Effective June 1, 2026, NIH prime recipients must obtain agency prior approval before adding a new domestic subaward to an active project, if that subrecipient arrangement was not part of the original peer-reviewed and approved application. The requirement comes from NOT-OD-26-062, “Prior Approval Requirement for Changes to Domestic Subawards,” issued through the NIH Guide for Grants and Contracts. This is a distinct, newer rule from the policy change that ended new traditional foreign subawards — see the distinction below before assuming one notice covers both cases.
What NOT-OD-26-062 requires
Under the notice, a prime recipient that wants to add a new domestic subaward to a project after the award has already been made — where that subrecipient was not identified in the application NIH originally reviewed and funded — must first request and receive NIH prior approval. NIH states the purpose plainly: the agency wants visibility into all subaward activity under a project so it can carry out its existing subrecipient monitoring and reporting obligations. A subaward that was already named in the peer-reviewed application does not trigger this requirement — it applies specifically to arrangements added post-award that were not part of what NIH’s reviewers actually evaluated.
How this differs from the NIH foreign subaward policy
CASRAI already covers a related but separate NIH change: effective May 1, 2025, NIH stopped recognizing new foreign subawards altogether, requiring institutions to restructure international collaborations as independent subprojects (the PF5/UF5 application structure) rather than traditional subawards to a foreign entity. See CASRAI’s NIH Foreign Subawards guide for that policy in full.
NOT-OD-26-062 is not an extension of that 2025 foreign-subaward overhaul. It addresses domestic subawards — arrangements between a prime recipient and a subrecipient organization within the United States — and it does not ban or restructure them the way the 2025 policy did for foreign subawards. Instead, it adds a prior-approval checkpoint: NIH must sign off before a new domestic subrecipient relationship not contemplated in the funded application can begin. Research offices should treat the two as separate compliance obligations that happen to both involve the word “subaward” — a domestic subaward change now needs NIH prior approval under NOT-OD-26-062; a new foreign subaward arrangement is governed by the May 2025 policy and the PF5/UF5 structure, not by this notice.
How to request prior approval
NOT-OD-26-062 directs recipients to submit the request through the eRA Commons Prior Approval Module, using the “Other Request” request type — NIH has not created a dedicated request type specific to domestic subaward changes, so recipients route the request through this general-purpose category. As with any NIH prior approval request, this should be submitted before the new subaward arrangement is put in place, not after the fact, and the request should identify the subrecipient and describe how the arrangement was not part of the originally approved project scope.
What this means for research offices right now
For any NIH award active on or after June 1, 2026, a sponsored-programs office adding a domestic subrecipient that was not named in the funded application should build in time for a prior-approval request and NIH review before executing the subaward agreement or allowing subrecipient work to begin. This is a process change, not a funding restriction — NIH is not limiting who can be added as a domestic subrecipient, only requiring advance notice and sign-off so the agency retains visibility into subaward activity across its portfolio. Institutions that already route consortium and subaward additions through a centralized pre-award or grants-management workflow are best positioned to add this checkpoint cleanly; those that have historically allowed a PI or department to add a domestic subrecipient informally post-award will need to close that gap before June 1, 2026.
Source
This summary is drawn directly from NIH’s own notice, NOT-OD-26-062, “Prior Approval Requirement for Changes to Domestic Subawards”, published in the NIH Guide for Grants and Contracts. Research offices should confirm current requirements against NIH’s own notice text, and against their institution’s eRA Commons guidance, before submitting a specific request.
