NIH Grants – subrecipients to provide copies of all lab notebooks, data and documentation

Departments who receive funding from the National Institutes of Health (NIH) need to be aware of the updated NIH Grants Policy Statement, section 15.2

For foreign subrecipients, a provision requiring the foreign subrecipient 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.

Grant recipients will need to comply with this updated policy guidance by 2nd March 2024.

In particular, please be aware that: 

• this policy affects existing agreements which means that that existing subrecipient contracts must be amended to include this new requirement by March 2023. 
• documents can be electronic and shared in secure platforms such as Onedrive, SharePoint, Teams etc. These documents do not need to be shared with the entire collaboration but only the lead to oversee the project effectively.

In those instances where the University is the prime recipient of NIH funding, the Research Operations Office will be in touch to provide specific guidance on the compliance requirements.

We will be providing more support and guidance in due course, but if you have any immediate queries, please contact crocompliance@admin.cam.ac.uk