Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries

SBIR STTR Foreign Disclosure Form

The Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries form applies to all competing applications for funding under the NIH, CDC, and FDA SBIR and STTR programs submitted for due dates on or after September 5, 2023.

SBIR STTR Foreign Disclosure Form
SBIR STTR Foreign Disclosure Form

Competing applications submitted for due dates on or after September 5, 2023

• Upon request from NIH institute or center staff, applicants will submit the completed disclosure form via the Just-In-Time (JIT) process described in the NIH GPS section 2.5.1 Just-in-Time Procedures. 
  • One disclosure form is filled out on behalf of the applying business and for all covered individuals in the application. 
  • Applicants fill out one disclosure form per application.
  • Applicants are required to disclose all affiliations requested in the Form, both related and unrelated to the requested project. Companies and other partner organizations listed in the application are part of the foreign risk assessment that takes place before an award can be made. More information can be found on the SEED Foreign Disclosure and Risk Management webpage.
  • Applicants are encouraged to disclose affiliations if they are uncertain whether the disclosure is required. 
  • Applicants may use the provided Form text boxes to add detail regarding an affiliation or lack of affiliation. Form text boxes may always be used to provide additional information, even when an applicant selects that they have no affiliation to disclose.
• Post-Award Reporting Requirements
  • Recipients are responsible for monitoring their relationships with foreign countries of concern post-award, for any changes that may impact previous disclosures. SBCs receiving an award under the SBIR/STTR program are required to submit an updated disclosure form to report any of the following changes to NIH, CDC, and FDA throughout the duration of the award:
    • any change to a disclosure on the disclosure form;
    • any material misstatement that poses a risk to national security; and
    • any change of ownership, change to entity structure, or other substantial change in circumstances of the SBC that NIH, CDC, and FDA determine poses a risk to national security.
  • Updated disclosure forms are required within 30 days of any change in ownership, entity structure, covered individual, or other substantive changes in circumstance, as described above. In addition, regular updates are required at the time of all SBIR/STTR annual, interim, and final Research Performance Progress Reports (RPPRs).

• NOT-OD-24-029: Clarification of Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-Award Requirements
• NOT-OD-23-139: Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-Award Requirements
• Just-in-Time Help & Tutorials
• SEED Foreign Disclosure and Risk Management webpage

July 2023