National Institutes of Health (NIH)

Disclosure Requirements

The National Institutes of Health (NIH) requires investigators and recipient institutions to disclose information regarding professional appointments and affiliations, research support, in-kind contributions, foreign components, financial conflicts of interest, and other activities necessary to promote transparency, protect research integrity, and support appropriate funding decisions.

NIH disclosure requirements apply throughout the lifecycle of an award, including application submission, Just-in-Time, prior-approval requests, Research Performance Progress Reports, and award closeout. Investigators are responsible for ensuring that information provided to NIH is complete, accurate, current, and consistent with NIH requirements, their University Disclosure Profile, and other sponsor submissions.

NIH recognizes the importance of international research collaboration while requiring transparency regarding financial support, affiliations, appointments, research resources, and significant scientific activities conducted outside the United States.

University Disclosure Requirements

Before preparing an NIH application or completing NIH disclosure documents, investigators should ensure that their University Disclosure Profile is current.

Maintaining an accurate institutional disclosure helps ensure consistency across sponsor submissions and supports the University's Conflict of Interest, Conflict of Commitment, Research Security, and Foreign Talent Recruitment Program compliance processes.

Sponsor disclosures are separate from—and in addition to—the University's disclosure requirements. Updating an NIH submission does not replace the obligation to update the University Disclosure Profile.

Related University Guidance

NIH Application & Award Disclosures

NIH requires disclosures at different stages of the application and award lifecycle. The information required depends on the applicable form, submission stage, funding opportunity, and award terms.

Investigators should review the current NIH application instructions, NIH Grants Policy Statement, applicable Notice of Funding Opportunity, and any requests issued by the NIH Institute or Center administering the award.

Disclosure Requirement	Purpose	When Required
Biographical Sketch Common Form	Provides standardized information regarding an individual's professional preparation, appointments, positions, products, and other federally required information.	Application submission and other submissions requiring an updated Biographical Sketch
NIH Biographical Sketch Supplement	Collects additional NIH-specific information that is not included in the government-wide Biographical Sketch Common Form.	Submitted with the Biographical Sketch Common Form when required by NIH
Current and Pending (Other) Support Common Form	Discloses current and pending research support, in-kind contributions, appointments, and other resources available in support of an individual's research activities.	Application, Just-in-Time, RPPR, and prior-approval submissions, as applicable
Foreign Component	Identifies the performance of a significant scientific element or segment of an NIH-supported project outside the United States, whether or not NIH funds are expended.	Application submission or through a prior-approval request when added after award
Facilities and Other Resources	Describes the institutional facilities, equipment, laboratory space, personnel, and other resources available to support the proposed project.	Application submission
Financial Conflict of Interest	Allows the University to identify, review, manage, and report financial conflicts of interest in accordance with Public Health Service regulations and NIH requirements.	Before expenditure of funds and throughout the award, as applicable
Research Performance Progress Report	Provides information regarding project progress, participants, products, support, changes, and other required award information.	During the award and at project completion
Post-Award and Prior-Approval Disclosures	Provides updated information or requests NIH approval for certain changes in project scope, personnel, foreign components, support, or other award circumstances.	Throughout the award period, as required

Each NIH disclosure document has its own purpose, definitions, and reporting instructions. Information required in one document may not necessarily be reported in the same way—or at the same stage—in another document.

NIH Common Forms

NIH requires use of the government-wide Biographical Sketch Common Form and Current and Pending (Other) Support Common Form, together with the NIH Biographical Sketch Supplement.

For application due dates and Just-in-Time, Research Performance Progress Report, and prior-approval submissions on or after May 8, 2026, NIH systems enforce the use of compliant Common Forms.

The Common Forms must be prepared through SciENcv and submitted as digitally certified PDF documents. Senior/Key Personnel must also have an ORCID iD linked to their eRA Commons Personal Profile.

Investigators should allow sufficient time to:

establish or update their SciENcv profile;
obtain an ORCID iD, if needed;
link the ORCID iD to eRA Commons;
review appointments, positions, support, and in-kind contributions;
complete the required individual certifications; and
generate compliant, digitally certified documents.

Examples of Information Commonly Reported

Depending on the applicable NIH form and submission stage, investigators may be required to report information such as:

domestic and foreign academic, professional, institutional, or research appointments;
current and pending research projects and proposals;
research support provided through grants, contracts, cooperative agreements, or other arrangements;
in-kind contributions and non-monetary resources;
laboratory personnel, visiting researchers, students, or other individuals supported by an outside entity;
access to laboratory space, equipment, materials, data, or other research resources;
high-value materials or resources that are not freely available;
consulting, advisory, or other professional activities when reportable under the applicable form;
significant scientific activities conducted outside the United States;
foreign affiliations or employment arrangements; and
financial interests that require review under the University's Conflict of Interest Program.

Investigators should not determine reportability solely by whether an activity is paid. NIH Other Support includes resources made available in support of or related to an individual's research endeavors, regardless of whether the resources have monetary value or are located at Stony Brook University.

Current and Pending (Other) Support

Current and Pending (Other) Support provides NIH with information regarding the resources available to Senior/Key Personnel in support of or related to their research activities.

Other Support may include both monetary and non-monetary resources from domestic or foreign sources, including:

active and pending grants, contracts, and cooperative agreements;
research resources provided by another institution or organization;
in-kind contributions;
externally supported laboratory personnel;
access to laboratory space, equipment, data, materials, or services;
certain outside appointments or affiliations associated with research support; and
other resources available in support of an individual's research endeavors.

Investigators should carefully review the current NIH Common Form instructions to determine what must be included, excluded, or reported elsewhere.

Supporting Documentation

When required by NIH, supporting documentation must be provided for certain appointments, employment arrangements, support, or agreements involving a foreign organization.

Supporting documentation must be submitted in English. If the original document is not in English, an English-language translation must also be provided.

Investigators should provide relevant agreements and supporting materials to the Office of Sponsored Programs and ORS sufficiently in advance of the applicable submission deadline.

Foreign Components and International Collaborations

NIH defines a foreign component as the performance of a significant scientific element or segment of an NIH-supported project outside the United States, whether or not NIH funds are expended.

A foreign component may arise when:

project activities are conducted at a location outside the United States;
a researcher employed by a foreign organization performs a significant element of the project;
human subjects, animals, data, samples, facilities, or resources located outside the United States are used to perform a significant scientific activity; or
an international collaboration otherwise constitutes a significant element or segment of the NIH-supported project.

Foreign components must be disclosed in the application when proposed. Adding a foreign component to an active NIH award generally requires prior approval before the activity begins.

Investigators should contact the Office of Sponsored Programs and Office of Research Security early when an application or active award may involve:

a foreign component;
a foreign institution receiving NIH funds;
international research sites;
research performed by foreign collaborators;
foreign subawards or consortium arrangements;
transfer of data, materials, samples, or funds internationally; or
significant scientific activities conducted outside the United States.

NIH has adopted a new application and award structure for certain NIH-funded foreign components. Investigators contemplating funded international collaborations should consult OSP early to determine whether the proposed activity is permitted under the funding opportunity and which NIH application mechanism must be used.

Other Support Disclosure Training

Effective October 1, 2025, NIH requires recipient institutions to train all faculty and researchers identified as Senior/Key Personnel regarding their responsibilities to disclose research activities, affiliations, and resources in Other Support.

Stony Brook University satisfies this requirement through its institution-specific Research Security Training program.

How to Complete the Requirement

Complete the designated Research Security Training condensed module in CITI.

The training addresses:

NIH Other Support disclosure requirements;
research activities and affiliations;
monetary and non-monetary research resources;
appointments and external relationships;
foreign and domestic support;
disclosure consistency; and
the investigator's responsibility to provide complete and accurate information.

Learn More

Research Security Training

In addition to NIH's Other Support disclosure training requirement, NIH requires covered individuals to complete research security training under the CHIPS and Science Act.

For NIH, covered individuals are Senior/Key Personnel listed on an NIH grant application. For applications submitted for due dates on or after May 25, 2026, each covered individual must certify that they completed qualifying research security training within the preceding 12 months.

The institution must also certify that each covered individual employed by the institution and named on the application completed the required training.

Qualifying research security training addresses:

cybersecurity;
international collaboration;
foreign interference;
proper use of research funds;
disclosure requirements;
conflict of commitment; and
conflict of interest.

Stony Brook University's Research Security Training is designed to address applicable federal requirements while providing guidance specific to University policies, processes, and resources.

Learn More

Research Security Training

Financial Conflict of Interest

NIH requires recipient institutions to identify, review, manage, and report Financial Conflicts of Interest in accordance with Public Health Service regulations and NIH policy.

Investigators must complete University disclosures and required Conflict of Interest training and must update reportable financial interests within the timelines established by University policy.

ORS administers the University's research Conflict of Interest Program and coordinates institutional reporting to NIH when required.

Learn More

Conflict of Interest

Important Post-Award Requirements

Investigators have an ongoing responsibility to ensure that NIH disclosures remain complete, accurate, and current throughout the life of an award.

Changes to Current and Pending (Other) Support

Investigators should promptly report new or changed research support, appointments, affiliations, in-kind contributions, or other resources to the University. OSP and ORS will determine whether the information must be included in an RPPR, submitted through a prior-approval request, or otherwise reported to NIH.

Undisclosed Other Support

When the University identifies Other Support that should previously have been disclosed, the information must be evaluated promptly. The University may be required to submit updated disclosure documents, supporting materials, and an explanation to NIH.

Investigators should notify OSP and ORS immediately upon identifying a possible omission. Investigators should not independently submit corrections to NIH unless coordinated through the appropriate institutional office.

Foreign Components

A foreign component generally may not be added to an existing NIH award without NIH prior approval. Investigators should consult OSP and ORS before beginning significant scientific activities outside the United States or materially expanding an international collaboration.

Changes in Senior/Key Personnel

Changes involving the PD/PI or other Senior/Key Personnel may require notification to or prior approval from NIH. Investigators should consult OSP before implementing the change.

Research Performance Progress Reports

Investigators must ensure that information reported in the RPPR—including participants, accomplishments, products, support, foreign components, and changes—is complete and consistent with current institutional and sponsor disclosures.

NIH Resources

Proposal & Award Guidance

Research Security

Frequently Asked Questions

Need Assistance?

Questions regarding NIH disclosure requirements should be raised as early as possible during proposal development or whenever circumstances change during an active award.

Office of Sponsored Programs (OSP)

Provides assistance with proposal preparation, sponsor requirements, award administration, and sponsor prior approvals.

Office of Research Security (ORS)

Provides assistance with research security, disclosure requirements, international collaborations, foreign affiliations, research support disclosures, conflict of commitment, foreign talent recruitment programs, and other sponsor-related compliance matters.