Post-Award Reporting

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.

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.

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.

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 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 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.

An NIH form used by recipients with active SBIR and STTR awards to disclose all funded and unfunded relationships with foreign countries. Per NOT-OD-25-102, recipients whose awards did not undergo foreign risk assessment at the time of their original application may be required to use this form, and NIH may terminate awards where a reported covered foreign relationship meets risk criteria prohibiting funding.

An NIH OPERA document providing illustrative scenarios to help investigators and institutions determine when monetary donations must be disclosed as Other Support versus when they qualify as unrestricted gifts. It explains that donations must be reported as Other Support when intended to directly support an investigator's research activities and carrying explicit or implicit expectations, such as use for specific projects, placement into a research account, or requirements to provide updates to donors. The scenarios correspond with those in the Office of the Inspector General's March 2025 review of institutional understanding of monetary donation reporting.

A March 2025 HHS Office of Inspector General review finding that many institutions receiving NIH funding did not fully understand when monetary donations must be reported as 'Other Support' versus when they qualify as unrestricted gifts. The scenarios in this review correspond with the illustrative scenarios later posted by the NIH Office of Policy for Extramural Research Administration (OPERA) to help investigators and institutions make this determination.

The NSF Proposal and Award Policies and Procedures Guide (NSF 23-1, January 2023). Post-award Disclosure of Current Support and In-Kind Contribution Information: PAPPG Chapter II.D.2.h(ii).

Published July 10, 2025. Includes NSF implementation of three new requirements (and three existing ones) in alignment with the CHIPS and Science Act and NSPM-33. The requirements, effective October 10, 2025, include: a. Recipient institutions must maintain supporting documentation for foreign activities reported as current and pending (other) support, b. Senior/key personnel must certify they have completed research security training (RST) within 12 months prior to proposal submission; Recipient institutions' Authorized Organizational Representative (AOR) must certify that all senior/key personnel have completed required RST and that the institution has a plan to provide appropriate training, c. AORs at institutions of higher education (IHEs) must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.

The CHIPS and Science Act of 2022 directs federal research funding agencies to establish a policy that requires each covered individual (CI) listed in an R&D proposal to certify that they are not a party to a MFTRP in the proposal submission and annually thereafter for the duration of the award. NSF was the first federal agency to implement this certification via the common federal biosketch and current and pending support forms in May 2024. NSF began rolling out the annual certification on June 7, 2025, for all PIs and co-PIs named on an NSF award made on or after May 20, 2024. NSF is making sample contracts available that meet the parameters of a MFTRP. Contract examples and frequently asked questions can be found on the NSF website under MFTRPs.

On November 25, 2025, the National Science Foundation (NSF) released an update to the agency's Important Notice No. 149. The update states that the requirements originally slated to take effect in October 2025 instead take effect on December 2, 2025 as a result of the recent government shutdown. The impacted requirements include: certifications of research security training for senior/key personnel; institutional certifications regarding contracts or agreements with Confucius Institutes; and recipient institutions providing supporting documentation for senior/key personnel activities reported as current and pending (other) support (e.g., contracts, grants, appointment letters) to NSF, upon request.

On December 5, 2025, NSF notified the research community that it is offering a grace period for enforcement of Important Notice No. 149 for proposals submitted between December 2 and December 31, 2025, to accommodate programs with deadlines near the December 2, 2025 effective date. NSF will continue to accept proposals using the previous Biographical Sketch and Current and Pending (Other) Support forms until December 31, 2025; after that date, all proposals must incorporate the new senior/key personnel certifications (research security training within the past 12 months and not being a party to a malign foreign talent recruitment program) required under Important Notice No. 149.

Issued July 8, 2025. This memorandum: a. Requires all USDA Mission Areas, Agencies, and Offices to: i. Within 30 days, conduct a comprehensive review of all current USDA awards/subawards with foreign persons/entities and provide justification as to why a US recipient was not selected, ii. Effective immediately, request approval (including justification) prior to issuing an award/subaward to a foreign person/entity. b. Requires applicants (i.e., covered individuals) to: i. Complete the Common Forms for Biographical Sketches and Current and Pending (Other) Support and provide updated information annually, ii. Certify they are not a participant in a malign foreign talent recruitment program (MFTRP) and recertify annually, iii. Certify that they are not contracting with or providing benefit to any foreign person/entity in a country of concern, iv. Certify that they are not party to utilizing forced labor, v. Complete an annual disclosure of contracts associated with participation in programs sponsored by foreign governments/entities, vi. Seek approval from USDA to subaward any portion of a funded arrangement, including university students, post-doctoral fellows, and visiting researchers. c. Requires Employing Entities to: i. Certify to applicants' completion of research security training, ii. Prohibit applicants who either are currently or have in the past 10 years participated in MFTRPs from working on USDA projects, iii. Provide supporting documentation for foreign activities reported as current and pending support, iv. Review any documents required under the memorandum for compliance with USDA award terms and conditions.