Updated November 3, 2021
Complying with National Institutes of Health Policy
November 3, 2021: Request for NIH investigator foreign agreements. As of January 25, 2022, NIH requires any senior and key personnel on awards and submitting proposals to provide supporting documentation specific to paid or unpaid foreign appointments (including honorary) and/or employment with a foreign institution.
Please review your disclosure in the COI disclosure system (access.caltech.edu) and make sure all such appointments or employment are disclosed there and send a copy of the associated agreement to email@example.com.
If you are receiving funding from or named on grant awarded to a foreign institution, you should disclose that as other support in the COI disclosure system and send a copy of the associated agreement to firstname.lastname@example.org.
July 31, 2021: NIH issues report of its findings on foreign influence cases from 2016 to 2021
July 18, 2021: NIH issues updated and new FAQs related to reporting Other Support
May 17, 2021: PIs have asked for more guidance on reporting research collaborators as NIH Other Support. Please review Caltech's guidance on when to report collaborators to the NIH, which includes several examples.
May 11, 2021: In response to concerns raised by the academic community, NIH is deferring implementation of its new Other Support and Biosketch formats and the other new requirements imposed in Notice NOT-OD-21-073 which was issued on March 12. The changes will now go into effect on January 25, 2022 instead of May 25, 2021.
You still must disclose all Other Support as described in that Notice and in Notice NOT-OD-19-114 in your just-in-time submissions and RPPRs. And you should contact OGC if you have any previously undisclosed other support.
For more details, please see the memo regarding the Update on NIH Requirements from the Vice Provost.
April 28, 2021: NIH issued a follow-up Notice: NOT-OD-21-110 regarding the May 25th deadline for reporting Other Support and biographical information on the Biosketch.
March 12, 2021: NIH issued Notice No. NOT-OD-21-073, which announced updated application forms and instructions intended to further promote transparency and full disclosure of all resources (both domestic and foreign) that directly support the individual's research endeavors. All proposal applications and Just-In-Time requests either submitted or with due dates on or after May 25, 2021, must comply with these new requirements.
The information below is intended to guide users to complete the NIH Other Support, Biosketches, and Foreign Component information.
Complying with NIH Policy when Completing Grant Applications
Other Support, Biosketches and Facilities, Equipment and Other Resources
Other Support and Biosketches must be provided for all senior/key personnel and faculty associates. The term "senior/key personnel" includes:
(Co)Principal Investigator(s) - the individual(s) designated by the grantee and approved by NIH who will be responsible for the project's scientific or technical direction. If more than one, the first one listed will have primary responsibility for the project and the submission of reports.
Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the performing institution to be a member of its faculty or who holds an appointment as a faculty member at another institution and who will participate in the project.
Appointments: All positions, domestic and foreign, including titled academic, professional, or institutional and regardless of whether full-time, part-time, voluntary, adjunct, visiting, honorary, or if remuneration is received.
Include all external positions and scientific appointments, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments if remuneration of any kind (compensation or in-kind) is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary), as Other Support if held by senior/key personnel and regardless of whether awarded through Caltech, another institution or directly to the researcher.
Note that external appointments that do not involve any remuneration should be reported in the Biosketch, and paid appointments must be included in Other Support.
Changes effective January 25, 2022 (postponed from May 25, 2021):
- Section A ("Personal Statement") adds language specifying that this section should be used for "including details on ongoing and completed research projects from the past three years that the researcher wants to draw attention to (previously known as research support)".
- Section B, "Positions and Honors," has been renamed "Positions, Scientific Appointments, and Honors".
- Changes the order of listing from "chronological order" to "reverse chronological order."
- Revised to include the following specific language: "List in reverse chronological order all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary)."
- Non-Fellowship Biosketches - Section D ("Scholastic Performance") has been removed.
- Fellowship Biosketches - Section D ("Scholastic Performance") has been updated to remove "Research Support".
Updated SciENcv Template
NIH anticipates that the updated SciENcv Biosketch template will be available by FY2022. Those with existing biosketches in SciENcv should be able to transfer their current biosketch information to the new format.
- Biosketch Format Pages, Instructions, and Samples (updated March 2021)
- Frequently Asked Questions (FAQs) - Biosketches (updated March 2021)
- Instructions for a Biographical Sketch
- Protecting US Biomedical Intellectual Innovation
NIH requires grantees to seek prior approval of when a non-US entity will be performing a significant part of an NIH-funded project, regardless of whether NIH funds will be used to support that work.
Performance of any significant part of an NIH project outside of the US includes, but is not limited to:
Caltech should evaluate the activity being conducted outside of the United States within the context of the project as a whole, and make a determination about its significance and whether it is a Foreign Component. Examples of activities that may be considered a significant element of the project include, but are not limited to:
- collaborations with investigators at a foreign site anticipated to result in co-authorship
- use of facilities or instrumentation at a foreign site
- receipt of financial support or resources from a foreign entity
Note: If the PI expects to name a foreign collaborator on any publications resulting from an NIH-funded project, name the person and the entity as a "foreign component" in the application, and seek prior approval before engaging the collaborator.
Complying with NIH Policy when Completing Just-In-Time (JIT) Submissions
Institutional Financial Resources
Note that in addition to the traditional forms of support, some Institutional resources must also be disclosed.
Internal Awards (e.g., Caltech Innovation Initiative)
Internal awards are included in Other Support if the award is in direct support of a research project. Specifically, the awards are used for a project that has (1) scope of work; (2) budget; (3) effort commitment by the PI; (4) period of performance.
Gifts made to Caltech
Caltech and the federal government define a gift as something given without expectation of anything in return. If an item or service meets the definition of a gift, it is not reported as Other Support. If a gift was given to Caltech for use on a specific research activity, the funds must be disclosed as Other Support. Also, 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 to NIH as Other Support.
Caltech start-up packages provided to the PI from Caltech are NOT included in Current and Pending Support. Start-up packages from institutions other than Caltech must be reported in Current and Pending Support.
ATTENTION: NEW CHANGES TO OTHER SUPPORT, EFFECTIVE JANUARY 25, 2022 (postponed from May 25, 2021 - see NIH Notice No. NOT-OD-21-073, issued March 12, 2021)
Re-Organization of Form
- The format page has been restructured, separating funded projects from in-kind contributions.
Signature Block Added
- All PD/PIs and other senior/key personnel must electronically sign the Other Support form prior to submission to NIH, certifying that the information is accurate and complete. Other Support forms must be submitted as a flattened PDF after all signatures are obtained. Original electronic signatures must be maintained and made available upon request
Supporting Documentation Relating to Foreign Activities or Resources
- If the Other Support submission includes foreign activities or resources, copies of contracts, grants, or any other agreements specific to the PD/PI or other senior/key personnel's foreign appointments, affiliations, and/or employment with a foreign institution must be included with the Other Support submission. These documents must be translated into English if they are in a foreign language.
Immediate Notification of Undisclosed Other Support
- If an organization discovers that a PD/PI or other senior/key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or RPPR submissions, the institution must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known. If you believe you need to disclose new information to NIH, please contact the Office of General Counsel (OGC).
Formatting & Future Transition to SciENcv
- NIH anticipates that the SciENcv template for Other Support will be available beginning in FY 2022. Until then, the MS Word version of the Other Support form should be used. (It must be converted to PDF and electronically signed prior to submission.)
How does NIH use Other Support Information?
NIH states that its scientific program and grants management staff review Other Support information to ensure that:
- All resources, domestic or foreign, directly supporting the individual's research endeavors have been reported
- Sufficient levels of effort are committed to the project
- There is no scientific, budgetary, or commitment overlap
- 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.
In addition to the above new requirements (which go into effect January 25, 2022), Other Support submissions must report the following, based on current, established NIH requirements:
NIH requires information on current and pending support for ongoing projects, and proposals.
All domestic and foreign research collaborations that directly benefit the researcher's research endeavors (new).
Include the following Other Support information:
All planned, pending and current project support and in-kind support that is either provided directly to the individual, or through an organization in support of that individual's research endeavors, from whatever source, including, but not limited to:
- Contracts or Cooperative Agreements for Research – All such sponsored agreements for research or educational activities that take place at Caltech or elsewhere must be included as Current and Pending Support.
- Consulting activities that involve performing research* for other entities that exceed Caltech's policy of one day per week or thirteen (13) days per quarter must be included in Other Support. Report the estimated amount paid for the consulting activity and not the time or effort commitment for the consulting (new).
- Reminder: Consulting activities must be reported through the Caltech Conflict of Interest Disclosure system regardless of whether external consulting supports research endeavors.
- Fellowship Program - Included in Other Support If the fellowship is granted to the Principal Investigator and/or key personnel.
- Foreign Talent Program1 - Include in Other Support for the Principal Investigator and any senior/key personnel (new).
- Grants for Research - Included as Other Support regardless of whether or not the grants are based at Caltech.
In-Kind support: Other resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether they have monetary value and whether they are based at the institution the researcher identifies for the current grant. This includes but is not limited to:
- Resources and/or financial support from all foreign and domestic entities that are available to the researcher. This includes but is not limited to:
- Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support but rather listed under Facilities and Other Resources.
- All domestic and foreign research collaborations that directly benefit the researcher's research endeavors, regardless of which projects they benefit.
When in doubt, err on the side of disclosure to federal sponsors.
Projects and Activities - All Projects and Activities not already included above are included as Other Support if the project or activity supports an individual's research in any way at Caltech or any institution or entity.
Prizes and Training Grants - Not included as Other Support
- Other Support Instructions (updated March 2021)
- Frequently Asked Questions (FAQs) - Other Support and Foreign Components (updated March 2021)
- Protecting US Biomedical Intellectual Innovation
- Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
- COGR - Commentary on Disclosing Other Support and Other Resources in Research Funded by the National Institute of Health
1 Foreign Government Talent Recruitment Program. In general, such programs include any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States. These recruitment programs are often part of broader whole-of-government strategies to reduce costs associated with basic research while focusing investment on military development or dominance in emerging technology sectors. See https://www.sciencemag.org/sites/default/files/January%20DOE%20memo.pdf for more information, including distinguishing features of a foreign government talent recruitment program as defined by the Department of Energy.
* NIH defines research as a systematic study directed toward fuller scientific knowledge or understanding of the subject studied." And, "[t]he term research also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function." See the Glossary – I-35 https://grants.nih.gov/grants/policy/nihgps/nihgps.pdf
Other disclosures during Just In Time (JIT)
Please note that Caltech is required to promptly notify NIH of any substantive changes to previously submitted Just-in-Time information up to the time of the award.
Accordingly, review the Biosketch and other disclosures and make any necessary revisions before submitting JIT information for a new award.
Research Performance Progress Report
Changes in Other Support information must be updated annually for the PD/PI and for those individuals considered by Caltech to be key to the project and must be reported in the annual progress report. Senior/key personnel are defined as individuals who contribute in a substantive measurable way to the scientific development or execution of the project, whether or not a salary is requested. NIH has added the following question to the RPPR: "D.2.c Changes in Other Support - Has there been a change in the active other support of senior/key personnel since the last reporting period?"
Use the new NIH Other Support page for both the JIT process and subsequent annual reports.
See the page on RPPR reporting, or follow NIH's detailed RPPR instructions beginning on page 86 of the document/page 93 of the RPPR instructions PDF.
If there have been changes in senior/key personnel's Other Support, prepare a revised Other Support report, and upload it to the RPPR. Annotate the information so it is clear what has changed since the last submission.
Contact the Office of Sponsored Research (OSR) if you have questions about completing the RPPR.
Request Prior Approval for Foreign Components including, any significant part of an NIH project performed outside of the U.S., including, but not limited to:
- international collaborations involving activities outside of the U.S.
- other research activities related to the grant, performed at a foreign location
See the Caltech guidance on research collaborations for more information.
Updates to Biosketch
At this time, there is no ability to report updated Biosketch information to NIH in the RPPR.
Reporting Undisclosed Relationships to NIH
Effective January 25, 2022, Caltech will be required to inform NIH immediately of any missed disclosures of Other Support within 30 days after it becomes known to Caltech. NIH states: 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.
If you believe you need to disclose new information to NIH, please contact the Office of General Counsel (OGC). If you and OGC determine that there is something to report, you will work with OSR to submit the retroactive disclosure to NSF using an "Other Request" in Research.gov.
Other Support Instructions (updated March 2021)
Frequently Asked Questions (FAQs) - Other Support and Foreign Components (updated March 2021)
Relevant Agency Notices:
- NIH FAQs Regarding Other Support and Foreign Components
- July 10, 2019 Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114)
- NIH Grants Policy Statement: 16 Grants to Foreign Organizations, International Organizations, and Domestic Grants with Foreign Components.
- April 28, 2021 Implementation of Changes to the Biographical Sketch and Other Support Format Page (NOT-OD-21-110)
- March 12, 2021 Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 (NOT-OD-21-073)
- July 16, 2020: NIH issued statement to follow principles aligned with those announced by the White House's Office, Science and Technology Policy in June 2020
- July 8, 2020: NIH Open Mike Blog: Addressing Foreign Interference and Associated Risks to the Integrity of Biomedical Research, and How You Can Help
- June 12, 2020: Advisory Committee to the NIH Director issued report on Foreign Influences on Research Integrity
Checklist and Guidance for Complying with NIH Policy when Reporting Other Support (4/15/2021). Thank you to the University of California, Santa Barbara for their very helpful website on these requirements.
Thank you to Michelle Christy for assistance with this site.