RAS would like to let you know about a few NIH changes that will impact your applications.
Research Security Training
NIH now requires Research Security Training (RST), similar to other federal agencies. Please make note:
- May 4, 2026: KC proposal validation will ERROR if NSPM-33 Research Security Training is missing or expired (> 12 months ago). KC proposals must validate without error to route for internal approval.
- RST is required for NIH applications submitted for due dates on or after May 25, 2026 (NOT-OD-26-017).
- Each covered individual (for NIH defined as senior/key personnel) listed on an NIH grant application must certify that they have completed RST within 12 months of the date of application submission.
Common Forms
NIH has implemented the use of Common Forms (NOT-OD-26-033).
- Use of the Common Forms generated by SciENcv for Biographical Sketch, NIH Biographical Sketch Supplement, and Current and Pending (Other) Support and will be required for all application due dates and Just-In-Time (JIT), Research Performance Progress Report (RPPR), and Prior Approval submissions on or after May 8, 2026.
- NIH’s Leniency Period will end. NOT-OD-26-079 states, “the current leniency period previously communicated in NOT-OD-26-033 will end on May 7, 2026." Meaning, as of May 8, 2026, system warnings will change to errors, blocking the submission of non-compliant applications.
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.
- 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.
- 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.
Other Updates
- NIH has ended the Continuous Submission Policy and updated the Late Submission Policy. Please see NOT-OD-26-064.
- NIH has a new format for the Data Management and Sharing Plan. Please see NOT-OD-26-046 and related news item.
- Prior approval is now needed for changes in domestic subaward agreement. Please see NOT-OD-26-062.
Please see NIH Checklists and reach out to your Contract Administrator with any questions.