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PHS 2590 (Non-Competing Continuation Progress Report)

PHS 2590 is the Non-Competing Continuation Progress Report, a Public Health Service-wide, OMB-approved form (face page, detailed budget for the next period, budget justification, progress-report summary, personnel and inclusion-enrollment reporting) historically filed annually on an already-funded, non-competing award. At NIH, the RPPR (Research Performance Progress Report) now replaces it for all Type 5 non-competing continuation annual progress reports, all project closeouts, and all interim reports; NIH restricts current PHS 2590 use to Type 4 administrative extensions, such as an SBIR/STTR Fast-Track Phase II application. The pre-RPPR SNAP/non-SNAP fork on the 2590 (whether a detailed budget page was required) carried over directly into the RPPR's own Section H budget requirement and due-date calculation. The form now in circulation is the 08/2025 revision, with a current OMB expiration date of 11/30/2027 and the previously required Trainee Diversity Report removed.

ByCASRAI Editorial Board
· Last updated 6 Sept 2026
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Editorial commentary

PHS 2590 is the Non-Competing Continuation Progress Report — a Public Health Service–wide, OMB-approved form (face page, detailed budget for the next period, budget justification, progress-report summary, and personnel/inclusion reporting) that grantees used to file each year to report on an already-funded, non-competing award. At NIH it has been superseded for that purpose: NIH now requires the Research Performance Progress Report (RPPR) for every Type 5 (non-competing continuation) annual progress report. The PHS 2590 itself still exists and is still current — NIH’s own use of it today is restricted to a narrower case, covered below — and other PHS awarding agencies may set their own requirements for it independent of NIH’s RPPR transition.

The SNAP vs. non-SNAP fork

Before the RPPR, the PHS 2590 itself carried a fork between two award types: a SNAP (Streamlined Non-Competing Award Process) award and a non-SNAP award, distinguished mainly by whether a detailed, categorized budget page was required for the coming period. That same fork did not disappear when RPPR replaced the form — it moved into the RPPR itself, where it still governs two concrete mechanics: which award types must complete the RPPR’s Section H budget page, and how far in advance the report is due. Per NIH’s own current RPPR guidance, a SNAP RPPR is due roughly 45 days before the next budget period starts; a non-SNAP RPPR is due roughly 60 days out, reflecting the extra time NIH program staff need to review the more detailed budget non-SNAP awards still require. So “is this a SNAP or non-SNAP award” is still the first question that determines what a grantee files and when — the form changed, the fork underneath it did not.

What replaced it: the RPPR

The RPPR is now the required vehicle for every type of NIH progress reporting: annual (Type 5) continuation, project closeout, and interim reporting ahead of a competing renewal. It is submitted electronically through the RPPR module in eRA Commons, with no paper or email-based alternative — the PHS 2590’s paper-form-shaped structure (face page, numbered sections, attachments) does not carry over into the RPPR’s own section layout one-for-one. For the report types, sections, and current deadlines, see CASRAI’s NIH RPPR guide; for NIH’s award-closeout mechanics specifically, see NIH Closeout.

Where PHS 2590 still applies at NIH

NIH’s own current guidance restricts PHS 2590 use to progress reports for administrative extensions — Type 4 awards — with an SBIR/STTR Fast-Track Phase II application named as the example case. That is a materially narrower use than the form’s old, general-purpose role: it is no longer the annual continuation vehicle for standard research grants, only for this specific extension mechanism. Sponsored-programs offices should not assume a 2590 request means the old non-competing-continuation workflow; confirm with the awarding Institute or Center whether the request is genuinely a Type 4 administrative extension before routing it as one.

The current form

The PHS 2590 in circulation now is the 08/2025 revision. Its most recent substantive update carries a new OMB expiration date of 11/30/2027 and removes the previously required Trainee Diversity Report from the form set. The combined form package still covers the face page and multiple-PI continuation pages, a detailed budget for the next budget period, a budget justification, a progress-report summary, personnel reporting and checklists, and the PHS Inclusion Enrollment Report. NIH’s Forms Directory is the authoritative source for biosketches, other-support documentation, and the data tables a complete Type 4 submission needs alongside the 2590 itself.

Requirement Authority Where to read it
RPPR required for all Type 5 non-competing continuation reports NIH grants policy (Office of Extramural Research) grants.nih.gov, PHS 2590 form page
PHS 2590 restricted to Type 4 administrative extensions NIH grants policy (Office of Extramural Research) grants.nih.gov, PHS 2590 form page
Current form revision, OMB expiration date OMB-approved PHS-wide form (Office of Extramural Research) grants.nih.gov, PHS 2590 form page
SNAP RPPR due ~45 days out; non-SNAP RPPR due ~60 days out NIH grants policy (Office of Extramural Research) grants.nih.gov, RPPR page

Checking this against the current guidance

Which attachments an awarding Institute or Center actually wants on a Type 4 administrative-extension 2590 — versus what a standard non-competing continuation used to require — is an agency-by-agency, case-by-case call that a general overview like this one cannot settle.

Ask CASRAI: When NIH uses the PHS 2590 for a Type 4 administrative extension instead of a full non-competing continuation, which standard 2590 attachments — the budget justification, the Personnel Report, the PHS Inclusion Enrollment Report — are still required, and which does the agency typically waive for an extension request?

It searches CASRAI’s indexed corpus of research-administration guidance and cites the passage behind each claim, so you can open the source and check it rather than take its word — and it says so when the corpus does not cover something instead of guessing. Two questions a day are free while you are signed out, no account and no card. Everything CASRAI publishes stays free to read.

Frequently Asked Questions

Is the PHS 2590 the same thing as the RPPR?

No. The RPPR is what replaced it for the vast majority of NIH progress reporting. NIH requires the RPPR for every Type 5 (non-competing continuation) annual progress report, every project closeout, and every interim report. The PHS 2590 itself still exists as a current, OMB-approved form, but at NIH it is now used only for Type 4 administrative extensions.

What is a Type 4 administrative extension, and why does it still use the 2590?

A Type 4 is an administrative-extension award action rather than a standard annual continuation — NIH’s own example is an SBIR/STTR Fast-Track Phase II application. NIH’s current guidance keeps the PHS 2590, not the RPPR, as the reporting vehicle for that specific case.

What is the difference between a SNAP and a non-SNAP award?

SNAP stands for Streamlined Non-Competing Award Process. The practical difference is the budget page: a non-SNAP award needs a detailed, categorized budget for the coming period; a SNAP award does not. That fork predates the RPPR — it ran through the PHS 2590 — and it still determines both the RPPR’s Section H budget requirement and its due date today (SNAP due roughly 45 days before the next budget period starts, non-SNAP roughly 60 days out).

What changed most recently on the PHS 2590 form itself?

The form now in circulation is the 08/2025 revision. Its most recent substantive update set a new OMB expiration date of 11/30/2027 and removed the previously required Trainee Diversity Report from the form package.

Do PHS agencies other than NIH still use the PHS 2590 for regular continuations?

PHS 2590 is formally a Public Health Service–wide form, not an NIH-only one. This page describes NIH’s own current restriction to Type 4 administrative extensions specifically; it is not a statement about every other PHS awarding agency’s practice. Confirm the current requirement directly with the specific awarding agency (for example CDC, HRSA, or another PHS component) rather than assuming NIH’s Type-4-only restriction applies there too.

Where do I get the current PHS 2590 form and instructions?

NIH’s own PHS 2590 form page is the authoritative source for the current fillable forms and instructions, and for the related biosketch, other-support, and data-table requirements a complete Type 4 submission needs alongside it.

Machine-readable encodings

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