National Institutes of Health (NIH)

Disclosure Requirements

The National Institutes of Health (NIH) requires investigators and recipient institutions to disclose information regarding professional appointments and affiliations, research support, in-kind contributions, foreign components, financial interests, and other activities necessary to promote transparency, protect research integrity, and support appropriate funding decisions.

NIH disclosure requirements apply throughout the application and award lifecycle, including application submission, Just-in-Time, prior-approval requests, Research Performance Progress Reports, and award closeout. Investigators are responsible for ensuring that information provided to NIH is complete, accurate, current, and consistent with NIH requirements, their University Disclosure Profile, and other sponsor submissions.

NIH supports international research collaboration while requiring transparency regarding financial support, professional appointments and affiliations, research resources, and significant scientific activities conducted outside the United States.

University Disclosure Requirements

Before preparing an NIH application or completing NIH disclosure documents, investigators should ensure that their University Disclosure Profile is complete, accurate, and current.

Maintaining an accurate University Disclosure Profile promotes consistency across sponsor submissions and supports the University’s administration of disclosure, conflict of interest, conflict of commitment, research security, export control, and Foreign Talent Recruitment Program compliance requirements.

Sponsor disclosures are separate from—and in addition to—the University’s disclosure requirements. Updating an NIH submission does not replace the obligation to update the University Disclosure Profile.

Related University Guidance

NIH Application & Award Disclosures

NIH requires disclosure of certain information at different stages of the application and award lifecycle. Requirements vary depending on the applicable form, submission stage, Notice of Funding Opportunity, NIH Institute or Center, and award terms and conditions.

Investigators should carefully review the current NIH application instructions, applicable Notice of Funding Opportunity, NIH Grants Policy Statement, and any additional instructions or requests issued by NIH.

Each NIH disclosure document has a distinct purpose, definition, and set of reporting instructions. Information included in one document may not necessarily be reported in the same way—or at the same stage—in another document.

NIH Common Forms

NIH uses the government-wide Biographical Sketch Common Form and Current and Pending (Other) Support Common Form, together with the NIH Biographical Sketch Supplement.

The Common Forms must be prepared through SciENcv and submitted as digitally certified PDF documents. Senior/Key Personnel must have an ORCID iD linked to their eRA Commons Personal Profile.

NIH systems enforce the use of compliant Common Forms for applicable application due dates and Just-in-Time, Research Performance Progress Report, and prior-approval submissions on or after May 8, 2026.

Investigators should allow sufficient time to:

• Establish or update their SciENcv profile.
• Obtain an ORCID iD, if needed.
• Link their ORCID iD to their eRA Commons Personal Profile.
• Review their appointments, positions, support, and in-kind contributions.
• Complete required individual certifications.
• Generate compliant, digitally certified documents.

Information Commonly Reported

The information required depends on the applicable NIH form and submission stage.

Investigators should not determine reportability solely by whether an activity is paid. NIH Other Support may include monetary and non-monetary resources made available in support of or related to an individual’s research endeavors, regardless of whether those resources are located at Stony Brook University.

Current and Pending (Other) Support

Current and Pending (Other) Support provides NIH with information regarding resources available to Senior/Key Personnel in support of or related to their research activities. It allows NIH to evaluate research commitments, potential scientific or budgetary overlap, and other research security considerations.

Depending on the applicable submission and instructions, reportable support may include:

• Active and pending grants, contracts, and cooperative agreements.
• Research resources provided by another institution or organization.
• In-kind contributions and non-monetary resources.
• Externally supported laboratory personnel.
• Access to laboratory space, equipment, data, materials, or services.
• Certain outside appointments or affiliations associated with research support.
• Other resources available in support of or related to an individual’s research activities.

Investigators should carefully review the current NIH Common Form instructions to determine what must be included, excluded, or reported through another disclosure document.

Supporting Documentation

When required by NIH, investigators must provide supporting documentation for certain appointments, employment arrangements, support, or agreements involving foreign organizations.

Supporting documentation must be submitted in English. When the original document is not in English, an English-language translation must also be provided.

Investigators should provide relevant agreements and supporting materials to the Office of Sponsored Programs and the Office of Research Security sufficiently in advance of the applicable submission deadline.

Foreign Components and International Collaborations

NIH defines a foreign component as the performance of a significant scientific element or segment of an NIH-supported project outside the United States, whether or not NIH funds are expended.

A foreign component may arise when:

• Project activities are conducted at a location outside the United States.
• A researcher employed by a foreign organization performs a significant element of the project.
• Human subjects, animals, data, samples, facilities, or resources located outside the United States are used to perform a significant scientific activity.
• An international collaboration otherwise constitutes a significant element or segment of the NIH-supported project.

Foreign components must be disclosed in the application when proposed. Adding a foreign component to an active NIH award generally requires prior NIH approval before the activity begins.

Investigators should contact the Office of Sponsored Programs and the Office of Research Security early when an application or active award may involve:

• A proposed or potential foreign component.
• A foreign institution receiving NIH funds.
• International research sites.
• Research performed by foreign collaborators.
• Foreign subawards or consortium arrangements.
• International transfer of data, materials, samples, or funds.
• Significant scientific activities conducted outside the United States.

Investigators contemplating funded international collaborations should also consult OSP early to determine whether the proposed activity is permitted under the applicable Notice of Funding Opportunity and which NIH application or award mechanism must be used.

Other Support Disclosure Training

NIH requires recipient institutions to train Senior/Key Personnel regarding their responsibilities to disclose research activities, affiliations, and resources in Other Support.

The training must address the responsibility to disclose resources made available in support of or related to an individual’s research endeavors, regardless of whether the resources have monetary value or are located at the recipient institution.

Stony Brook University satisfies this requirement through its institution-specific Research Security Training program.

The training addresses:

• NIH Other Support disclosure requirements.
• Research activities and affiliations.
• Monetary and non-monetary research resources.
• Appointments and external relationships.
• Domestic and foreign support.
• Consistency across institutional and sponsor disclosures.
• The investigator’s responsibility to provide complete and accurate information.

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RESEARCH SECURITY TRAINING

Research Security Training

NIH requires each covered individual listed on an applicable NIH grant application to certify that they completed qualifying research security training within the preceding twelve months. For NIH, covered individuals are Senior/Key Personnel listed on the application.

The applicant institution must also certify that each covered individual employed by the institution and named on the application completed the required training.

This requirement applies to applications submitted for due dates on or after May 25, 2026.

Qualifying research security training addresses:

• Cybersecurity.
• International collaboration.
• Foreign interference.
• Proper use of research funds.
• Disclosure requirements.
• Conflict of commitment.
• Conflict of interest.

Stony Brook University’s Research Security Training is designed to satisfy applicable federal requirements while providing institution-specific guidance regarding University policies, processes, and resources.

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RESEARCH SECURITY TRAINING

Important Post-Award Considerations

Investigators have an ongoing responsibility to ensure that NIH disclosures remain complete, accurate, and current throughout the life of an award.

Changes involving research support, appointments, affiliations, in-kind contributions, international activities, Senior/Key Personnel, or other reportable matters may require an updated institutional disclosure, Research Performance Progress Report, prior-approval request, or other notification to NIH.

Investigators should promptly notify OSP and ORS whenever circumstances change that may affect NIH disclosures or award requirements.

This includes:

• New or modified Current and Pending (Other) Support.
• New professional appointments or affiliations.
• New in-kind contributions or research resources.
• International collaborations or foreign activities.
• Changes involving Senior/Key Personnel.
• Potential foreign components.
• Previously omitted or incomplete Other Support.
• Other changes requiring notification or prior approval under NIH policy or the award terms and conditions.

Undisclosed or Incomplete Other Support

When an investigator identifies information that may have been omitted from a prior NIH disclosure, the matter should be reported promptly to OSP and ORS.

The University may be required to evaluate the omission, submit updated disclosure documents and supporting materials, and provide NIH with an explanation or other required information.

Investigators should not independently submit corrections to NIH unless coordinated through the appropriate institutional office.

Foreign Components

A foreign component generally may not be added to an existing NIH award without prior NIH approval.

Investigators should consult OSP and ORS before beginning significant scientific activities outside the United States, materially expanding an international collaboration, or making other changes that may create a foreign component.

Changes in Senior/Key Personnel

Changes involving the Program Director/Principal Investigator or other Senior/Key Personnel may require NIH notification or prior approval. Investigators should consult OSP before implementing the change.

Research Performance Progress Reports

Investigators must ensure that information reported in the Research Performance Progress Report—including participants, accomplishments, products, support, foreign components, and other changes—is complete and consistent with current University and sponsor disclosures.

Official NIH Resources

Need Assistance?

Questions regarding NIH disclosure requirements should be raised as early as possible during application development or whenever circumstances change during an active award.

The Office of Sponsored Programs (OSP) provides assistance with application preparation, NIH requirements, award administration, Just-in-Time submissions, Research Performance Progress Reports, prior-approval requests, and other sponsor actions.

The Office of Research Security (ORS) provides assistance with research security, disclosure requirements, Current and Pending (Other) Support, supporting documentation, foreign components, international collaborations, foreign affiliations, conflict of commitment, Financial Conflict of Interest, Foreign Talent Recruitment Programs, and other NIH research security compliance matters.

CONTACT THE OFFICE OF RESEARCH SECURITY