• In accordance with NSPM-33 requirements, NASA has issued a NIH Disclosure Chart on Pre- and Post-Award Disclosures, which  provides reference information regarding pre-award and post-award disclosures and includes:
  • The types of activities to be disclosed
  • Biographical Sketch; Current & Pending (Other) Support; and Facilities, Equipment, & Other Resources
  • Project Reports
  • Post-award Information Term & Condition
  • Disclosure Not Required

• NIH Biosketch Format Pages, Instructions, and Samples
• The National Institutes of Health (NIH) and National Science Foundation (NSF) have partnered to use SciENcv: Science Experts Network Curriculum Vitaeas the approved format for use in preparation of the biographical sketch section of proposals. The Intelligence Advanced Research Projects Activity has adopted this common form.
• FIU Guidance on Biosketch preparation and submission

Per NIH policy (NIH Grants Policy Statement 2.5.1) Other Support information is required for:

• All individuals designated in an application as senior/key personnel, except
  • Program Directors, training faculty, and other individuals involved in the oversight of training grants
  • Individuals categorized as Other Significant Contributors
• All senior/key personnel, excluding consultants, in progress reports when there has been a change in active other support, except Program Directors, training faculty, and other individuals involved in the oversight of training grants

Effective January 25, 2026, NIH has adopted the Common Forms for the Biographical Sketch and Current and Pending (Other Support), which include the certification of non-participation in MFTRPs. Forms are also found at:

• https://grants.nih.gov/sites/default/files/other-support-format-page-rev-10-2021.docx
• https://grants.nih.gov/sites/default/files/nih-other-support-instructions-rev-06-28-2021.docx

Supporting documentation for all foreign activities and resources that are reported in Other Support must be made available to NIH. If the contracts/agreements are not in English, recipients must provide translated copies.

Per Notice NOT-OD-26-084 (May 27, 2026), certain foreign activities may constitute both a form of Other Support as well as a Foreign Component (see below), and may represent significant risk based on the country and/or party involved.  Examples of such activities could include but are not limited to:

• Receiving use of foreign laboratory space to conduct project work
• Receipt of financial support from a foreign entity

Immediate notification of undisclosed Other Support is mandatory. If you become aware of activities or interests that should have been reported as Other Support, please notify Proposal Services immediately. Pursuant to NIH rules, FIU MUST immediately submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

• FIU Guidance on Current & Pending/ Other Support preparation and submission

Per Notice NOT-OD-26-084 (May 27, 2026), foreign components are prohibited unless allowed in the NOFO.  NIH funding recipients must disclose and receive prior approval for activities, resources, and collaborations that qualify as a “foreign component”.

As defined by NIH, a foreign component is : “[t]he performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to:

1. the involvement of human subjects or animals at a foreign site,
2. extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or
3. any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.”

Under NIH policy, examples of a “foreign component” include but are not limited to:

• collaborations with investigators at a foreign site that are anticipated to result in co-authorship;
• use of facilities or instrumentation;
• receipt of financial support or other resources from a foreign entity, regardless of whether NIH grant funds are expended or if they supported the co-author's involvement; and/or
• most instances of co-authorship.  

Even if allowed in the NOFO, ALL foreign components must be approved by NIH before work begins.  Recipients must pay close attention to the Notice of Funding Opportunity (NOFO), which outlines whether foreign components are permitted.

To avoid the appearance of a foreign component, Investigators should list their affiliations on publications to reflect where they performed the NIH-funded work, not their current address, if it is different from the performance site.

• FIU Notice re: NIH Foreign Component rule change (June 5, 2026)

A separate Collaboration and Co-author (COA) submission is not required by NIH.  However, per Notice NOT-OD-26-084 (May 27, 2026), “[m]ost instances of co-authorship represent a foreign component”, which may or may not be allowed pursuant to the NOFO for an NIH award.

Investigators are strongly encouraged to review the requirements for their NIH awards to determine if foreign collaborations are allowed.

Where investigators may have preexisting and/or ongoing collaborations with foreign entities related to an NIH award, they are encouraged to work with [OSP] and their Program Manager to evaluate next steps to report such collaboration, appropriately credit co-authorship, and/or anticipate pending co-publications.

Beginning with application due dates on or after May 25, 2026, NIH requires all Senior/Key Personnel to certify that they have completed Research Security Training  within the past 12 months of the date of application submission. (See NOT-OD-26-017)

Certification must be included in the SciENcv-generated Biographical Sketch at the time of submission. Institutions must also certify that key personnel have completed training.  AOR signature on the application serves as the institutional certification of training completion.

Please refer to the Research Security Training page for instructions on accessing and completing the training.

• FIU Notice re: NIH Research Security Training Requirements (Feb. 6, 2026)

• Effective January 25, 2026, individuals who are a current party to a  Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.
• Individual MFTRP certifications are required from applicants and individuals identified as Senior/Key Personnel, as part of their SciENcv-generated Biographical Sketch
• Annual certifications from key personnel will also be required at the time of the RPPR.
• See: NIH NOT-OD-26-018