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Clarifying Long-Standing NIH Policies on Disclosing Other Support

Who funds your current research? Make sure to let NIH know. It is required.

Institutions and investigators must disclose all forms of what is termed “other support” when applying for and receiving NIH grants. Other support, as described in the NIH Grants Policy Statement (GPS) Section 2.5.1, includes all resources, regardless of whether or not they have monetary value, available in direct support of an individual’s research endeavors.

This is not new, but rather a long-standing requirement for those seeking NIH grants to be fully transparent regarding all of their research activities both domestic and foreign, which is critical for prudent fiscal management, accountability, and stewardship of U.S. taxpayer funds.

So, do you need to report those other NIH grants you have? Yes. What about a contract from another federal agency? Yes. Grants or contracts that go through another institution, including institutions in foreign countries?  Yes.  Commercial funds? Yes. Domestic or international positions held by senior/key personnel? Yes. In kind lab or office space? Yes. Scientific materials? Yes. Even if it has no monetary value? Yes. Affiliations (even if described as honorary or adjunct) with foreign entities or governments, including talents programs? Yes.

NIH uses this information to ensure that all resources made available to an investigator, including any foreign activities, are considered prior to making an award. With this in hand, we will know that sufficient levels of effort are committed to the project, there is no scientific, budgetary, or commitment overlap, and only the funds necessary to the approved project are included in the grant award.

We recently published a Guide Notice to clarify what is meant by foreign activities as they relate to other support and what NIH expects to be disclosed. As part of this notice, applicants are reminded they must also promptly notify NIH if previously submitted just-in-time information is substantively changed prior to award or at the time of the progress report, which could lead to budgetary, scientific, or commitment overlap.

Since institutions are the applicants for and recipients of NIH funding, they are responsible for ensuring that all materials submitted to NIH are complete and accurate. This means they must also ensure individual investigators make all appropriate disclosures to them regarding other support, affiliations, and financial interests. Sometimes we discover potential issues involving institutions not accurately reporting other support, including foreign support through foreign institutions, associated with their NIH award.  Sometimes it’s because investigators don’t report their foreign research activities to their American institutions. In such cases, we can take (and have taken) action. Depending on the severity and duration of the noncompliance (see NIH GPS Section 8.5), we may contact the affected institutions, impose specific award conditions, disallow costs, withhold future awards for the project or program, suspend the award activities, make a referral for investigator suspension or debarment, or terminate the award.

I want to be clear that we are focusing our efforts on enhancing research integrity across all our processes and systems. The extraordinary contributions of foreign nationals to American science are indisputable. As just one example, 24% of U.S. Nobel prizes have been awarded to foreign-born scientists. The biomedical research workforce continues to be greatly enriched and strengthened by scientists who come to our shores from many parts of the world. The overwhelming majority of researchers participating in NIH grants, whether U.S. or foreign-born, are honest contributors to the advancement of knowledge that benefits us all. Driving away talented scientists from other countries would have a profoundly negative effect on American productivity.

We appreciate the efforts of recipient organizations to partner with us to improve reporting of all sources of research support and international collaborative research. These obligations are instrumental to protecting the integrity of biomedical research.  Working together, we can be better assured that federal funding decisions are sound, proprietary information is protected, and compliance with grant terms is achieved.

If you have questions, please refer to the FAQs, the Guide Notice, or send an email to grantscompliance@od.nih.gov for additional assistance.

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18 thoughts on “Clarifying Long-Standing NIH Policies on Disclosing Other Support

  1. I work at a national laboratory, and our management tells us not to report internal funding (e.g., LDRD). Is this in violation of Current Support that NIH seeks? Sometimes we put a disclaimer or footnote if one of our PIs is mainly supported on internal funding (e.g., <75%).

    • All resources and other support for individuals designated as senior/key personnel, must be reported. Information must be provided about all current support for ongoing projects, including those where the support is provided by the applicant organization.

  2. I’m in agreement with the primary sentiment expressed in this article about disclosing other support.

    I’m appalled, however, that NIH would cast thinly veiled aspersions against foreign researchers.

    “The overwhelming majority of researchers participating in NIH grants, whether U.S. or foreign born, are honest contributors….” to me sounds very much like “most of [name the ethnic group here] are honest people.” There is no need to say that, unless you believed the opposite.

    You should be ashamed of using government space and resources to make these sorts of thinly-veiled aspersions against non-US born researchers. I still cannot believe this article was posted by NIH. Shame on you.

  3. It appears philanthropic gifts and endowments are not included as part of other support, but that is not explicitly stated.

  4. The article notes that these types of support should be reported: “Domestic or international positions held by senior/key personnel? Yes. In kind lab or office space? Yes. Scientific materials? Yes. Even if it has no monetary value? Yes. Affiliations (even if described as honorary or adjunct) with foreign entities or governments, including talents programs? Yes.” However, we have had a number of requests for revised other support documents following JIT submissions because we included a form of support for which the person does not have a specific effort commitment. The instructions we received said we could not include entries unless we included associated person months. Can you please give guidance about reporting support, such as in-kind office space, that would not have any committed effort?

    • NIH is currently updating the Other Support Format page to provide additional guidance and examples for these types of resources. At this time, applicants and recipients should provide the data requested on the Format Page, as applicable. In your example, office space, since there is no effort that would not need to be included.

  5. The statement, “Other support, as described in the NIH Grants Policy Statement (GPS) Section 2.5.1, includes all resources, regardless of whether or not they have monetary value, available in direct support of an individual’s research endeavors.” is vague.
    Should we report intellectual resources, like discussion with colleagues, research-in-progress meetings, all University core facilities, in other support? What about materials (cells, proteins, DNAs, etc.) we obtain from colleagues? This statement reads like a bureaucratic attempt to cover the NIH’s posterior rather than an honest effort to account for support. This is way too broad and is likely lead to unanticipated consequences.

    • Informal meetings and discussions with colleagues would not fall within the scope of resources available in direct support of an individual’s research endeavors. Similarly, University core facilities or other general institutional resources that are made broadly available would not be reportable as Other Support. These general facilities available in support of the NIH project should be described in the Facilities and Other Resources portion of the application.

  6. As a foreign-born researcher in this great country, I am appalled how Lauer, Collins and company are okay being complicit in this xenophobic witch hunt promoted by the current administration.

    • Sadly, your playing of the “xenophobia” card is the ideal camouflage for the truly bad actors in this story. The countries of origin did the targeting and NIH is simply reacting to its aftermath. In one case, the foreign funding agency told grantees not to divulge their funding to NIH. This breach of NIH rules was a part of the foreign agency’s conditions for support. Understanding the scope of this issue may prevent the knee-jerk responses that our present times are fueling.

  7. My research central office has come out with a new rule in order to address the NIH requirements that we must list all foreign post docs on our Other Support going forward. They are to be considered an “in kind” contribution. Are they correct that the NIH wants us to do this from now on? If so will the NIH be publishing guidance soon that specifically says we must do this? I feel as if our central office may be going overboard trying to interpret what the NIH wants us to do and this new rule is making some of our faculty uncomfortable. Anyone who has knowledge of this issue your feedback would be appreciated

  8. The initial release of the Other Support and Foreign Components FAQs addressed startup packages and consultant fees. I noticed in the August 6th version there is no mention of either. Does this mean they are no longer required to be included in Other Support? Please advise as soon as you possibly can. Thanks. Sheree

  9. Please provide some guidance with regard to documenting a non-effort based support. The existing Other Support format does is inconsistent with this type of reporting. Are we expected to put a $$ value to all support – what is the rubric for this relatively abstract kind of reporting. Please provide some implementation guidance. Thank you.

  10. Could it be that some of this information belongs in the Research Support section of the biosketch rather than in Other Support? A properly created biosketch has the framework for providing all this information without creating confusion about effort-based support. Please, please clarify. Additional guidance is really needed.
    Thank you, MK

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