The Council on Governmental Relations (COGR) has engaged with the leadership of the National Institutes of Health (NIH) regarding questions that COGR member institutions have raised concerning NIH’s Biosketches and Other Support FAQs.
In response, NIH has updated these FAQs to make the following clarifications:
- Faculty consulting activities must be reported as Other Support only when the consulting activity involves research and “fall[s] outside of an individual’s appointment” with their home institution.
- When consulting activities constitute Other Support, they should be reported as estimates of the amount paid, as opposed to an estimate of time and effort.
- Consulting activities do not count towards the 12 calendar months of effort.
- NIH will not require the disclosure of completed support (including completed in-kind support) as Other Support, only current and pending support. (FAQs I.B.3 & I.C.5).
- Institutions need only go back three years in reporting as Other Support materials that were received from external collaborators. (FAQ I.C.7). NIH has provided separate guidance on when data and resources should be acknowledged in grants. [See, FAQs – Communicating and Acknowledging Federal Funding.]
- Information may not be redacted from contracts, agreements, or other supporting documents that are submitted to NIH. (FAQ I.D.8). [Note that this FAQ differs from some prior NIH verbal statements on this topic.]
- If a researcher has a foreign appointment, affiliation, and/or employment with a foreign institution, they must provide supporting documentation of that relationship, even if they do not have a formal agreement in place. (FAQ I.D.9).
