NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements

Notice Number: NOT-OD-25-133

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-133.html

Purpose

Background

This Guide Notice announces a new policy requirement that requires NIH recipients to provide training to all faculty and researchers identified as Senior/Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form). The new requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see NIH Grants Policy Statement (GPS), Section 2.5.1 "Just-in-Time Procedures") in order to provide a comprehensive plan in the area of disclosure requirements for recipients. This update will be included in the FY2026 version of the NIH GPS as part of NIH’s standard processes.

Effective October 1, 2025,  recipients must implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.

Please refer to the full notice linked above for further details.

Should you have any questions, please contact the Office of Sponsored Programs.

Supporting Fairness and Originality in NIH Research Applications

Notice Number: NOT-OD-25-132

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-132.html

Purpose

NIH is providing guidance to researchers on the appropriate usage of artificial intelligence (AI) to maintain the fairness and originality of NIH’s research application process. NIH is also instituting a new policy limiting the number of applications that NIH will consider per Principal Investigator per calendar year.

Background

NIH has recently observed instances of Principal Investigators submitting large numbers of applications, some of which may have been generated with AI tools. While AI may be a helpful tool in reducing the burden of preparing applications, the rapid submission of large numbers of research applications from a single Principal Investigator may unfairly strain NIH’s application review processes. The percentage of applications from Principal Investigators submitting an average of more than six applications per year is relatively low; however, there is evidence that the use of AI tools has enabled Principal Investigators to submit more than 40 distinct applications in a single application submission round.

NIH will continue to employ the latest technology in detection of AI-generated content to identify AI generated applications, but it is imperative that all NIH research applications are consistent with the NIH Grants Policy Statement (GPS) Section 2.1.2’s expectation that institutions and affiliated research teams propose original ideas for funding. AI tools may be appropriate to assist in application preparation for limited aspects or in specific circumstances, but researchers should be aware that using AI comes with its own risks. AI use may result in plagiarism, fabricated citations, or other kinds of research misconduct. As a reminder, NIH oversees research misconduct investigations and acts on non-compliance (see GPS Section 4.1.27).

Policy

NIH will not consider applications that are either substantially developed by AI, or contain sections substantially developed by AI, to be original ideas of applicants. If the detection of AI is identified post award, NIH may refer the matter to the Office of Research Integrity to determine whether there is research misconduct while simultaneously taking enforcement actions including but not limited to disallowing costs, withholding future awards, wholly or in part suspending the grant, and possible termination.

NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year. This policy applies to all activity codes except T activity codes and R13 Conference Grant Applications. Based on recent data, this limit will affect a relatively small number of Principal Investigators while enabling the NIH to maintain consistently high-quality grant application review and appropriately steward taxpayer dollars.

Effective Date

This policy is effective for applications submitted to the September 25, 2025, receipt date and beyond.

 Please refer to the full notice linked above for details.

Should you have any questions, please contact the Office of Sponsored Programs.

-- Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects

Notice Number: NOT-OD-25-130

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-130.html

Purpose

As previously noted in NOT-OD-25-104, NIH must ensure it can transparently and reliably report on each dollar spent on foreign collaborations. The current subaward structure does not allow for consistent reporting and accurate tracking; therefore, NIH will not issue awards to domestic or foreign entities (new, renewal, or non-competing continuation) that include a subaward to a foreign entity. This Guide Notice updates the policy concerning existing projects and submitted applications.

Applicability

This Guide Notice addresses the implementation of the NIH Policy on Foreign Subawards (See NOT-OD-25-104) for applications submitted before May 1, 2025, and projects active on or before May 1, 2025.

 Please refer to the full notice linked above for further details.

Should you have any questions, please contact the Office of Sponsored Programs.

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-- Updated NIH Policy on Foreign Subawards

Notice Number: NOT-OD-25-104

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-104.html

Purpose

This Guide Notice updates NIH policies and practices utilizing foreign subawards. NIH recognizes that some recipients do not accurately report on subawards consistent with Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements (NIH GPS 8.4.1.5.5), which state that recipients must report on all subawards/subcontracts/consortiums equal to or greater than $30,000. This includes awards that are initially below $30,000 but subsequent grant modifications result in an award equal to or greater than $30,000. This lack of transparency is particularly concerning in the case of foreign subawards, in which the United States government has a need to maintain national security.

In an effort to maintain strong, productive, and secure foreign collaborations in support of the NIH mission, NIH must ensure it can transparently and reliably report on each dollar spent. Therefore, NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime with independent awards that are linked to the prime that will allow NIH to track the project’s funds individually, while scientific progress will be reported collectively by the primary institution, under the Research Performance Progress Report. NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026.

Please refer to the full notice linked above for further details.

Should you have any questions, please contact the Office of Sponsored Programs.

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