New NIH Policy Requires Foreign Subrecipients to Share Lab Notebooks and Research Data with the US Prime Awardee

September 27, 2023

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The National Institutes of Health (NIH) recently moved forward with a controversial new policy requiring foreign subrecipients to provide, at least once per year, copies of lab notebooks, data and documentation that support research outcomes described in a progress report to the prime award recipient. The new policy is in direct response to recent audits conducted by the Department of Health and Human Services, Office of Inspector General (DHHS OIG) and the Government Accountability Office (GAO), each of which raised concerns about NIH’s oversight of funds provided to, among other institutions, the Wuhan Institute of Virology. More generally, the new NIH policy is among the latest salvos in the government’s ongoing efforts to impose stricter security requirements on U.S. taxpayer-funded research.

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