Closeout Requirements During Appeals of Terminations of NIH Research Grants

Ropes & Gray – On July 7, 2025, the National Institutes of Health (NIH) Office of Policy for Extramural Research issued NOT-OD-25-128, titled “Guidance on Enforcement of Closeout Requirements During the Appeals Process.” The Notice indicates that if an award recipient has submitted a timely appeal to NIH in response to an award termination notice, NIH will not, during the pendency of such appeal, act unilaterally to close out the award based on technical non-compliance with closeout requirements.