Not in the way the steep FY2026 cuts proposed by the White House might suggest: those cuts were a budget request, not the funding level Congress enacted. NIH says the Consolidated Appropriations Act, 2026 provided $47.5 billion in program-level funding, 1% more than in FY2025. Separately, NIH did implement a major change to how many new projects involving foreign research sites must apply for and receive funding. That rule changes the funding process, but official sources reviewed do not quantify resulting losses to research outside the United States.
Were the proposed NIH budget cuts enacted?
No. The sharp NIH-wide reductions discussed for FY2026 appeared in the President’s budget request; they were not the final appropriation. NIH’s fiscal notice says the Consolidated Appropriations Act, 2026, signed February 3, 2026, provided $47.5 billion in program-level funding, including $226 million under the 21st Century Cures Act. NIH describes this as a 1% increase over FY2025. NIH’s FY2026 fiscal notice also says noncompeting continuation awards generally issue at the commitment level shown on the Notice of Award, subject to exceptions and later budget-period conditions.
A Senate Appropriations Committee release describes $48.7 billion for NIH biomedical research. That release and NIH’s notice use different labels and the sources reviewed do not explain how the totals reconcile. For the implemented funding level, NIH’s $47.5 billion program-level figure is the clearest operational figure; the committee’s $48.7 billion should be attributed to that release rather than combined with it. Senate Appropriations Committee release.
Projections based on the President’s requested cuts should not be treated as actual FY2026 outcomes. For example, the Congressional Research Service analyzed potential competing-grant effects under the proposed level; those projections do not describe grants awarded under the enacted appropriation. Congressional Research Service analysis.
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What changed for NIH-funded international research?
NIH changed the award structure for foreign subawards. Under the traditional route, a U.S. institution could receive an NIH award and pass part of the funding to a foreign organization as a subaward. NIH’s May 2025 policy ended that route for new applications requesting support for foreign components and established independent foreign awards linked to the U.S. prime institution. NIH said the policy applied prospectively to grants and cooperative agreements, including new, renewal, and noncompeting continuation awards, and said it would not retroactively remove foreign subawards from ongoing awards at that time. NIH’s May 2025 notice.
For competing applications with foreign components, the later implementation requires a funding opportunity announcement that supports a PF5 grant, UF5 cooperative agreement, or another complex mechanism supporting an International Project component. The new structure applies to applications with due dates on or after January 25, 2026. NIH’s application guidance and implementation announcement.
How the PF5/RF2 or UF5/UL2 structure works
- Apply through a U.S. organization. The U.S.-based organization is the primary applicant and submits an application with an Overall component, a Research Project component, and an International Project component.
- Separate international collaborators by institution. Each foreign institution involved requires a separate International Project component.
- NIH reviews components. NIH evaluates the overall project and individual components; separating them does not guarantee that any component will receive funding.
- Receive linked awards if selected. A funded foreign component can be issued as a linked RF2 award for a PF5 grant or UL2 award for a UF5 cooperative agreement. The foreign organization is responsible for its own award terms and financial reporting.
This is a change in application, award, and financial-reporting structure—not a general prohibition on international research or on all NIH funding for foreign organizations. NIH continues to make direct foreign awards. Its notice also identifies foreign consultant support and purchases of unique equipment or supplies from foreign vendors as examples outside the foreign-subaward rule.
Which projects count as having a foreign component?
NIH defines a foreign component as a significant scientific element or segment of a project performed outside the United States. It can be carried out by the recipient or by a researcher employed by a foreign organization, and it can qualify whether or not grant funds are spent abroad. The definition focuses on the research activity, not just the destination of a payment. NIH’s foreign-component guidance gives examples including:
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- Human-subject or animal research conducted at a foreign site.
- Extensive foreign travel to collect data.
- Some collaborations with foreign researchers expected to result in coauthorship.
- Use of foreign facilities or instrumentation.
- Resources provided by a foreign entity.
Because NIH’s definition can cover significant research activity even when no money is spent abroad, a project’s eligibility and application route cannot be determined simply by checking whether it has a foreign subaward.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What does this mean for research funding beyond U.S. borders?
The established effect is procedural: U.S. applicants and foreign collaborators covered by the policy may need to prepare linked components, meet separate award requirements, and manage financial reporting by recipient organization. Foreign institutions may receive NIH funding through linked awards when NIH selects their components, or through direct foreign awards where applicable.
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NIH’s May 2025 notice said that if a project could not remain viable without its foreign subaward, NIH would work with the recipient to negotiate bilateral termination, taking patient safety and animal welfare into account. That describes a possible response for affected projects; it is not evidence of how many projects ended or how much funding was lost.
The official sources cited here do not provide country-by-country losses, establish a net reduction in NIH dollars reaching foreign collaborators under enacted FY2026 appropriations, or quantify effects on global health research output. It is therefore accurate to say the route for many new international collaborations changed, but not to assign a specific global funding loss or downstream scientific effect on this evidence. NIH’s budget and the foreign-subaward restructuring are distinct developments: the proposed NIH-wide cuts were not enacted, while the award-structure change was implemented.
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Why does NIH say it changed the rules?
NIH cites transparency, reliable reporting of each dollar, oversight, and national security as reasons for restructuring foreign subawards. NIH Director Jay Bhattacharya also said the agency expects international-site research to have a clear scientific reason for being conducted abroad and direct potential to generate knowledge applicable to understanding, improving, or protecting Americans’ health. In his August 25, 2025 statement, he said, “All research supported at international sites should have a clear scientific rationale to be conducted in a foreign country rather than in the United States.” NIH Director’s statement. These are NIH’s stated justifications, not independent evidence that the previous system failed or that the new structure will produce better outcomes.
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