Published on Jul 24, 2019
To Federal Award PI’s and Research Administrators,
NIH has released a new Notice to remind grant recipients about reporting foreign activities through documentation of Other Support, Foreign Components and Financial Conflict of Interests.
The Notice is available at https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html with accompanying FAQs on Other Support and Foreign Components available at https://grants.nih.gov/grants/faq-other-support-foreign-components.htm.
It is important that all NIH investigators of active, pending and proposed projects and their research administrators read and understand the contents of these two documents.
NIH considers the contents of the Notice to be clarifications and not changes in policy. However, some clarifications may be different from past interpretations of the requirements, especially as they relate to reporting of Other Support. The NIH Notice provides that applicants and recipients should report the following as Other Support (emphasis added):
- “Report all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).”
- “Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts” (such as a visiting scholar or scientist working in a laboratory while supported by another organization).
- “Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space if provided outside of the University, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.”
- “Report the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.”
We are monitoring developments closely and are working with our peers and national organizations to better understand these requirements. Please understand that while this information was recently released by NIH, we expect that further revisions by NIH to the Notice and/or FAQs may be forthcoming. Please contact any manager in URA if you have questions about these requirements or the NIH reporting obligations more generally.
Michael R. Ludwig
Associate Vice President for Research Administration & Director, URA
Office of Research and National Laboratories
The University of Chicago