Working with NIH

Visit NIH Grants Policy Statement (NIHGPS) for the latest version.

As of January 25, 2026, NIH requires the use of the Common Forms created in SciENcv for Biographical Sketch and Current and Pending (Other) Support. The requirement applies to anyone identified as Senior/Key Personnel on proposals, RPPRs, JIT submissions and prior approval requests due on or after January 25, 2026. The requirement also applies to Agency for Healthcare Research and Quality (AHRQ), Centers for Disease Control and Prevention (CDC) and Department of Veterans Affairs (VA). As of April 2, 2026, NIH continues to allow a period of leniency and only provides a warning when the Common Forms are not used. It is expected that the leniency period will expire in May, and investigators are strongly encouraged to transition the NIH Common Forms by May 1, 2026 to ensure compliance at the time of submission. NIH will issue a Guide Notice announcing the date when the validation will be changed to an error and the requirement to use the Common Forms will be system-enforced.

• The forms require the use of an ORCID ID, so all PIs and Senior/Key Personnel must have an ORCID ID by May 1, 2026. Learn how to set up an ORCID ID. 
• The ORCID ID also must be connected to the eRA Commons Account. Learn now to connect them. 
• Researchers needing guidance creating Common Forms in SciENcv can follow this step-by-step guide or access the NIH FAQs on the subject. 

NIH recently released NOT-OD-25-132 Supporting Fairness and Originality in NIH Research Applications addressing the appropriate use of Artificial Intelligence (AI) in proposal development and limiting the number of applications that will be considered per Principal Investigator per calendar year. 

To limit the potential stress of multiple AI generated proposals on the application review process, beginning with applications submitted for the September 25, 2025, receipt date, NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director (PI/PD) or Multiple Principal Investigator (MPI) for all council rounds in a calendar year. Applications on which the PI/PD or MPI is a co-Investigator do not count towards the 6-application limit. Training grants (T activity codes) and R13 Conference Grant Applications are also excluded. NIH expects this limitation to apply to only a small number of investigators.

Other Support is sometimes referred to as current and pending support or active and pending support. It is each investigator’s responsibility to ensure true, complete and accurate reporting of all sources of support for their research activities. While reporting other support has always been expected, a number of federal agencies have published expanded guidance.

As of October 1, 2025. all senior/key personnel named on an NIH proposal or award must receive training on other support disclosure requirements before submission of JIT materials or the RPPR (NOT-OD-25-133).

• This training is available in BuckeyeLearn and completion status is noted on User Profile (Study Team Lookup). 
• Sponsored Programs can not not submit JIT material or an RPPR until this training requirement is met.

Review recent announcements by NIH regarding undue foreign influence at U.S. institutions:

• August 20, 2018 letter reminded the research community of the requirement to disclose “support coming from foreign governments or other foreign entities”
• July 2019 NIH Notice NOT-OD-19-114 included Other Support guidance and reminded NIH applicants and recipients that “other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors…”
• August 2024 NIH published a Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel

The National Institutes of Health (NIH) NIH requires that all trainees, postdocs, fellows, participants and scholars receiving support through any NIH training, career development award, research education grant and dissertation research grant must receive in-person instruction in the responsible conduct of research (see NIH RCR NOT-OD-10-019 and NOT-OD-22-055).

Training requirements apply to the following grant programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R or any other NIH-funded programs supporting research training, career development or research education that require instruction in responsible conduct of research as stated in the relevant funding opportunity announcements.

Depending on the grant type, additional courses may be required for researchers working with human subjects or in clinical research.

For the specified award categories, the Principal Investigator (PI) must develop a discipline-specific, tailored plan for RCR training that meets NIH requirements with significant face-to-face interaction and participation by research faculty members. The instructional plan is evaluated as a component of the funding proposal and applications lacking an RCR instructional plan may be delayed in the review process or not reviewed.

The PI is responsible for ensuring that course attendance is monitored, and training records are maintained to document that all NIH-supported individuals received the required instruction. The PI must also comply with the specific reporting requirements in continuation applications. The RCR training should occur within one year of assignment to an applicable NIH Grant. NIH training records are subject to audit.

Ohio State's Office of Research Compliance offers an in-person RCR course - Responsible and Ethical Conduct of Research (GRDSCH 8000 RCR) - designed to fulfill the in-person NIH required training.

Additional courses that meet the in-person NIH requirement for RCR instruction include:

• BIOPHRM 5510 - Responsible Conduct in Biomedical Research
• MEDCOLL 5000 - Responsible Conduct of Research & Research Ethics
• ANIMSCI 7789 - Nutrition Research Ethics
• BIOMEDE 6983 - Research Ethics
• BIOPHRM 5510 - Responsible Conduct in Biomedical Research
• BIOPHRM 7510 - Professional and Ethical Issues in Biomedical Sciences
• BIOPHYS 7600 - First-Year Student Orientation
• MCDBIO 7600 - First-Year Student Orientation
• MICRBIO 7600 - First-Year Student Orientation
• MOLGEN 7600 - First-Year Student Orientation
• OSBP 7600 - First-Year Student Orientation
• PHR 8520 - Research Ethics
• VISSCI 7960 - Ethics in Biomedical Research
• Center for Ethics and Human Values: CARE Training Program (open to graduate and professional students, postdocs, university staff, and faculty)

To ensure compliance with federal regulations, including those set by the NIH, all Ohio State personnel named on federal award proposals or who are funded by federal grants are required to complete an annual research security training requirement each spring. 

Many new funding applications submitted to NIH on or after January 25, 2023, must comply with the National Institutes of Health (NIH) Data Management and Sharing (DMS) Policy. Under the policy, investigators and institutions are expected to:

• plan and budget for the managing and sharing of data
• submit a DMS plan for review when applying for funding
• comply with the approved DMS plan.

Unless specifically noted in the funding opportunity announcement, plans are not part of the scored peer review criteria and are reviewed only by program staff. However, peer reviewers will see and may comment on the related budget items.

Resources

• Ohio State NIH DMS Policy Guide
• 2023 Data Management & Sharing Policy FAQs
• example budget form
• example budget narrative for detailed budget
• example budget narrative for modular budget

Since 2008, publications resulting from NIH-sponsored research must be made publicly available in PubMed Central. A 2024 NIH Public Access Policy went into effect on July 1, 2025, based on guidance released in 2022 from the White House Office of Science and Technology Policy (OSTP) to make federally-funded research freely available without a delay. Under the policy, investigators are expected to:

• provide immediate access in PubMed Central upon the official date of publication
• include an acknowledgement statement of federal funding in all publications
• agree to a standard Government Use License for all publications

These requirements no longer allow for a 12-month embargo of publications. All manuscripts accepted for publication on or after July 1, 2025 must be made available in PubMed Central immediately upon publication in a journal. The policy applies to all publications resulting from NIH-sponsored research, regardless of when the grant was initiated.

Resources

• Overview Video: NIH Public Access Policy (5 minutes)
• Ohio State NIH Public Access Policy Guide
• Supplemental Guidance on Publication Costs

Effective June 1, 2026, all prime recipients are required to obtain NIH prior approval when adding a new domestic subaward to a project post-award, when the arrangement was not originally a part of the peer-reviewed and approved application (NOT-OD-26-062). 

NIH no longer recognizes foreign subawards (NOT-OD-25-104) and as of May 25, 2026, utilizes a dedicated award structure for research grants and cooperative agreements that involve international collaborations.

Unlike domestic collaborations supported through subrecipient agreements, the Collaborative International Research Awards allow NIH to have a direct legal relationship with both the domestic and foreign collaborating organizations. All research grants and cooperative agreements involving NIH-funded international collaborations must be submitted in response to a Notice of Funding Opportunity (NOFO) that is specifically designated for Collaborative International Research Awards. 

• The current NOFO is NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional) 
• PF5 applications will follow the P series standard deadlines and use the Multi-Project application forms
• The U.S. institution applies as the prime
• If funded, each foreign component is disaggregated and awarded directly to the foreign institution as a linked RF2 award

Foreign collaborators are no longer subrecipients but direct NIH awardees, with independent compliance and reporting obligations and must complete multiple required organizational registrations in sequence:

• NCAGE
• SAM.gov
• Grants.gov
• eRA Commons

Potential foreign collaborators should begin the registration processes during the preaward stage so as not to delay or jeopardize issuance of a future award. These registrations can take many months to complete and cannot be expedited because of a pending award.

Even though foreign awards are issued directly by NIH, the domestic institution retains responsibility for ensuring foreign project progress and an Authorized Organization Representative (AOR) must attest to satisfactory progress of each foreign project annually.