Common Forms & SciENcv — the 2026 disclosure standard

NIH — following the NSPM-33 Implementation Guidance and the federal Common Forms framework — requires that every senior/key person on an application submit their biosketch and Current & Pending (Other) Support using the SciENcv tool, with each researcher personally certifying their submission. Every researcher's ORCID identifier must be linked to their eRA Commons account. The requirement applies to all applicant institutions, regardless of size.

The three-phase rollout

NIH implemented the requirement in three phases (Guide Notices NOT-OD-26-018 and NOT-OD-26-079):

1. Policy implementation — January 25, 2026. From this date, applications were expected to use the Common Forms / SciENcv / ORCID format.
2. Leniency period — through May 7, 2026. NIH continued to accept applications that did not fully meet the new requirements without automatic system rejection, to give institutions time to complete the transition.
3. System enforcement — beginning May 8, 2026. NIH's electronic Research Administration systems now reject applications that do not conform to the Common Forms / SciENcv / ORCID requirements. For applications submitted on or after this date, non-conforming disclosures fail at submission, not at review.

Institutions preparing NIH proposals today are working under system enforcement — the leniency period is over.

What changed

Before the Common Forms transition, disclosure formats varied by agency and often by application mechanism. Institutions collected disclosures in many shapes; consistency across agencies was weak; the researcher's personal certification was implicit rather than explicit.

The Common Forms standard, implemented through SciENcv as the production tool, changes three things at once:

• Format is standardized. The same biosketch and Current & Pending form structure across NIH, NSF, and other federal science funders.
• Certification is personal and explicit. The researcher, not the institution, signs the disclosure inside SciENcv before it becomes part of the application.
• Identity is bound. ORCID linked to eRA Commons ties the researcher's public scholarly record (publications, employment, affiliations) to the certified disclosure.

Who is covered

Every senior/key person on an NIH application; every senior person on an NSF proposal; and — as other agencies complete their Common Forms rollouts — the equivalent designation at each funder. There is no funding threshold for this requirement, unlike the NSPM-33 program certification.

What the AOR certifies

The institutional AOR continues to certify at submission that the information in the application is true, complete, and accurate to the best of the AOR's knowledge. What changed is what "the information" now contains: personally certified disclosures whose accuracy the AOR must be able to defend if challenged. False Claims Act settlements to date (see the FCA tracker) have hinged precisely on this point — disclosures that were certified but not verified.

The categories most frequently under-disclosed

Enforcement cases and audit findings converge on the same short list. These are the items an institution's verification process must actively reconcile:

• Foreign appointments — including adjunct, courtesy, honorary, and talent-program positions with foreign institutions.
• Foreign in-kind support — laboratory space, personnel, samples, materials, or equipment provided by a foreign entity, whether or not a cash grant is involved.
• Foreign grants and support — funding from any foreign government, institution, or program not previously reported.
• Publications and affiliations that imply undisclosed engagement — authorship of papers acknowledging support the researcher's disclosure does not reflect.
• Effort commitments — total person-effort exceeding what the researcher's institutional time allows.

What institutions should do now

1. Confirm every senior/key person has an active SciENcv-linked ORCID iD tied to their eRA Commons account. Without the linkage, applications will not be accepted.
2. Update pre-submission review to inspect the SciENcv-certified forms, not a locally reformatted copy. The certified form is the record that will be audited.
3. Cross-check the disclosure against authoritative sources. Publications (ORCID, PubMed) that acknowledge undisclosed support are the highest-yield finding.
4. Document exceptions and their resolution. If a disclosure was updated between draft and submission, keep the trail. AORs are certifying to the final state.
5. Extend the same review to NSF submissions. The Common Forms framework is a federal standard, not an NIH-only requirement.