About

About the NIH Subaward Prior-Approval Checker

This is a narrow decision-support tool for NIH grants offices reviewing whether a proposed post-award subaward change requires prior approval under NOT-OD-26-062.

The rule is intentionally simple. Prior approval is required when the proposed change is a subaward, the subrecipient is new to the project, the arrangement was not part of the peer-reviewed and approved application, and the subaward is domestic. If any required input is missing or ambiguous, the tool routes the matter to human review.

What the tool does

The checker asks for the approved baseline and the proposed change. It returns a determination, a plain-language rationale, the rule path, the citation, and an audit trail. When prior approval is required, it drafts text for the eRA Commons Prior Approval Module using the Other Request type.

What the tool does not do

The checker does not submit anything to NIH. It does not decide foreign subaward rules. It does not make official NIH determinations. A grants officer must review the inputs, the source documents, the generated draft, and the final eRA Commons submission.

AI boundary

The model may extract approved subrecipients and budget notes from an uploaded PDF and may draft a justification narrative. The model never decides whether prior approval is required. That determination comes from a deterministic rule engine so the answer is reproducible.

Why this exists

The risk in this workflow is not that grants officers cannot read the notice. The risk is that mid-project changes happen under time pressure, with inconsistent source documents and uneven institutional memory. This tool makes the rule path visible enough to review, challenge, and save.