New NIH Notices Released
On July 18, 2025 the Office of Sponsored Programs sent the following information through the OSPCommunications list serv.
The National Institutes of Health opens in a new tab (NIH) has released three notices stating new requirements concerning the use of Artificial Intelligence (AI) and calendar year limits on applications, Other Support training, and an update on foreign subawards. This communication serves as an informational notice on these new requirements. Further guidance will be forthcoming on UNC implementation for each notice.
NOT- OD-25-132: Supporting Fairness and Originality in NIH Research Applications
This notice provides guidance regarding the appropriate use of AI in proposal applications and frequency of Principal Investigator (PI/PD) submissions.
Key Points
- Effective for applications submitted on and after September 25, 2025.
- NIH will not consider applications substantially developed with AI.
- If AI usage is detected post award, applications may be referred to the Office of Research Integrity and subject to enforcement actions.
- NIH will limit each individual PI/PD, or multiple PI/PDs to a calendar year maximum of six new, renewal, resubmission, or revision applications across all council rounds.
NOT- OD-25-133: New Policy Requirement to Train Key Personnel on Other Support Disclosure Requirements
This notice requires NIH recipients to provide training to all faculty and researchers designated as Senior/Key Personnel on the obligation to disclose all active and pending research activities and affiliations in their OS disclosure.
Key Points
- Effective October 1, 2025, recipient institutions must implement training for OS disclosure and maintain a written and enforced policy.
- Senior/Key personnel required to disclose all research activities and affiliations, both active and pending, regardless of monetary value and whether activity is based at the institution listed on the current grant.
The Research Compliance Services Office is aware of these new training requirements and will provide additional information on UNC implementation.
NOT- OD-25-130: Supplement for Foreign Subawards Involving Human Subjects Research on Active Projects
This notice outlines the implementation of the NIH Policy on Foreign Subawards (NOT-OD-25-104) by introducing a temporary measure that allows foreign supplements for active subawards involving human subjects research, such as clinical trials and clinical studies.
Key Points
- NIH Institutes, Centers, and Offices may renegotiate awards to financially separate foreign subawards involving human subjects research from the prime award to award them as administrative supplements (i.e., Type 3 awards).
- Each foreign supplement (involving human subjects research) award will only include funds allocated for a single foreign entity.
- Separate annual Federal Financial Reports (FFR, SF-425) must be submitted for each foreign supplement.
- Prime and foreign supplements will be excluded from SNAP (Streamlined Non-Competing Award Process), including restrictions on automatic carryover authority.
- No rebudgeting is allowed between the prime award and supplements within a budget period. Reallocation of future year commitments may be requested via the annual progress report (RPPR) process; total costs must remain within previously committed limits.
- Available only for the current competitive segment and does not replace the new award structure outlined in NOT-OD-25-104, which will apply to future applications, including planned renewals.
Resources and Contacts
NIH Resources
- NIH NOT-OD-25-132: Fairness and Originality in NIH Research Applications
- NIH-NOT-OD-25-133: Train Senior/Key Personnel on Other Support
- NIH NOT-OD-25-130: Implementation of Foreign Supplements
- NIH NOT-OD-25-104: Updated NIH Policy on Foreign Subawards
- NIH Other Support Resources
UNC Resources
- OSP Other Support & Biographical Sketch Guidance
- OSP Guidance on NIH Foreign Subawards
- Biosketch & Other Support Training Module
- UNC Health Sciences Library NIH Biosketch Guidance
- General sponsored programs questions, email SponsoredPrograms@unc.edu
- Proposal questions, contact your department’s OSP Sponsored Projects Specialist or School of Medicine Sponsored Programs Office Grants Analyst