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US Federal Funding: spolight on NIH

15 February 2024

From 2 January 2024, foreign subrecipients of National Institutes of Health (NIH) grants such as UCL are being asked to provide access to all documents that support research outcomes. Find out more about the changes and where to access support.

Scientist working in lab

What has changed and what is required?


The new policy requires foreign subrecipients of NIH funds to, “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.”

Prime recipients of existing NIH grants will need to update their subaward agreements to include the requirement for foreign subrecipients to provide this access. These amendments will need to be reviewed by our Contracts Services team. If you receive an amendment from the prime recipient, please submit a Contract Request in Worktribe.

To meet the requirements of NIH’s updated policy, it is essential to plan ahead with a data management plan that takes these requirements into account. UCL’s Electronic Research Notebook (ERN) may be an appropriate service for your work and can facilitate electronic access to records. There is no additional cost for use of ERN. 

You can find guidance and support on research data management and data management plans on the Library Services website. You can also view other data storage options available at UCL and their costs on the ISD website.

Further information and guidance


You can read the full final updated policy guidance on the NIH website.  

Queries about US Federal Funding at UCL should now be directed to our Award Services European Research and Innovation Office (ERIO) team. Please get in touch with your usual departmental ERIO contact for support or advice.