NIH’s Implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support for Due Dates on or after January 25, 2026

 

Key Dates

 

Related Announcements

September 4, 2025 – Preview of NIH Common Forms for Biographical Sketch and Current and Pending (Other) Support Coming Soon to SciENcv. See Notice: NOT-OD-25-152.

July 17, 2025 – NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements.  See Notice NOT-OD-25-133.

 

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Agency for Healthcare Research and Quality (AHRQ)
Centers for Disease Control and Prevention (CDC)
Department of Veterans Affairs (VA)

 

Purpose

In an effort to support strong collaboration between Federal research agencies, NIH is adopting the Common Forms for Biographical Sketch and Current and Pending (Other) Support as per the White House Office of Science and Technology Policy (OSTP) memorandum on Policy Regarding Use of Common Disclosure Forms. This Guide Notice provides details for the Common Forms, NIH Biographical Sketch Supplement, and instructions required for use for application due dates and Research Performance Progress Report (RPPR) submissions on or after January 25, 2026.  An important reminder: institutions must maintain internal controls (e.g., policies and procedures) for disclosure, which must include training on these policies and procedures for senior/key personnel.

A table entitled, NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support for NIH will be posted on Common Forms for Biographical Sketch and Current and Pending (Other) Support that provides helpful reference information regarding pre-award and post-award disclosures. The table includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award lifecycle. A final column identifies activities that are not required to be reported.

Malign Foreign Talent Recruitment Program Prohibition:

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.

Definition: Malign Foreign Talent Recruitment Program.

Malign Foreign Talent Recruitment Program Certification:

NIH will require MFTRP certifications from applicants and individuals identified as senior/key personnel with its implementation of the Common Forms for Biographical Sketch and Current/Pending (Other) Support.

• Institutional Certification: In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), the AOR must certify, via their signature on the face page of the application (i.e., SF424 R&R cover form), that all individuals identified by the applicant as senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.
• Individual Certification at the time of the application: In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), each individual identified by the applicant as a senior/key person must certify on their Common Form for Biographical Sketch, attached on the R&R Senior/Key Person Profile (Expanded) Form, that they are not a party to a malign foreign talent recruitment program.
• Annual Certification at the time of the RPPR: For NIH awards with RPPRs submitted on or after January 25, 2026, individuals serving as senior/key personnel must certify annually to their participation or non-participation in an MFTRP by uploading a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ‘MFTRPcert_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.

Effective Date

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement will be required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026.

This effective date replaces the date previously communicated in NOT-OD-24-163. See table below for the effective dates relevant to different submission scenarios.

Note: NIH will enforce the use of the Common Forms via eRA system validations immediately as a warning when the wrong form is used. By February 6, 2026, the warning will be elevated into an error preventing submission of the incorrect or uncertified forms. Failure to utilize the correct forms during the timeframes specified in the table below will cause NIH to withdraw your application from consideration.

Reminder: When a receipt date/submission date falls on a weekend, Federal holiday, or Washington, DC area Federal office closure, the application deadline is automatically extended to the next business day. See NIH Submission Policies.

Further details at the NIH website.