NIH requests disclosure of “Other Support” as part of its Just-in-Time procedures and in annual research performance progress reports (RPPR). NIH clarified its expectations regarding “Other Support” reporting in its July 2019 Notice NOT-OD-19-114 and related FAQ . It is very important that all NIH investigators of active, pending and proposed projects and their research administrators read and understand the contents of these two documents.
Please understand that while this information was recently released by NIH, further revisions by NIH to the July 2019 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 and check this website for up-to-date information.
The July 2019 Notice defines “Other support” very broadly, to include “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).”
While the following list is not inclusive of all “Other Support”, investigators should be particularly mindful of the following types of relationships and report them:
Other Appointments. All positions and scientific appointments both domestic and foreign held by senior/key personnel that are related to research endeavors including affiliations with foreign entities or governments should be disclosed. 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).
In addition to disclosure of the appointment itself, if compensation and other monetary support is provided through an appointment (e.g., visiting professorship at a foreign university), these financial terms should be included in the Other Support disclosure.
Per the NIH FAQs, even if a researcher is not receiving monetary compensation under the appointment, if lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts (whether or not such research is supported by Federal funds), the appointment constitutes Other Support. Note, other payments, such as travel or living expenses must also be reported.
Participation in “Foreign Talent Programs” NIH has indicated that selection to a foreign “talents” or similar-type program constitutes Other Support and therefore must be disclosed. However, the NIH has not provided a definition of these programs. If you have questions or wish to discuss whether a particular activity constitutes a disclosable talent program, contact Mallory Snyder, Director, Research Integrity ((773) 702-4857; firstname.lastname@example.org).
In-kind support. NIH has also clarified that “Other Support” includes non-monetary support, such as laboratory space, personnel, and access to equipment and facilities provided by the non-applicant institution.
Participation of Visiting Researchers/Scholars. Participation of Visiting Researchers/Scholars may result in the need to disclose such participation as Other Support and/or may trigger the need for a Foreign Component Approval discussed below.
With respect to visiting researchers that perform research in University labs, investigators should also be sure to comply with all requirements relating to Export Controls
Support Received Outside of Appointment Period (for 9-month Appointees). PIs with a 9-month appointment should disclose support received for research they conduct during the year, even if outside of their 9-month appointment. For example, if the PI spends two months at a University outside of the U.S. during the summer conducting research under a foreign award, NIH has indicated this should be disclosed as other support.