Learn about NIH's standard procedures for handling issues related to undisclosed other support, foreign components, and financial conflicts of interest (FCOI).
Standard Procedure

-
Potential issues are identified by:
- Institutional self-disclosure
- NIH Institute or Center or NIH Office of Extramural Research (OER) staff
- Anonymous allegations received in various ways, including through submition via NIHResearchIntegrity@mail.nih.gov
- Other, including law enforcement
-
Allegations/concerns are reviewed by OER staff to assess:
- If NIH-funded grants are involved
- Whether sufficient and verifiable information exists to proceed
- What information has been disclosed to NIH
-
If NIH-funded research is involved, OER staff conduct an in-depth assessment to determine whether other support was properly disclosed. The NIH Deputy Director of Extramural Research (DDER) sends a letter to the institution (usually the Vice President of Research) regarding the issue. The letter content includes:
- A reminder of NIH's requirements for disclosure of other support, foreign components, and FCOI regulations.
-
A request for the following information, as applicable:
- All applications, notifications of award, and progress reports related to undisclosed grants (English translation and original language)
- Employment documents (including all contracts or agreements) for the individual's positions at foreign institutions
- A request for a response within 30-60 days
-
Institutional responses are reviewed to assess:
- Whether there is any scientific, commitment, or budgetary overlap with NIH projects
- Whether Significant Financial Interests (SFIs) were appropriately disclosed to the recipient institution
- Whether the individual adhered to Financial Conflict of Interest (FCOI) management plans
- Whether prior approval was obtained for foreign components on the NIH project
- Other factors and actions relevant to the allegation
-
Appropriate actions are taken commensurate with degree of noncompliance, which may include:
-
Coordinating with funding IC(s) on necessary grants management actions
- Requesting the recipient institution to identify a replacement principal investigator on an NIH award
- Holding pending awards associated with the PI of concern until compliance issues are resolved
- Fully or partially restricting funds until compliance issues are resolved
- Imposing specific award conditions to terms of award
- Working with recipient institution to recover funds
- Referral to the HHS Office of Inspector General (OIG) and/or referral for suspension or debarment
-
Coordinating with funding IC(s) on necessary grants management actions