Global health threats don’t respect borders — they require strong collaborations and trust across partners. Yet a new policy from the National Institutes of Health blindsided U.S. researchers and could immediately upend the international research collaborations critical for understanding and responding to global health threats.
Most of NIH’s research is conducted through grants awarded to U.S. universities and research institutions. When these projects involve collaborative work overseas, U.S.-based researchers need to establish subcontracts with international partners who have the local expertise and infrastructure needed to carry out the research.
For example, for a U.S. research team to be able to study the development of HIV drug resistance in sub-Saharan Africa, they need to develop and put in place subcontracts with Africa-based research teams and local clinics providing HIV treatment. Those collaborators can then hire or pay staff members to help the U.S.-based team develop the research protocol that is tailored to the local context, obtain local ethical approval, administer the research project (including consenting of participant volunteers, collection of specimens and other scientific data, conduct laboratory testing), collaborate on data analysis, and co-author scientific manuscripts to disseminate the research findings. Subcontracts outline the scope of work, deliverables, and a budget, and also help ensure scientific and fiscal accountability to the scientists leading the project.
On May 1, without warning NIH announced a disruptive policy that affects both new and active grants, eliminating the use of subcontracts with research partners at institutions outside the U.S. Instead, those institutions must apply to become direct NIH grantees themselves. This policy shift effectively eliminates — sometimes immediately — the support for many of the NIH’s most impactful global scientific collaborations, leaving scientists unable to pay staff or cover operating costs, while they await a yet-to-be-defined process that won’t be available until the end of September at the earliest. The lack of a clear process and guidance on how to move forward is immediately affecting an estimated 1,800 active international health research projects totaling $10 billion in U.S. taxpayer investment, including ongoing clinical trials in which participants are receiving drugs, vaccines, or other interventions under investigation whose impacts are not yet — and may never be — known.
Many of the affected global research projects have not only generated knowledge that has saved lives abroad but also driven innovation here in the U.S. This sweeping policy change effectively slows or halts scientific progress against HIV, tuberculosis, Covid-19, mpox, and other fast-moving epidemics.
The NIH claims this new policy is needed to improve oversight, protect national security, and ensure that research funded by U.S. taxpayers advances U.S. interests. However, it already has systems to help ensure accountability with foreign subcontracts, and there is no evidence of widespread fund misuse justifying an abrupt policy shift that destabilizes global scientific collaborations.
I’ve spent more than 20 years in public health research, leading and collaborating on NIH-supported global studies to improve HIV treatment outcomes, including those aimed at monitoring and strengthening the impact of HIV treatment programs supported by U.S. President’s Emergency Plan for AIDS Relief (PEPFAR) and the Global Fund to Fight AIDS, TB, and Malaria. This research has been vital in helping to improve health outcomes abroad and in seeding innovations that improve HIV care delivery in the U.S. They represent a high return on U.S. taxpayer investment.
One of my international collaborations, focused on optimizing HIV treatment using data from over 40 countries, was abruptly halted due to this new NIH policy. For decades, the work on this project has shaped clinical guidelines, strengthened HIV care systems, and helped prevent infections and deaths among infants, adolescents, and pregnant women. The project, which necessarily included subcontracts to organizations in countries heavily affected by HIV/AIDS, has not been renewed because of these subcontracts, stopping work and payments to collaborators and research staff in the U.S. and abroad. Funding is being withheld while we try to find a way, without any clear guidance, to continue the research without international subcontracts.
That’s not oversight — it’s both obstructive and destructive to critical research collaborations.
This change is also hurting U.S. institutions. These partnerships support U.S. jobs, sustain university-based research teams, and train the next generation of scientists. If the NIH isolates U.S. researchers from the rest of the world, we risk falling behind — not just scientifically, but diplomatically and economically. And the U.S. risks a scientific brain drain. Indeed, as the NIH pulls back, the European Union is recruiting top U.S. scientists.
The rollout process of this policy was especially troubling. It took effect the same day it was released. There was no consultation with grantees, no public comment period, and no transition plan. Changes of this magnitude and with such high-stakes implications should be informed by those who understand how they will play out and deployed with ample lead time to allow transition planning to minimize negative impacts. Instead, the NIH imposed the sweeping policy overnight without transparency or concern for the consequences. That’s not how good policy is made.
This policy did not arise in a vacuum. As an anonymous NIH employee recently wrote that we are witnessing a form of “impoundment” by default — a quiet and corrosive withholding of research dollars that bypasses normal oversight and appropriations processes. With the fiscal year ending in September, these policies and slowdowns in awarding grants mean that billions of dollars earmarked by Congress for NIH-supported science will be lost if they are not disbursed soon.
Many of us were worried that something like this could happen. Beginning in March, as U.S. global and domestic health policy entered a period of rapid change, more than 150 scientists and public health leaders from 41 countries — including me — signed a declaration warning that abrupt, unilateral policies like this one threaten the infrastructure needed to detect and respond to global health threats. The declaration emphasizes the essential need for global cohort studies and collaborations to fill the growing gaps in evidence and situational awareness needed to respond to and ensure continued progress against global health threats.
NIH Director Jay Bhattacharya should immediately pause implementation of this policy, at least until another workable system is in place. He should consult with scientists, funders, and global partners to develop a more workable and transparent path forward. Any new policy should avoid sweeping reforms that abruptly destabilize high-functioning systems without warning or consideration of their consequences.
Instead of an abrupt overhaul, the NIH could have introduced a transition period while finalizing the policy, with structured consultation and clear criteria for when foreign subawards will require enhanced oversight or should be elevated to direct grantees. A smarter, more efficient, and science-friendly policy would build on existing accountability tools while preserving vital scientific collaborations. Any new system should ensure that the lead institution retains both scientific and fiscal oversight of work by international collaborators that is being supported under the project.
If NIH leadership will not act, then the House Committee on Appropriations must examine whether this policy amounts to a backdoor impoundment of funds, effectively defying both Congress and taxpayers.
Global health collaborations depend on trust, continuity, and shared purpose. If we sever those ties now, the world will be slower to detect the next pathogen, lose progress against the current threats, and be more alone when the next crisis hits.
It’s not too late to protect the science and collaborative partnerships that keep us all safer. The NIH should reverse course — before the damage becomes permanent.
Denis Nash is a distinguished professor of epidemiology at the City University of New York’s Graduate School of Public Health and Health Policy. He has led large-scale public health research projects in the U.S. and abroad.
