Compliance Updates and Information


NSF Notice on Harassment

The National Science Foundation has issued Important Notice No. 144: Harassment. NSF is working to make certain NSF’s awardee organizations respond promptly and appropriately to instances of sexual and all other forms of harassment.

This notice describes a new award term that includes the following new requirements: 

  • Grantee organizations will be required to report findings of sexual harassment, or any other kind of harassment regarding a PI or co/PI or any other grant personnel.
  • Grantees also will be required to report the placement of the PI or co-PI on administrative leave relating to a harassment finding or investigation.

NSF will be soliciting feedback on this term through an announcement in the Federal Register within the next few weeks.


Changes affect National Institutes of Health applications:

  1. NIH applications submitted on or after January 25, 2018 requires all sites participating in multi-site studies, which involve non-exempt human subjects research funded by the NIH, will use a single Institutional Review Board (sIRB) to conduct the ethical review required for the protection of human subjects. This policy applies to the domestic sites of NIH-funded multi-site studies where each site will conduct the same protocol involving non-exempt human subjects research. The requirement does not apply to career development, research training or fellowship awards. 

    Applicants must include a plan for the use of a sIRB in the grant application.  For more information: Single IRB Policy for Multi-site Research  The USA Human Subjects website provides Institutional Policy and Procedures for compliance with the NIH sIRB mandate. 
  2. NIH will require all applications involving one or more clinical trials be submitted through a Funding Opportunity Announcement (FOA) specifically designed and designated for clinical trials.

    For more information: Reminder: Policy on Funding Opportunity Announcements (FOA) for Clinical Trials Takes Effect January 25, 2018 (NOT-OD-18-106)
  3. NIH applicants must use FORMS-E application packages for due dates on or after January 25, 2018.


The U.S. Department of Health and Human Services and 15 other federal departments and agencies have announced an Interim Final Rule (IFR) that delays by six months the effective date and general compliance date of the revisions to the “Federal Policy for the Protection of Human Subjects” (also known as the Common Rule) originally published in the Federal Register on January 19, 2017 (82 FR 7149). Most provisions in the revised Common Rule were scheduled to go into effect on January 19, 2018.

The IFR delays the effective date and general compliance date to July 19, 2018, providing regulated entities additional time to prepare to implement these revisions.


Human Subject's Protection:  Changes to the Common Rule

The effective date of compliance is set to take effect on January 19, 2008.  The previous rule applies to research approved prior to January 19, 2018 and will not transition to the new rule. 

See "Changes to the Common Rule for summary of updates.

The 2017 Final Rule was originally slated to become effective on January 19, 2018, and institutions Required to comply with its new requirements by that same date. However, on January 20, 2017, President Trump issued an executive memorandum freezing all regulations that had been published but were not yet effective. 

On October 7, 2017, the Office of Management and Budget (OMB) received a proposal from the Department of Health and Human Services (DHHS) that, by its title, seeks a “1-Year Delay of the General Implementation Date While Allowing the Use of Three Burden-Reducing Provisions During the Delay Year.”

Until a formal delay is published by final rulemaking, we will continue to prepare for the implementation to comply with the updated changes by January 19, 2018. 


NIH Changes to Certificates of Confidentiality

Effective October 1, 2017, NIH will automatically issue Certificates of Confidentiality to all research funded by NIH that is collecting or using identifiable sensitive information. Additional information can be found on the NIH Certificates of Confidentiality Kiosk at In part, the new policy reads:

"For the purposes of this Policy, consistent with subsection 301(d) of the Public Health Service Act (42 U.S.C 241), the term "identifiable, sensitive information" means information about an individual that is gathered or used during the course of biomedical, behavioral, clinical, or other research.

Consent document wording related to the NIH Certificate of Confidentiality has been provided by NIH consent sample language.


Guidance on Exceptions to the NIH Single IRB Policy

Notice Number:  (NOT-OD-18-003) National Institutes of Health 

Guidance on Implementation of the NIH Policy on the Use of a Single Institutional Review Board for Multi-Site Research

Notice Number:  (NOT-OD-18-004) National Institutes of Health 


Clinical Trial Requirements for NIH Grantees and Contractors

NIH is launching a series of initiatives that are rolling out in 2017-2018 to enhance the accountability and transparency of clinical research. These initiatives target key points along the whole clinical trial lifecycle from concept to results reporting. Learn more about these changes and how they will affect your research. 


The American Statistical Association's points of caution in interpreting p-values