Reminder of Compliance Requirements for NIH Extramural Recipients Related to Renegotiated Aims, Objectives, Titles, and Abstracts

NIH has issued a reminder to NIH awardees that changes in scope represent new terms and conditions, with which recipients must comply. The reminder applies to grants, cooperative agreements, and other transactions.

Policy

Awardees are reminded that all changes in scope that were agreed upon by NIH and the Authorized Organizational Representatives (AOR) become new terms and conditions of award, and the recipient must comply with those changes. This includes changes in scope that were renegotiated to align with the agency’s priorities. As such, NIH fully expects recipients to comply with the new terms and conditions, unless otherwise stated in the Notice of Award, or unless NIH has been enjoined by court order from imposing or enforcing such terms while that court order is in effect.

If recipients have questions related to the new terms and conditions of the awards, the recipient must seek clarification from the Grants Management Official, prior to drawing down on the funds. Once the funds are drawn down from the HHS payment system, the recipient agrees to the terms and conditions of the award and must fully comply with them.

Please be advised that if NIH discovers that recipients have not complied with the new terms and conditions of their award, NIH can immediately take an enforcement action under 2 CFR 200, as appropriate, which includes termination for non-compliance under 2 CFR 200.340(a)(1). 

Full notice

National Institutes of Health
NOT-OD-26-007
November 18, 2025

Updated Terms and Conditions of Award – Termination and Compliance with Court Orders

Effective October 1, 2025, all new NIH Notices of Award will include the following terms:

This award is subject to the termination provisions at 2 CFR 200.340. Pursuant to 2 CFR 200.340, by accepting an NIH award, the recipient agrees that continued funding for the award is contingent upon the availability of appropriated funds, recipient satisfactory performance, compliance with the Terms and Conditions of the award, and may also otherwise be terminated, to the extent authorized by law, if the agency determines that the award no longer effectuates the program goals or agency priorities, in line with 2 CFR 200.340(a)(4).

Any term or condition in this Notice of Award, including those incorporated by reference, that NIH is enjoined by court order from imposing or enforcing, shall not apply or be enforced as to any recipient or subrecipient to which that court order applies and while that court order is in effect.

Additionally, the new Notices of Award will reference 2 CFR 200 instead of 45 CFR Part 75, where applicable.

These terms of award will be applied prospectively to new, renewal, supplement, or continuation awards issued on or after October 1, 2025.

The updated language will also be incorporated into the FY26 version of the NIH Grants Policy Statement.

Full notice

National Institutes of Health
NOT-OD-26-009
November 18, 2025