Published March 16, 2020
This website contains guidance for completing Other Support documents for the National Institutes of Health (NIH). The NIH released a notice in July 2019 to “clarify,” not change or update, the information requested in Other Support.
Though NIH called the notice a “clarification” some of the information now requested appears to be a departure from what was traditionally provided in Other Support. In addition to NIH, NSF is revising their Current and Pending Support instructions.
This guidance is subject to change and will be revised as sponsors release new information.
Other Support requirements are not the same as the University’s Financial Conflict of Interest disclosing requirements, though there will be overlap of activities that are included in both. Please contact the UB COI Officer regarding any questions concerning what should be disclosed via the Click COI Module to satisfy the University’s Conflict of Interest Policy.
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.
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:
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.
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).
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.
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.
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:
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: