NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel

Principal Investigators and Key Personnel on NIH awards may participate in foreign research grants and/or foreign employment but, as described recently by OSTP, may not participate in malign foreign talent recruitment programs. 

The Decision Matrix is based on the NIH Grants Policy Statement (GPS), NSPM-33, NSPM-33 Implementation Guidance, and 2 CFR 200.206.

Process for Handling Allegations Related to Foreign Interference
Learn about NIH's standard procedures for handling issues related to undisclosed other support, foreign components, and financial conflicts of interest (FCOI).

Forms

NOT-OD-24-163 - NIH’s Adoption of Common Forms for Biographical Sketch and Current and Pending (Other) Support by May 25, 2025

Biographical Sketch (2.3.7.12)

NIH requires the submission of a biographical sketch (also referred to as biosketch) for each proposed senior/key personnel and other significant contributor. 

Applicants and recipients are required to submit biosketches in 1) competing applications for all types of grant programs; 2) in progress reports when new senior/key personnel or other significant contributors are identified; and 3) to support prior approval requests for changes in senior/key personnel status and changes of the recipient organization. 

NIH staff and peer reviewers utilize the biosketch to ensure that individuals included on the applications are equipped with the skills, knowledge, and resources necessary to carry out the proposed research. Applications containing one or more biosketches that do not conform to the required format may be withdrawn. 

The below information is taken from the NIH Grants Policy Statement (NIHGPS), April 2024, and the General Application Guide for NIH and Other PHS Agencies, October 25, 2022. 

Positions, Scientific Appointments, and Honors

List in reverse chronological order all current positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). High school students and undergraduates may include any previous positions. For individuals who are not currently located at the applicant organization, include the expected position at the applicant organization and the expected start date.

List any relevant academic and professional achievements and honors. In particular:

• Students, post-doctorates, and junior faculty should include scholarships, traineeships, fellowships, and development awards, as applicable.
• Clinicians should include information on any clinical licensures and specialty board certifications that they have achieved.

Other Support (2.5.1 Just-in-Time Procedures)

Reporting of other support is required for all individuals designated in an application as senior/key personnel – those devoting measurable effort to a project.

Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes but is not limited to:

• Resources and/or financial support from all foreign and domestic entities, that are available to the researcher.  This includes but is not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).
  • Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources. 
• Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities. 
  • Non-research consulting activities are not Other Support.
• In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source. 
  • If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.

Other support does not include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as such.

Other Support information is requested for:

• All individuals designated in an application as senior/key personnel, except
  • Program Directors, training faculty, and other individuals involved in the oversight of training grants
  • Individuals categorized as Other Significant Contributors
• All senior/key personnel, excluding consultants, in progress reports when there has been a change in active other support, except
  • Program Directors, training faculty, and other individuals involved in the oversight of training grants

Each PD/PI or other senior/key personnel must electronically sign their respective Other Support form before submission. This signature certifies that the statements are true, complete, and accurate. 

Foreign Component

Per the NIH's Grant Policy Statement and Reminder on Foreign Components, a Foreign Component is the existence of any significant scientific element or segment of a project outside of the United States, in other words

1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or;
2. performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. 

Activities that would meet this definition include, but are not limited to:

• the involvement of human subjects or animals
• extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities
• collaborations with investigators at a foreign site that are anticipated to result in co-authorship
• use of facilities or instrumentation at a foreign site
• receipt of financial support or resources from a foreign entity
• any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. 

If both criteria are met, then there is a foreign component. To aid with what may be considered significant, click on the FAQ. 

The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, as outlined in the NIH GPS Section 8.1.2, Prior Approval Requirements.

If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as Other Support. 

NOTE  

For Other Support submissions that include foreign activities and resources, recipients are required to submit copies of contracts, grants, or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation.

If the contracts/agreements are not in English, recipients must provide translated copies.

Disclose external activities (Other Support) in upcoming Research Performance Progress Reports (RPPR) and/or via an email to the NIH Grants Management Specialist named in the Notice of Award as soon as it becomes known.

Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.