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News & Updates

April 8, 2026

NIH: Updated Grants Policy Statement and Other Changes

Updated Grants Policy Statement

NIH has released an updated NIH Grants Policy Statement (NIHGPS). No major new changes have been identified beyond what NIH has already communicated in prior notices, but all administrators are encouraged to review the update. A helpful resource to keep abreast of NIH policy changes is the Galter Library’s list of recent updates and announcements from NIH.

Update of Late Application Submission Policy and End of Continuous Submission (NOT-OD-26-064)

NIH has issued a new notice (NOT-OD-26-064) updating its late submission policy effective for applications submitted for due dates on or after May 25, 2026, and formally ending continuous submission as of August 10, 2026.

NIH Prior Approval Requirements

NIH has issued two companion notices that significantly change how domestic subawards and prior approval requests must be handled:

  • NIH announced (NOT-OD-26-026) that effective February 21, 2026, all prior approval requests must be submitted through the eRA Prior Approval Module, standardizing the process across request types. Be sure to review Section 8.1.3 of the Grants Policy Statement for a reminder of what changes require prior approval, and submit the appropriate Award Modification Request to Sponsored Research so that we can track review, submission, and sponsor approval.
  • Historically, NIH did not require prior approval to add domestic subawards to an active award. Under the new policy (NOT-OD-26-062) effective June 1, 2026, NIH will require prior approval before adding any domestic subaward that was not included in the original peer reviewed application. All such requests must be submitted through the eRA Commons Prior Approval Module, using the “Other Request” category.

Requesting Prior Approval for a New Subaward in CERES: Because CERES does not include a dedicated “New Subaward” AMR type, requests for prior approval to add new subawards should be routed to SR using the Award Modification Request (Rebudget) type.

NIH Foreign Subawards

NIH has reiterated that foreign subawards are no longer allowed after May 1, 2025. Any new international collaboration must instead follow the PF5/UF5 application structure for NIH funded international collaborations. This shift reflects NIH’s broader effort to increase transparency and oversight of international research activities.

NIH Foreign Components

NIH is also increasing oversight of foreign components. NIH may consider activity to be a foreign component even when no funds are exchanged. Review the criteria carefully and consult with your Sponsored Research contact if there are questions. Note that coauthorship alone does not automatically constitute a foreign component, but NIH is examining these relationships more closely, particularly those with a foreign country of concern.

Department of Defense: New Research Security Rules & Risk Matrix

The Department of Defense (DoD) has issued new research security requirements effective March 9, 2026, that may affect a PI’s eligibility for funding or require mitigation. PIs may be impacted if they:

  • Collaborate with or have published (within 5 years) with entities on expanded U.S. restricted lists
  • Use foreign research equipment from restricted organizations
  • Participate in foreign talent programs or receive funding/patent support from countries of concern

A message to DoD-funded PIs and Senior/Key Personnel was sent on April 1st informing them of the new requirement. The Export Controls & International Compliance team is available to assist with questions, risk assessments, and mitigation plans.

Additional Resources

Research Security Training Refresher Now Available

Faculty and research personnel are beginning to receive reminders for the annual Research Security Training requirement. This training is required for all Federal proposals and awards and must be completed every 12 months. Once an individual passes the one-year mark from the previous completion, the course will automatically reappear in myHR Learn with a status of “Assigned.”

To reduce burden, Northwestern researchers may take a “refresher” version of the course. The “refresher” allows a researcher to retake the quiz component without rewatching the full video; if they pass, their training is renewed.  The full course remains available for anyone who wishes to take it.

For questions about the training, contact Export Controls & International Compliance (ECIC).

Zero-Dollar ($0) Proposals and Awards

Northwestern University must review and document all research proposals and agreements involving Northwestern personnel and resources, even when no funding is provided or the sponsor doesn’t require institutional endorsement. For example, some research projects might require Northwestern investigators to commit quantifiable effort or other “in-kind” support.

Proposals

Just as with any funded proposal, zero-dollar proposals must be submitted to Sponsored Research via CERES prior to submission, in accordance with the Sponsored Research deadline policy.

All regularly required proposal documentation must be provided, including:

  • Solicitation (or equivalent communication)
  • All proposal materials (e.g. the assembled proposal or Statement of Work for subawards)
  • Confirmation of PI effort (minimum 1% commitment per University policy)
  • Confirmation that any non-funded project costs will be covered by nonsponsored funds or by the external partner

These proposals will undergo a full review for all standard administrative and compliance requirements, including Conflict of Interest, if required. Following review, Sponsored Research will provide documentation of institutional endorsement via a Letter or Statement of Intent, or sign other forms as required.

Awards

When a $0 award is received, and following receipt of a complete and compliant proposal record as noted above:

  • An OTH (Other Agreement) record will be created in CERES and processed through standard review, negotiation, and signature procedures.
  • Once fully executed, a $0 AWD record and chartstring will be established to track effort, along with any required human or animal subject approvals and other award reports or deliverables

SR Reminders & Upcoming Events

  • The Sponsored Research website has been updated with expanded Help page guidance to assist users in identifying the correct point of contact for various needs.
  • SR is launching Coffee Hour Connect, a new series of virtual how-to sessions designed to be both informative and interactive. Each session will feature a focused presentation by SR staff along with dedicated time for audience questions. The first session, Subcontracts Management: Process & CERES Navigation, will take place on Wednesday, April 15, from 10:00–11:15 a.m. Register now to attend via Zoom.
  • Please be vigilant to reminders related to upcoming reporting deliverables. As a reminder, overdue reports can cause serious compliance issues for both the individual researcher and the University as a whole. Annual progress reports such as RPPRs do require a CERES record and must be routed in eRA Commons to the appropriate Award Management contact once ready for review.