Improper Influence (Including Improper Foreign Influence)

Federal agencies continue to evolve the disclosure requirements designed to mitigate improper influence in federally funded research, with particular attention to disclosures regarding foreign involvement.  Currently, the changes below apply only to the National Institutes of Health.

Important Changes

On 12 March 2021, the National Institutes of Health (NIH) issued a notice which set forth new requirements in the form of updated, reorganized forms and instructions for the Biosketch and Other Support documents. The changes are substantial in order to promote transparency and full disclosure of all resources—both domestic and foreign—supporting an individual’s research endeavors. The most dramatic new requirement is a certifying signature by the PD/PI or other senior/key personnel on their own Other Support form.

Signature Block Added: All PD/PIs and other senior/key personnel must electronically sign the Other Support form, prior to submission to NIH, certifying that the information is accurate and complete.

Guidance for Review

All PIs and all Department Administrators involved in research administration should review Notice No. NOT-OD-21-110 and Notice No. NOT-OD-21-073, along with the documents below, to begin understanding the new requirements:

All Stages of Lifecycle

The new requirements affect all stages of the NIH proposal and award lifecycle:

lifecycle of an award

Effective for Submissions to NIH Due Dates on or after 25 January 2022