NIH Ends Foreign Subawards, Requires New PF5 Grant Type for International Research

Researchers planning NIH-funded projects with foreign collaborators face a structural overhaul: the agency will no longer issue awards that include subawards to foreign entities. Instead, all competing applications requesting foreign components must use a new grant type under PA-26-002, the Collaborative International Research Project mechanism.

The parent funding opportunity begins accepting submissions on April 25, 2026.

What Changed and Why It Matters

NIH announced the policy shift on September 12, 2025, with an effective date of January 25, 2026 for applications with foreign components. The rationale, per the agency: "NIH must ensure it can transparently and reliably report on each dollar spent on foreign collaborations."

The practical impact is sweeping. Any domestic institution that previously routed international work through standard subaward agreements must now restructure those arrangements. The new PF5 mechanism creates a separate, trackable funding pathway for every foreign component — meaning additional paperwork, revised budgets, and new compliance workflows for sponsored programs offices nationwide.

Who Needs to Act Now

The policy affects three groups immediately:

• PIs with active foreign collaborations who plan to submit competing renewals or new applications after January 25, 2026
• Sponsored programs administrators who must learn the PA-26-002 submission mechanics before the April 25 opening
• Foreign partner institutions that need to understand how the new mechanism changes their role in U.S.-funded research

Universities including Washington University have already begun issuing guidance to their research communities, urging faculty to consult their grants offices well before the April submission window.

Parallel NIH Policy Changes Compound the Burden

The foreign collaboration restructuring arrives alongside two other NIH compliance deadlines. Applications submitted after January 25, 2026 must use SciENcv Common Form versions for biosketches and Other Support documents — NIH is currently providing warnings but will eventually reject non-compliant submissions. And as of February 20, 2026, all prior approval requests must go through the eRA Prior Approval Module.

Taken together, these changes represent the most significant overhaul of NIH administrative requirements in years. Grant seekers tracking multiple federal deadlines can use tools like Granted to monitor shifting requirements across agencies. The April 25 PA-26-002 opening is the date to circle.