to research records.