Behavioral Codes of Conduct for NIH Award Recipients


We are 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.

We previously established our 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
  • 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.



  1. “structural racism in biomedical research”, a scientific theory that, interestingly, no scientific institution has ever been able to prove is actually happening.

  2. This will flow through to to the people we subcontract with? If they don’t have codes, then they will have to agree to use ours?

  3. Unfortunately, while there has long been a need for more attention to harassment, bias, bullying, etc. in laboratories, not only by PIs but other investigators as well, and a role for NIH in requiring grant recipients to ensure “safe” working conditions, misconduct seems to now include anything outside HR “best practices” that leads to a complaint. Scientists simply do not work in safe environments if we use criteria appropriate for accounting firms, government offices or retail stores. At any given time, a fraction of scientific researchers will be dissatisfied, frustrated, angry, irritable, disgruntled and maybe even discouraged and depressed. However, it is completely normal to have strong emotional reactions, often negative, when one’s “job” is to struggle to do very difficult things like repeatedly discover and validate results that no other scientists have reported while experiencing failure more often than success. Of course, scientists have to fear the string of perfectly normal failures that may end their career. Some scientists will consider their situation unfair while others may act out inappropriately and upset their colleagues. Both situations lead to reasonable complaints, many of which can be addressed case-by-case by involving unconflicted third parties and listening, advising, counseling, interventions, mediation, retraining, etc. Ensuring that scientists can access this kind of individualized help without suffering further harm is important and should be a priority for NIH. However, training and science are not going to be improved if we start treating each adverse situation as potential misconduct equivalent to scientific fraud and/or triggering formal reporting as we do reflecting our Title IX reporting responsibilities, automatically initiating a formal, confidential and lawyered-up CYA process that can easily end with harm to all parties save for the institution and NIH.

    1. I agree with your comment. The victimhood culture will be terrible for science. We also need to protect the most important diversity of all: diversity of opinion and free inquiry. Ideology and dogmatism is doing a lot of harm to science already.

    2. Thank you to Dr. Kron for spelling out what worklife is for an academic researcher! Is NIH not aware research Universities have had HR departments for as long as they’ve existed? And, customarily HR departments spend 100% of their time devoted to maintaining supportive and decent workplaces. Wasn’t NIH’s original mandate to build and maintain a national research infrastructure in support of major teaching Universities? Appears somehow the line between which institution is responsible for what, and who is supporting who, has gotten blurred? For the sake of academic researchers, everywhere, isn’t it time NIH works to LIGHTEN the load of bureaucratic responsibility, and return to trusting the academic institutions and researchers they support?

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