The University of Iowa: NIH Common Forms Implementation and Basic Experimental Studies in Humans (BESH)

Division of Sponsored Programs

NIH Allowing for Period of Leniency Related to Common Forms Implementation (FAQ)

Though NIH has not issued an official notice, an FAQ posted on the NIH website suggests the agency is aware of numerous technical issues associated with the implementation of the Common Forms and intends to allow for a period of leniency:

5. Will Grant applications submitted for due dates on or after January 25, 2026 be withdrawn if they do not use the Common Forms?

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement are required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026.

After evaluating the number and types of recent technical inquiries we received to both the SciENcv and eRA Service Desks, we recognize the difficulties these issues have had on the community’s ability to comply with the original timeline of January 25, 2026.

To allow for a period of leniency, NIH will provide a warning when the Common Forms are not used but will not withdraw applications that don’t comply with the use of the Common Forms. We expect the leniency to be in place through May 2026. NIH will issue a Guide Notice announcing the date when the validation will be changed to an error and the requirement to use the Common Forms will be system-enforced.

Basic Experimental Studies in Humans (BESH) Will No Longer Be Considered Clinical Trials by the NIH

Effective with applications submitted to due dates on or after May 25, 2026, Basic Experimental Studies in Humans (BESH) will no longer be considered clinical trials by the NIH. Going forward, BESH will not have to follow the requirements for clinical trials, including registration and reporting in ClinicalTrials.gov. BESH must continue to follow all other applicable clinical research laws, regulations, and policies, including, but not limited to human subjects protections and the NIH Data Management and Sharing Policy.

Currently funded BESH studies should follow their established Terms and Conditions of Award as well as NOT-OD-25-134 (Flexibilities for Registration and Results Reporting of Prospective Basic Experimental Studies with Human Participants).

The NIH will provide further guidance and examples for how to assess if a study is BESH, a clinical trial, or an observational study involving humans. NIH is actively reviewing current instructions and system validations and will provide detailed guidance in a forthcoming Guide Notice on any instruction or system changes, as needed, to reflect the updated classification. NIH also anticipates expiring all BESH-specific NOFOs for due dates on or after May 25, 2026 because BESH research can now be accepted through the Clinical Trials Not Allowed companions of these NOFOs.

Full Notice
National Institutes of Health
NOT-OD-26-032
January 29, 2026