Over the last several years, the federal government and federal funding agencies have raised concerns regarding research security and undue foreign influence on federally funded research. As a result, many federal funding agencies, including the National Institute of Health (NIH), have revised what information they require from investigators to appropriately assess available resources and other sources of support. A summary of NIH’s efforts to address foreign influence concerns can be found at their webpage Protecting U.S. Biomedical Intellectual Innovation. As part of this effort, NIH issued Policy Notice NOT-OD-19-114, Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components, and the accompanying FAQs in July 2019. This clarifying guidance from NIH outlines requirements that differ from what was previously understood to be required of applicants and awardees. A summary of these current NIH requirements follows.

NIH Disclosure Requirements Matrix - Updated June 8, 2022

NIH Disclosure FAQs

 

Foreign Contracts

NIH requires researchers to provide foreign contracts, grants or any other agreements specific to senior/key-personnel foreign appointments, affiliations, and/or employment with a foreign institution. Copies must be provided as part of the PDF following the Other Support format page.

The requirement to provide foreign contracts, grants or any other agreements applies to all Other Support information submitted on or after January 25, 2022. In the Research Performance Progress Report (RPPR) for ongoing grants, recipients must provide copies of foreign contracts, grants or any other agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support.