NIH reissued its Grants Policy Statement in March 2026, superseding the April 2024 edition via Guide Notice NOT-OD-26-057. The revision consolidates every NIH Guide Notice in effect as of 17 March 2026, adds a new prior-approval requirement for domestic subawards, harmonises NIH’s definition of “intervention” with the Common Rule, and folds in the zero-embargo public access requirement that took effect on 1 July 2025. For institutions managing NIH awards, the practical effect is a single, current reference document — but several of its changes carry hard compliance deadlines that pre- and post-award offices need to act on now.
The NIH Grants Policy Statement (NIHGPS) is NIH’s primary vehicle for setting standard terms and conditions on grants and cooperative agreements, applied by incorporation into every Notice of Award. The March 2026 revision (rev. 03/2026) applies to all NIH grants and cooperative agreements with budget periods beginning on or after 1 October 2025, and formally supersedes the April 2024 version.
Contents
- What changed in the March 2026 NIHGPS revision
- New prior-approval requirement for domestic subawards
- Terminology shifts and Common Rule alignment
- Where the update meets the zero-embargo public access rule
- What institutions should do now
- Answer-first Q&A
What changed in the March 2026 NIHGPS revision
NIH announced the revised NIHGPS through Guide Notice NOT-OD-26-057, published 25 March 2026. The notice states the update “incorporates new and modified requirements, clarifies certain policies, and implements changes in statutes, regulations, and policies” made since April 2024. Institutional summaries from Northeastern University and Washington University in St. Louis flag further administrative shifts folded into this edition: expanded research-security disclosure across the award lifecycle, new guidance restricting generative AI use in applications and peer review, tighter limits on concurrent applications per principal investigator, and confirmation that childcare costs are allowable for full-time NRSA trainees and that dependent-care resources are allowable for conference-grant participants.
The table below summarises the notices anchoring the update, each with its own effective date — a distinction institutions often miss when treating the NIHGPS as a single-date change.
| Guide Notice | Change | Effective date |
|---|---|---|
| NOT-OD-26-057 | Publishes revised NIHGPS (rev. March 2026), supersedes the April 2024 edition | Awards with budget periods starting on/after 1 October 2025 |
| NOT-OD-26-062 | New prior-approval requirement for post-award domestic subawards | 1 June 2026 |
| NOT-OD-26-063 | Harmonises the NIH definition of “intervention” with the Common Rule (45 CFR 46, Subpart A) | 27 March 2026 |
| NIH foreign-subaward policy | NIH no longer recognises foreign subawards; new PF5/UF5 application structure required for international collaborations | 1 May 2025 |
| 2024 NIH Public Access Policy (accelerated by NOT-OD-25-101) | Zero-embargo deposit of peer-reviewed manuscripts in PubMed Central | 1 July 2025 |
New prior-approval requirement for domestic subawards
Effective 1 June 2026 under NOT-OD-26-062, prime recipients must obtain NIH prior approval before adding a new domestic subaward to a project post-award, whenever that subaward arrangement was not part of the originally peer-reviewed and approved application. NIH states the requirement exists so it “is aware of all subaward activities for each NIH project,” supporting monitoring and reporting compliance further down the award chain.
Requests must be submitted through the eRA Commons Prior Approval Module, using the “Other Request” type. For Small Business Innovation Research and Small Business Technology Transfer awards, the March 2026 NIHGPS goes further: recipients must seek prior approval for any new subaward and include a foreign risk assessment of the proposed subrecipient.
This sits alongside a harder line already in force: since 1 May 2025, NIH has not recognised foreign subawards. International collaborations must instead use NIH’s PF5/UF5 application format.
Terminology shifts and Common Rule alignment
Two changes in the March 2026 NIHGPS are easy to miss because they read as drafting cleanup rather than policy change, but both affect how compliance offices should tag and search award documents.
- “Facilities and Administration (F&A) Costs” is now “Indirect Costs” throughout the NIHGPS, aligning NIH’s terminology with 2 CFR 200 (the Uniform Guidance).
- “Non-Federal entity” has been replaced with “recipients and subrecipients” — a distinction that matters for institutions cross-referencing older award language against the current document.
Separately, under NOT-OD-26-063, effective 27 March 2026, NIH adopted the Common Rule’s definition of “intervention” — “both physical procedures by which information or biospecimens are gathered (e.g., venipuncture) and manipulations of the subject or the subject’s environment that are performed for research purposes” (45 CFR 46, Subpart A) — replacing its own prior operational definition. NIH frames this as harmonising human-subjects implementation “across federal agencies,” reducing ambiguity when institutions classify a study as a clinical trial, a basic experimental study involving humans, or an observational study.
Where the update meets the zero-embargo public access rule
The March 2026 NIHGPS does not introduce a new public access policy — it consolidates the one that already reshaped NIH-funded publishing. The 2024 NIH Public Access Policy took effect on 1 July 2025, after NIH accelerated its original 31 December 2025 target date. Under the policy, any peer-reviewed manuscript arising from NIH funding and accepted for publication on or after 1 July 2025 must be deposited in PubMed Central for immediate public availability, with no embargo period permitted.
For award administrators, the intersection matters because the same Notice of Award terms and conditions that reference the NIHGPS now also carry the zero-embargo requirement as a standing condition of every applicable award — not a separate library-services matter. Institutions that track compliance by Notice of Award language, rather than by publication date alone, should confirm their research-output tracking systems flag manuscripts by acceptance date against the 1 July 2025 threshold, since the obligation attaches at acceptance, not at final publication.
What institutions should do now
Sponsored-programs offices should treat the March 2026 NIHGPS as a trigger for three concrete actions. First, update subaward-change checklists to route any new domestic subaward through the eRA Commons Prior Approval Module before 1 June 2026. Second, audit standard operating procedures for the terminology shift from “F&A Costs” to “Indirect Costs” and from “non-Federal entity” to “recipients and subrecipients,” since document searches keyed to the old terms will miss current guidance. Third, confirm research-output compliance tracking distinguishes manuscripts accepted before and after 1 July 2025, given the zero-embargo requirement now sits inside the same consolidated policy document as the award terms.
The stakes are not abstract. NIH’s total FY2026 budget for extramural grants and contracts is approximately $38 billion, yet the overall number of grants awarded is running roughly 25% below levels typical for a comparable date in 2021–2024, according to reporting in Science. Against that backdrop, missteps on prior approval or subaward compliance carry a higher relative cost: fewer awards means less institutional tolerance for a stalled or non-compliant action.
Answer-first Q&A
What is the NIH Grants Policy Statement?
The NIH Grants Policy Statement is NIH’s standard terms-and-conditions document for grants and cooperative agreements, incorporated by reference into every Notice of Award. NIH reissues it periodically — most recently in March 2026, superseding the April 2024 version — to consolidate Guide Notices and reflect statutory, regulatory, and policy changes.
What is the NIH salary cap for 2026?
Effective 1 January 2026, the NIH salary cap increased to $228,000, up from $225,700 in 2025. This is a 12-month cap; institutions with 9-month faculty appointments must prorate the figure accordingly for budgeting and rebudgeting purposes on active awards.
When does the March 2026 NIHGPS take effect?
The revised NIHGPS applies to all NIH grants and cooperative agreements with budget periods beginning on or after 1 October 2025. It consolidates NIH Guide Notices in effect as of 17 March 2026 and supersedes the prior, April 2024 edition of the document.
Does the NIH Grants Policy Statement cover public access requirements?
Yes. The NIHGPS incorporates the 2024 NIH Public Access Policy, which took effect 1 July 2025 and requires zero-embargo deposit of peer-reviewed manuscripts in PubMed Central for any paper accepted for publication on or after that date.
The bottom line for award administration
The March 2026 NIHGPS is best read as a consolidation exercise with two genuinely new compliance obligations — the domestic subaward prior-approval rule taking effect 1 June 2026, and the Common Rule-aligned “intervention” definition already in force since 27 March 2026 — layered onto a document that now also carries the zero-embargo public access requirement as standing award language. Institutions that update subaward workflows, terminology-dependent search tools, and publication-tracking systems ahead of the June deadline will avoid the compliance gaps that a document reissue of this scope typically exposes.
For related context on how research-administration offices track compliance obligations across funders, see CASRAI’s research administration resources.