Guidance Regarding Disclosures of NIH Other Support

Below are some general guidelines to help standardize and set expectations on what to include in Other/Current and Pending Support documents submitted by University at Buffalo senior/key personnel when requested as part of a sponsored project proposal or Just-in-Time (JIT) request.

• It is the investigator’s responsibility to ensure the accuracy of Other/Current and Pending Support documents, in accordance with the application guidelines or the sponsor’s instructions.
• Any activity conducted within the scope of an Investigator’s UB appointment that receives funding or requires a quantifiable commitment of time must be reported.
  • Commitments are regular obligations of time (part of an investigator’s regular activities), not short-term obligations, such as attending a meeting or making a presentation.
  • If an Investigator has a quantifiable commitment for an activity but is receiving no salary support from the activity (salary is cost shared by the University), that activity must be reported.
• All collaborations and affiliations that provide funding or require a commitment of time must be reported, whether foreign or domestic.
• Investigator’s VA-funded activities should be included.

Each sponsor may differ slightly in the information they require for Other/Current and Pending Support, so careful reading of specific sponsor requirements is needed. Per specific sponsor guidelines:

• Include the proposal being submitted as a pending proposal (clearly state that the proposal is the proposal under consideration).
• Include projects within a no-cost extension.
• Address potential overlap or over-commitments. As this is a primary concern of Federal agencies, please be clear in your explanations.
• Update information as much as possible, e.g., remove outdated proposals or expired awards, unless specifically requested by sponsor.

Investigator/Department Responsibility:  As sponsor guidance may change, SPS recommends that the investigator/department pay close attention to the sponsor’s instructions in the request for proposal, policy guides, etc. on how to prepare these Other/Current & Pending Support documents. Each sponsor may request slightly different information or require that it be provided following their own format.

Investigators and departments should be prepared to respond to a sponsor’s questions about the information provided in Other Support.

report all resources made available to a researcher in support of and/or related to all of their research endeavors.

all individuals designated in the NIH application as senior/key personnel – including the program director/principal investigator (PD/PI) and 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. Other Significant Contributors  do NOT submit Other support.  Generally, a consultant is not considered senior/key personnel. However, if the consultant contributes to the scientific development or execution of a project substantively and measurably, he/she should be designated as senior/key personnel and would be included in Other Support.

• INCLUDE: all resources made available in support of and/or related to all your research endeavors, not just those endeavors related to this particular project the Other Support is for.
• INCLUDE resources from any source (federal, non-federal, commercial, foreign, institutional) that directly support your research endeavors
• INCLUDE: resources that do not have a monetary value
• INCLUDE: resources and/or financial support available to the investigator whether the resources are available to the investigator through their UB appointment/association or through their appointment/association with any other institution, either foreign or domestic (e.g., the VA).
• DO NOT INCLUDE: institution-wide resources such as core facilities or shared equipment that are made broadly available (this should be listed in the Facilities statement of the application)

Despite the excerpt from the GPS shown below, and the clarification listed in Notice NOT-OD-19-114, there still remains some ambiguity in what NIH wants disclosed in Other Support. 

The below information, which is subject to change pending additional guidance, reflects our current understanding of what should be included in Other Support. Please see NIH FAQs for additional guidance.

*include all resources made available to support all of an individual’s research endeavors (not just the project being considered for funding).

• Domestic and foreign grants and contracts, whether signed and administered through the RF, SUNY, UB, or another institution, or to the researcher directly should be included.
• Awards resulting from RF/SUNY/UB-funded competitions, such as SUNY TAF funds, should be included.
• Non-monetary support provided for the benefit of an investigator’s research endeavors needs to be included. This includes resources and facilities that are uniquely available to the researcher, but would not include facilities, services, or resources available for shared use and not specific to the individual investigator. Those facilities, services and resources would typically be reported under the Facilities and Other Resources section of the application.
• Provision of scientific materials that are not freely available for use at UB or another institution where the faculty is working (e.g., biologics, chemical, model systems, technology, equipment, etc.) should be included.
• Financial support for laboratory personnel (e.g., students, postdocs, or scholars working in a researcher’s lab at UB and who are supported by a foreign entity either through salary, stipend, or receipt of living or travel expenses) should be included.
• Gifts, training grants, and prizes are still excluded from Other Support. Care must be taken to ensure that funds are appropriately categorized. However, gift funds utilized to support the key personnel’s research endeavors should be included.
• Start-up funds provided by UB are not subject to disclosure in Other Support. Although key personnel must include start-up packages and other forms of research support provided by other institutions.
• Participation in a foreign talent program needs to be included.
• Academic, research, or administrative appointments at a foreign institution, even if the appointment is uncompensated need to be included. This includes appointments that are full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
• Any foreign affiliation that is likely to be included in any publication by the UB faculty member from an NIH award should be included.
• Individuals with a 9-month appointment must include any time spent conducting research under a foreign award over the summer. See the NIH FAQ on this topic.
• All resources provided by a foreign organization, whether monetary or not, should be included.
• Any contractual agreement with a foreign institution or government agency should be included.
• Any agreement with a foreign university for which the UB faculty member directs non-UB students, postdocs, or other personnel affiliated with that university should be included.
• Any non-UB agreement in which foreign funds or other resources are provided to the faculty for activities either at UB or at a foreign institution should be included
• Other funding (e.g., salary, stipend, honoraria, etc.) paid to a UB researcher by an outside entity should be included.
• Provision of lab space at another institution, foreign or domestic should be included.
• Consulting activities, which re not considered research do not require reporting; however, when the individual will be conducting research as part of the consulting activities, it must be reported as Other Support.
• Travel and/or living expenses directly paid or reimbursed by an outside entity should be included.

On July 10, 2019, the NIH Office of the Director issued Notice Number: NOT-OD-19-114 “Reminders of NIH Polices on Others Support and on Policies related to Financial Conflicts of Interest and Foreign Components”. This Notice changed some of the guidance NIH has provided in the past. This Notice is accompanied by FAQs. As NIH issues more anticipated clarifications on the Notice referenced above, SPS will update this guidance.

This Notice and associated FAQs indicate that ALL resources and other support be included, such as internal projects (i.e., TAF funds) and in-kind resources (e.g., space, equipment, supplies, employees). NIH instructs investigators to err on the side of disclosure and report.

SPS recognizes this updated guidance from NIH does not align with the current designated Other Support template format. National organizations such as Council on Governmental Relations (COGR) are working with NIH to clarify and streamline Other Support reporting. NIH is developing new forms, but the timeline for their release is not known. COGR’s Commentary on Disclosing Other Support to NIH can be found here.

Other Support
Includes all resources made available to researcher or senior key personnel 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. Other support does not include training awards, prizes, gifts or start-up support from the US based institution.
Source: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_1/1.2_definition_of_terms.htm

Other Support

Information on other active and pending support will be requested as part of the Just-in-Time procedures. 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:

• Resources and/or financial support from all foreign and domestic entities that are available to the researcher. This includes 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.). Institutional resources, such as core facilities or shared equipment that is made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.

• Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities.

• In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.

Other support does not include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as Other Support.

Reporting of other support is required for all individuals designated in an application as senior/key personnel-those devoting measurable effort to a project. Information on Other Support is not specifically requested for Program Directors, training faculty, and other individuals involved in the oversight of training grants since applicable information is collected in other sections of a training grant application. It is also not requested for individuals categorized as Other Significant Contributors.

Recipients are expected to establish and maintain effective internal controls (e.g. policies and procedures) to ensure that individuals designated in applications as senior/key personnel fully disclose all Other Support information to their institution as soon as it becomes known. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

For Other Support submissions that include foreign activities and resources, recipients are required to submit copies of contracts, grants, or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation. If they are not in English, recipients must provide translated copies.

The supporting documentation must be provided as part of the Other Support PDF following the Other Support Format page. See NIH Other Support page for forms, instructions, and other resources.

IC scientific program and grants management staff will review this information before award to ensure the following:

• Sufficient levels of effort are committed to the project.
• There is no scientific, budgetary, or commitment overlap.
  • Scientific overlap occurs when (1) substantially the same research is proposed in more than one application or is submitted to two or more funding sources for review and funding consideration or (2) a specific research objective and the research design for accomplishing the objective are the same or closely related in two or more applications or awards, regardless of the funding source.
  • Budgetary overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salaries) are requested in an application but already are provided by another source.
  • Commitment overlap occurs when an individual's time commitment exceeds 100 percent (i.e., 12 person months), whether or not salary support is requested in the application.
  • Overlap, whether scientific, budgetary, or commitment of an individual's effort greater than 100 percent, is not permitted. Any overlap will be resolved by the IC with the applicant and the PD/PI at the time of award.
• Only funds necessary to the approved project are included in the award.
• Any foreign resources that meet the definition of a foreign component have received appropriate prior approval.

Source: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_2/2.5.1_just-in-time_procedures.htm

• When an individual holds multiple appointments involving support for research activities, information from each appointment must be included separately in the Other Support documentation. The support from each funding source should be clearly and separately delineated so that the separate appointments can be considered independently when determining any potential overlap.
• List each appointment separately and include enough information on the type of appointment so that an assessment of an individual’s commitment can be made. Within each appointment, include appropriate sources of research support providing the standard detailed information cited above.
• Note that when an individual has multiple appointments (UB & VA) it is possible that the combined effort can result in excess of 12 calendar months (not from any one institution, but a combination of multiple appointments). In all cases, an individual’s combined total professional effort must meet a test of reasonableness.
• Source: https://www.research.va.gov/services/shared_docs/Other-Support-JIT.pdf