NIH Restrictions on Shipping Human Biospecimens and Countries of Concern
Effective October 24, 2025, the NIH instituted a policy, which “applies to all human clinical and research biospecimens obtained from U.S. persons (regardless of identifiability) that are collected, obtained, stored, used, or distributed and that are supported or funded by any on-going or new NIH funding mechanisms (grants, cooperative agreements, contracts, Other Transactions, and intramural support) regardless of NIH funding level.” The policy prohibits the sharing of such biospecimens, directly or indirectly, with institutions or parties located in Countries of Concern - People’s Republic of China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba and Venezuela.
Pitt Intellectual Property and Supplier Processing of Specimens
To protect Pitt’s intellectual property when specimen/samples (cells, compounds, DNA) are sent to a supplier for analysis-type service, specific information needs to be known before a PantherExpress System requisition is created.
As the requestor of the analysis-type service, you need to know a) what is being shared, b) who owns it, c) what is the deliverable (i.e., another sample/specimen, a report), and d) what happens to the specimen/sample after the service is complete (i.e., return to Pitt, destroy). Your department research contact may need to provide this information to you.
The most often used suppliers for these services are listed in this supplier table. The Supplier Table reflects historically what has been shared with the supplier, who owns the specimen/sample, the deliverable(s), and what each supplier does with the specimen/sample after services are completed. If your requisition is going to one of these suppliers and the specifics of the order align to that supplier’s information in the Supplier Table, you don’t need to send the specifics to Purchasing Services but may state in a requisition comment that the order aligns to the table.
If the supplier is not in the Supplier Table or your requisition doesn’t align to the information in the Supplier Table, you are responsible for gathering and documenting: a) what is being shared, b) who owns it, c) what is the deliverable, and d) what happens to the specimen/sample after the service is complete.
Upon gathering the above information, Purchasing Services recommends you keep a copy for your records for audit purposes. If the requisition is over $15,000, the information needs to be included with the requisition (either as a comment or an attachment). Requisitions over $15,000 will be returned if the information is missing.