July 10, 2019

NIH Requirements for Other Support

The National Institutes of Health has issued Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114) to remind NIH researchers that they must take care to report all of their foreign activities through other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.

“Other Support” includes 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.).

Please Note:
  1. All pending support at the time of application submission and prior to award must be reported using “Just-in-Time Procedures.”
  2. Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award, including “Other Support” changes that must be assessed for budgetary or scientific overlap.
  3. Further, if other support, as described as above, is obtained after the initial NIH award period, from any source either through the institution or directly to senior/key personnel, the details must be disclosed in the annual research performance progress report (RPPR).
  4. Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”
More details on “Other Support” reporting requirements, guidance on how to define a “foreign component,” and NIH reminders about financial conflict of interest reporting are described in NOT-OD-19-114.

Frequently Asked Questions on “Other Support” also are provided.

Please Note:
  • FAQ #A4 indicates that NIH requires that any foreign collaborations that “directly benefit” the investigator’s research be reported in “Other Support” even if the investigator is not involved and the project is not funded with NIH dollars.
  • FAQ #A5 indicates that NIH requires reporting of start-up packages and institutional research grants.
  • FAQ #A6 indicates that NIH requires reporting of outside teaching or consulting (paid or unpaid) if this activity is, “in any way,” related to the investigator’s research endeavors.
  • FAQ #A7 indicates that NIH requires the researcher report activities outside of the researcher’s appointment period (e.g., summer activities for a 9 month appointee).
  • FAQ #B6 indicates that a visiting postdoc paid by a foreign government but working in the US does NOT constitute a foreign component.

November 01, 2018 Research Advocate: NIH and NSF Current and Pending Support Requirements