The Common Forms, explained

NIH has adopted the Common Forms as per the White House Office of Science and Technology Policy (OSTP) memorandum on Policy Regarding Use of Common Disclosure Forms. NIH implemented the Biographical Sketch Common Form and the Current and Pending (Other) Support Common Form for Research Performance Progress Reports (RPRRs) and application submissions on or after January 25, 2026. Use of the Common Forms and NIH Biographical Sketch Supplement will be required for all application due dates and Just-In-Time (JIT), Research Performance Progress Report (RPPR), and Prior Approval submissions on or after May 8, 2026. On that date, system warnings will change to errors that will stop any submission not using compliant Common Forms. This timing will also provide applicants with additional time to address errors before the May 25, 2026 standard receipt date for Cycle 2.

The approved Common Forms for Biographical Sketch and Current and Pending (Other) Support (OMB Number 3145-0279 managed by the U.S. National Science Foundation (NSF)), can be accessed at NSF’s website at NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization.

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement will be required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026.

See NOT-OD-26-018 for a table of effective dates relevant to different application, performance report, just-in-time and prior approval submission scenarios.

After evaluating the number and types of recent technical inquiries we received to both the SciENcv and eRA Service Desks, we recognize the difficulties these issues have had on the community’s ability to comply with the original timeline of January 25, 2026.

To allow for a period of leniency, NIH will provide a warning when the Common Forms are not used but will not withdraw applications that don’t comply with the use of the Common Forms. We expect the leniency to be in place through May 2026 (see NOT-OD-26-033).

Update on System Enforcement of Common Forms

The current leniency period previously communicated in NOT-OD-26-033 will end on May 7, 2026, the final AIDS standard receipt date for Cycle 1. See Notice: NOT-OD-26-079.

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support, and NIH Biographical Sketch Supplement will be required for all application due dates and Just-In-Time (JIT), Research Performance Progress Report (RPPR), and Prior Approval submissions on or after May 8, 2026.

During the remainder of the leniency period, NIH will continue to provide system warnings and will not withdraw applications containing the NIH Biosketch and NIH Other Support format pages, or non-compliant Common Forms. On May 8, 2026, system warnings will change to errors that will stop any submission not using compliant Common Forms. This timing will also provide applicants with additional time to address errors before the May 25, 2026 standard receipt date for Cycle 2.

In an effort to support strong collaboration between Federal research agencies, NIH is adopting the Common Forms for Biographical Sketch and Current and Pending (Other) Support as per the White House Office of Science and Technology Policy (OSTP) memorandum on Policy Regarding Use of Common Disclosure Forms. This Guide Notice provides details for the Common Forms, NIH Biographical Sketch Supplement, and instructions required for use for application due dates and Research Performance Progress Report (RPPR) submissions on or after January 25, 2026. An important reminder: institutions must maintain internal controls (e.g., policies and procedures) for disclosure, which must include training on these policies and procedures for senior/key personnel.

A table entitled, NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support for NIH will be posted on Common Forms for Biographical Sketch and Current and Pending (Other) Support that provides helpful reference information regarding pre-award and post-award disclosures. The table includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award lifecycle. A final column identifies activities that are not required to be reported.

Malign Foreign Talent Recruitment Program Prohibition:

Effective January 25, 2026, individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.

Definition: Malign Foreign Talent Recruitment Program.

Malign Foreign Talent Recruitment Program Certification:

NIH will require MFTRP certifications from applicants and individuals identified as senior/key personnel with its implementation of the Common Forms for Biographical Sketch and Current/Pending (Other) Support.

• Institutional Certification: In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), the AOR must certify, via their signature on the face page of the application (i.e., SF424 R&R cover form), that all individuals identified by the applicant as senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.
• Individual Certification at the time of the application: In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), each individual identified by the applicant as a senior/key person must certify on their Common Form for Biographical Sketch, attached on the R&R Senior/Key Person Profile (Expanded) Form, that they are not a party to a malign foreign talent recruitment program.
• Annual Certification at the time of the RPPR: For NIH awards with RPPRs submitted on or after January 25, 2026, individuals serving as senior/key personnel must certify annually to their participation or non-participation in an MFTRP by uploading a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ‘MFTRPcert_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.

Effective Date

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement will be required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026.

The current leniency period previously communicated in NOT-OD-26-033 will end on May 7, 2026, the final AIDS standard receipt date for Cycle 1. Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support, and NIH Biographical Sketch Supplement will be required for all application due dates and Just-In-Time (JIT), Research Performance Progress Report (RPPR), and Prior Approval submissions on or after May 8, 2026.

During the remainder of the leniency period, NIH will continue to provide system warnings and will not withdraw applications containing the NIH Biosketch and NIH Other Support format pages, or non-compliant Common Forms. On May 8, 2026, system warnings will change to errors that will stop any submission not using compliant Common Forms. This timing will also provide applicants with additional time to address errors before the May 25, 2026 standard receipt date for Cycle 2.

The Biographical Sketch Common Form is a standardized document used to summarize the qualifications, experience, and relevant contributions of key personnel for federally funded research projects.

It ensures consistency, transparency, and compliance with federal disclosure requirements, particularly those outlined in National Security Presidential Memorandum - 33 regarding foreign government-sponsored programs and talent recruitment activities.

NIH uses the Biographical Sketch Common Form together with the NIH Biographical Sketch Supplement.

• Common Forms for Biographical Sketch and Current and Pending (Other) Support Frequently Asked Questions (FAQs)
• Reminder: Applicants are required to have an ORCID ID and link it with their eRA Commons profiles.

The NIH Biographical Sketch Supplement collects three required NIH specific data elements (i.e., Personal Statement, Contributions to Science, and Honors) in accordance with NIH’s Peer Review Regulations at 42 Code of Federal Regulations Part 52h. This information is used to assess qualifications and documents an individual's qualifications and experience for a specific role in a project.

The Current and Pending (Other) Support (CPOS) form is a standardized document used to disclose all current and pending research support for senior/key personnel to assess capacity, conflicts of commitment, and potential overlap with proposed projects. The form was developed in response to the National Security Presidential Memorandum - 33.

Applicants are required to use Science Experts Network Curriculum Vitae (SciENcv) to complete the Biographical Sketch Common Form and the NIH Biographical Sketch Supplement to produce digitally certified PDF(s) for use in application submission. Do not flatten this PDF attachment