An Update on How NIH Protects NIH-Funded Research from Undue Foreign Interference

Protecting the integrity of NIH-funded research while supporting international collaboration remains a priority for NIH. Over the past year, we have advanced initiatives to strengthen transparency and ensure disclosure of other support. These actions align with White House Office of Science and Technology Policy (OSTP) standards and build on prior work to address risks associated with foreign interference while reinforcing that honesty, transparency, and funding‑overlap prevention remain non‑negotiable requirements.

NIH is committed to upholding the highest standards of scientific integrity, public accountability, and social responsibility in the conduct of research. As part of this commitment, we work closely with applicant and recipient institutions, researchers, and other federal agencies to protect the integrity of the NIH biomedical research enterprise. NIH and the greater biomedical research ecosystem have a long history of international collaborations, with rules of engagement that allow science to advance while assuring honesty, transparency, integrity, fair merit-based competition, and protection of intellectual capital and proprietary information. These rules of engagement also are designed to limit bias in the design, conduct, and reporting of NIH-supported research. NIH’s grant compliance and oversight efforts have been and will continue to be based on objective behaviors. 

Below are examples of recent efforts. 

Foreign Interference Assessment Tool

NIH released a decision matrix for assessing potential foreign interference in August 2024. The matrix, developed using information available on the NIH Foreign Interference web page, functions as our decision tree, describing conditions in which NIH will contact the grant applicant or recipient for further information, and in which mitigation may be required, recommended, or not needed. NIH published the matrix to give NIH-funded institutions and researchers a better understanding of how their applications and disclosures may be received and reviewed throughout the application and grants process.

Revised Disclosure Forms

NIH continued its requirement that applicants and recipients disclose all sources of research support, foreign components, and relevant affiliations for senior/key personnel. The agency has moved forward with adoption of the Biographical Sketch and Current and Pending (Other) Support (CPOS) Common Forms (see NOT-OD-26-018) for applications with due dates on or after January 25, 2026. While supporting appropriate international collaboration, these forms allow NIH to assess the potential for any scientific, budgetary, or commitment overlap that may affect an individual’s ability to carry out the research effort as proposed. 

In addition, NIH required award recipients to train all faculty and researchers designated as senior/key personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see NOT-OD-25-133). This new training requirement complements existing disclosure policies and is designed to reduce unintentional omissions and improve institutional compliance. 

Small Business Program Foreign Risk Assessments

The April 13, 2026, reauthorization of the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs clarified which types of foreign relationships and security risks will be evaluated as well as which types of security risks require the denial of an award (see NOT-OD-26-074). If an award cannot be made due to a security risk, HHS will now advise the small business that a security risk was found that required denial of award and indicate which risk category necessitated the denial. Foreign disclosure requirements, risk categories, case studies, and FAQs can be found on our small business research Foreign Disclosure and Risk Management webpage.

Research Security Training Certification

In addition, NIH announced a new requirement that each senior/key personnel listed on an NIH grant application certify completion of research security training within 12 months of the date of application submission. Completion of the training and the individual and institutional certifications will be required for applications submitted for due dates on or after May 25, 2026 (see NOT-OD-26-017).

In Summary 

NIH strongly supports properly conducted international collaborations, which play a critical role in helping to keep the United States competitive. These collaborations must respect the integrity of the scientific process. Routine academic research activities can be done in the absence of scientific or budgetary overlap, overcommitment, and nondisclosure of financial conflicts of interest and foreign components.

It is critical for NIH-supported institutions and their researchers to be wholly transparent about financial support from and affiliations with international institutions. Such transparency ensures that NIH's funding decisions are fair and appropriate, and that U.S. institutions and the American public benefit from their investment in biomedical research.

Additional Resources:

• NIH Grants Policy Statement
• Summary of Significant Changes to the NIH Grants Policy Statement for March 2026 Version
• NOT-OD-26-057: Publication of the Revised NIH Grants Policy Statement (Rev. March 2026) for Fiscal Year 2026