Behavioral Codes of Conduct for NIH Award Recipients

NIH is pleased to announce that the NIH Grants Policy Statement (GPS) was recently updated, replacing the December 2021 version as standard terms and conditions of award. The updated GPS applies to all awards issued on or after October 1, 2022. Consistent with longstanding federal regulations (45 CFR 75.303), institutions receiving NIH support will now be required to have internal controls to assure compliance with terms and conditions of award. These internal controls include behavioral codes of conduct to assure safe and healthful working conditions for their employees and foster work environments conducive to high-quality research.

NIH previously established their own code of conduct for NIH staff. Codes of conduct define what is expected for staff to maintain professional behaviors, integrity, and ethical values when conducting NIH-supported research. They align with other related efforts, such as requiring safety plans for NIH-supported conferences. The Advisory Committee to the NIH Director Working Group on Changing the Culture to End Sexual Harassment recognized their value too, calling on NIH-funded institutions develop or maintain a professional code of conduct as a condition of award (see recommendation 1.1d in their December 2019 final report). The UNITE E Committee, which has been developing new initiatives to address structural racism in biomedical research, also recognized the importance of requiring recipient institutions to have behavioral codes of conduct and was instrumental in getting this change made to the GPS.

It has been a long-standing expectation that recipients of NIH awards have systems, policies, and procedures in place to properly manage NIH funds and activities (see Section 8.3 of the GPS). These expectations derive from existing regulations centered around compliance and accountability, including uniform administrative requirements as well as standards for internal controls (cited by 45 CFR 75.303(a)).

Behavioral codes of conduct are integral to meeting this expectation. A recipient’s codes of conduct will assure their compliance with terms and conditions of award, such as:

• Providing true, complete, and accurate information on application documents (GPS Section 2.3.7.6)
• Assuring work environments are free of discriminatory harassment and are safe and conducive to high-quality work
• Meeting applicable public policy requirements (GPS Section 4.1).

Codes of conduct are critical to leveraging our prior efforts to ensure that people engaged in NIH-supported research do so in an environment free from harassment, discrimination, bullying, retaliation, or hostile working conditions. If you have a concern about harassment, discrimination, and other forms of inappropriate conduct at your institution, please find help on this page.

Original post by NIH Staff on 12.29.2022