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In a September 29, 2025, notice (NOT-OD-25-161), the National Institutes of Health (NIH) rescinded the September 11, 2025, notice (NOT-OD-25-154) Implementation of NIH Research Security Policies. Per the notice, 'NIH continues to work with the National Science Foundation and other Federal research agencies to finalize guidance on each of the required elements outlined in the Office of Science and Technology Policy (OSTP) Guidelines for Research Security Programs at Covered Institutions, and to develop a centralized process for recipients to certify compliance.' The notice indicates that the implementation date for the requirements announced in NOT-OD-25-154 have not been finalized, the notice is therefore rescinded, and that 'NIH will issue updated guidance on Research Security requirements in the coming months.'

Issued September 24, 2025, and effective October 24, 2025, NIH implemented NOT-OD-25-160, a policy to enhance security for human biospecimens in NIH-funded research.

On September 24, 2025, and effective immediately, NIH issued NOT-OD-25-159, establishing new security, operational, and transparency standards for controlled-access data repositories (CADRs) that store and manage sensitive human research data.

On September 18, 2025, NIH released additional information regarding the agency's new application and award structure for international collaborations, previously announced in NIH NOT-OD-25-155. In addition to summarizing impacts to proposing/recipient institutions, the announcement provides links to additional information for the four new Activity Codes (grant types) that will be used to facilitate the new application and award process.

Issued September 12, 2025, this notice provides additional information on the agency's new process for handling foreign components, as NIH announced in NOT-OD-25-104 that the agency would not issue awards for proposals that include subawards to foreign entities. Under the process described in NOT-OD-25-155, competing applications that include one or more foreign components must submit to a Notice of Funding Opportunity (NOFO) that supports a complex mechanism activity code, including two new international project 'parent' activity codes that NIH is creating: PF5 for grants and UF5 for cooperative agreements.

On September 4, 2025, NIH issued notice NOT-OD-25-152, regarding the agency's plans to release preview versions of NIH's Common Forms for Biographical Sketches (Biosketches) and Current and Pending (Other) Support in the Science Experts Network Curriculum Vitae (SciENcv) system. Access to the preview versions is purely for informational purposes and applicants/recipients may not submit documents to NIH that were created using the preview functionality. Applicants/recipients must continue to use the current NIH Biosketch and Other Support forms until NIH officially implements its Common Forms, which the agency anticipates will occur in November 2025. The fall 2025 government shutdown may impact this timeline.

Issued July 18, 2025 as a follow-up to NOT-OD-25-104. This updated guidance creates an alternative, short-term approach for existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) with foreign sites. The alternative approach involves removing a foreign sub-award from the primary award and having it issued as a foreign supplement award.

Effective October 1, 2025, recipient institutions must train senior/key personnel on the requirement to disclose all research activities and affiliations in Other Support and maintain a 'written and enforced policy on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose.'

Issued May 1, 2025. Prospectively updates NIH policies and practices for utilizing foreign subawards. Per the notice, '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 linked awards] 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. The policy continues to support direct foreign awards and plans to expand this policy to domestic subawards in the future, for consistency.

Effective immediately (April 29, 2025), the SBIR and STTR Foreign Disclosure and Risk Management Requirements described in NOT-OD-23-139 and NOT-OD-24-029 may be applied to all active SBIR and STTR awards regardless of the due date the competing application was submitted. Recipients with active awards that did not undergo foreign risk assessment at the time of their original application may be required to disclose all funded and unfunded relationships with foreign countries, using the Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form. If the recipient reports a covered foreign relationship that meets any of the risk criteria prohibiting funding, NIH may deem it necessary to terminate the award for material failure to comply with the federal statutes, regulations, or terms and conditions of the federal award.

August 2024. Assists agency staff in assessing grant applications and ongoing awards for potential foreign interference. Factors considered include: (1) current or past participation in a malign foreign talent recruitment program, which is prohibited by law, (2) undisclosed current or prior funding from a foreign country of concern (FCOC), or connected entity (currently China, Russia, North Korea, and Iran (higher risk)) or other foreign country (lower risk) and, (3) Indicators of an undisclosed current or past affiliation with an institution or entity located in or connected to a FCOC (higher-risk/mitigation) or foreign country (lower-risk/mitigation). Per the matrix, mitigation is either required, recommended, suggested, or not required based on the timing of the engagement and if accurate and complete disclosure information was provided. Mitigation conditions include: (1) specific award conditions, (2) modification of terms and conditions of award, (3) suspension, termination, or withdrawal of an award, (4) conversion from advance payment to reimbursement, and (5) recovery of funds.

An NIH blog post from August 2024 explaining the new Decision Matrix and clarifying NIH processes for handling allegations of foreign interference.

Issued March 2021. Requires immediate notification of undisclosed Other Support. If a recipient discovers Other Support information on an active NIH grant that should have been, but was not, disclosed during just-in-time or in an annual progress report, updated Other Support must be submitted to the Grants Management Specialist as soon as the undisclosed information is known.

Issued July 10, 2019. Reminds institutions receiving NIH funding of the requirement for researchers to disclose all sources of support for their research endeavors, regardless of the source, value, or whether monetary or in-kind, and to disclose all scientific appointments and positions, whether foreign or domestic, paid or unpaid, etc. The notice also reminds the extramural community of the requirement to comply with HHS regulations regarding Financial Conflicts of Interest, as well as the requirement to report all Foreign Components involved in NIH-supported activities.

NIH's research security portal providing access to notices, policies, decision matrices, and resources related to identifying and addressing foreign interference in NIH-funded research.