NIH/OER (Approved for implementation by October 2018)
NIH Conflict of Interest Rules:
Information for Reviewers of NIH Applications and R&D Contract Proposals
The NIH peer review system relies on the professionalism of each reviewer to identify any conflict of
interest (COI) or apparent COI that may affect or appear to affect the integrity of the NIH peer review
process.
• The NIH COI rules for initial peer review for grant applications, and technical evaluation of
R&D contract proposals, are based on federal regulations (42 CFR Part 52h) and presented in
detail in NIH Guide Notices NOT-OD-13-010 and NOT-OD-14-069.
• Note: Beginning immediately, all reviewer COI certifications, including certifications for
technical evaluation of R&D contract proposals, must go through electronic certifications.
• In order to participate in the review meeting, you must:
o Review the appropriate set of rules below and screen the applications or proposals for
real or apparent COI for yourself.
o Notify the Scientific Review Officer immediately:
If you have a COI that prevents you from serving on that review panel (see
below), or
If you are assigned to an application with which you have a COI.
o Electronically certify (see sample certifications):
On the pre-meeting Conflict of Interest Certification that you have
identified any application or proposal with which you have a COI or appearance
of COI, prior to the peer review meeting.
• For grant application reviews, if you do not certify the pre-meeting
COI, you will not be able to submit critiques, criterion scores and
preliminary scores.
• A recertification will be required if an additional conflict is discovered
before the meeting or under other scenarios (meeting date changes
and certifications reflect the previous date, etc.).
On the post-meeting Conflict of Interest Certification that you recused
yourself from the review of any application or proposal pending review in the
Scientific Review Group where your participation constitutes a real or apparent
COI. In addition, the NIH may determine that a particular situation involves a
COI and require that the potential reviewer not be involved in the review of
the application(s) or proposal(s) in question.
The post-meeting COI certification must be electronically signed at the time
you complete your participation in the study section meeting. Paper
certifications will no longer be accepted.
• Federal employees participating in NIH peer review are subject to a comprehensive set of
statutes and regulations governing their conduct, in addition to NIH policy regarding their
selection and use in the peer review process. A Federal employee serving as an NIH peer
reviewer is responsible for obtaining any clearance required by his/her employing institute,
agency, or office.
Reviews of Applications for Grants, Cooperative Agreements, and Fellowships
You may not be on the study section if:
• You are named on an application in a major professional role (Program Director/Principal
Investigator [PD/PI], Senior/Key Personnel, Other Significant Contributor, Project/Site/Core
