What the 2026 Common Forms rules change for disclosure review

NIH (along with the federal Common Forms schedule and NSF) requires every senior/key person on an application to submit biosketch and Current & Pending (Other) Support using SciENcv, with each researcher personally certifying the submission and every ORCID identifier linked to eRA Commons. Policy implementation began January 25, 2026 (NIH Guide Notice NOT-OD-26-018); a leniency period ran through May 7, 2026; and system enforcement began May 8, 2026 (NOT-OD-26-079) — from that date, NIH's eRA systems reject applications that do not conform. The requirement is small in text and large in consequence: the institutional review process built around locally reformatted disclosures no longer matches the certification the AOR signs.

The three practical shifts

On paper, Common Forms is a format standardization. In practice it changes three things about what disclosure review has to look like inside the institution:

1. The certified form is the SciENcv form — not the institutional copy

Historically, sponsored programs offices often collected disclosure information in an institutional template, reformatted it, and submitted the result. That workflow is still common. It is now also structurally divergent from the certification: the researcher's personal certification lives inside SciENcv, on the SciENcv-produced form, which is what the application ultimately carries. If institutional review inspects a locally reformatted copy, it is reviewing a document that is not what was certified.

2. Personal certification is now explicit

The researcher's certification inside SciENcv is a discrete step, not an implicit consequence of "the PI signed off." This has legal weight: enforcement cases now rest, in part, on what the researcher personally attested, distinct from what the institution certified. Under the False Claims Act framework the institution's exposure remains — but the individual's exposure has been sharpened.

3. ORCID-eRA Commons linkage makes the record checkable

ORCID is a persistent researcher identifier that carries publications, employment history, and affiliations. Linking it to eRA Commons ties the researcher's public scholarly record to the certified disclosure, and — this is the operational point — makes the disclosure checkable against sources the researcher does not control. The linkage is federal infrastructure for exactly what our platform does.

What institutional review has to do differently

1. Inspect the SciENcv-produced form, not a reformatted copy. The certified form is the record that will be audited.
2. Reconcile the certified disclosure against the ORCID record. Publications that acknowledge undisclosed support are the highest-yield finding across the enforcement history to date.
3. Check Current & Pending against the categories enforcement looks at — foreign appointments, foreign in-kind support, foreign grants. See our Common Forms explainer for the recurring under-disclosed list.
4. Document every exception and its resolution — as evidence attached to the certification, not as free-text notes in a spreadsheet.
5. Extend the same review to NSF submissions. The Common Forms framework is a federal standard, not an NIH-only requirement.

The pattern this creates

Every application now carries a certification that rests on: (a) what the researcher personally attested in SciENcv, (b) what the institutional record shows, and (c) what the public scholarly record (ORCID, PubMed, sponsor systems) shows about the same researcher. The institution's job is to reconcile the three, resolve the mismatches before submission, and keep the evidence.

Historically, that reconciliation happened only when an application drew attention. Under the current framework, it has to happen at the point of every certification — because every certification is a statement to the federal government, and the FCA does not distinguish between routine and prominent submissions.