Research Security: New NIH Policy Requires Foreign Subrecipients to Share Lab Notebooks & Research Data With the U.S. Prime Awardee

On September 15, 2023, the National Institutes of Health (NIH) 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…
By: Akin Gump Strauss Hauer & Feld LLP