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NIH Compliance

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PDF of NIH RPPR Checklist Reporting on Collaborations FAQs for NIH Funding
Updated June 2024

The NIH plans to implement the Common Forms (Biosketch and Current and Pending (Other) Support) for all applications and RPPRs submitted on or after May 25, 2025.  Applicants/Recipients will be required to use Science Experts Network Curriculum Vitae (SciENcv) for completing and certifying the Common Forms. The Common Forms have been developed as part of the National Science and Technology Council (NSTC) Research Security Subcommittee. All federal sponsors will be announcing their implementation plans for the Common Forms.

SciENcv will generate a digitally certified PDF for use in application submission.

  • NIH will have a separate supplement form to collect the three required agency specific data elements (i.e., Personal Statement, Contributions to Science and Honors).
  • Reminder: Until the Common Forms are fully adopted by NIH, NIH requests applicants and recipients use the current NIH Biosketch and Other Support formats for applications, Just-in-Time (JIT) Reports, and RPPRs.

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Complying with National Institutes of Health Policy

A complete list of agency links and information is available at the bottom of this page.

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 caltechcoi@caltech.edu.

PIs may enter their appointments/positions in the Biosketch and Other Support application in access.caltech.edu.

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 caltechcoi@caltech.edu.

The NIH 2024 Grants Policy Statement can be found here- https://grants.nih.gov/policy/nihgps/index.htm (April 2024)

Complying with NIH Policy when Completing Grant Applications

Other Support, Biosketches and Facilities, Equipment and Other Resources

Biosketches must be provided for all Senior/Key personnel and Other Significant Contributors.

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 there is more than one, the first one listed will have primary responsibility for the project and the submission of reports.

The term "Other Significant Contributors" is defined by NIH as:

Individuals who have committed to contribute to the scientific development or execution of the project, but are not committing any specified measurable effort (i.e., person months) to the project. These individuals are typically presented at "effort of zero person months" or "as needed." Individuals with measurable effort may not be listed as Other Significant Contributors (OSCs). Consultants should be included if they meet this definition.

Biosketch

Biosketch Format Pages, Instructions, and Samples (updated August 2022)

(NIH recently updated their guidance to require only "current" positions and appointments, instead of "all" positions and appointments)

Include all current 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. However, NIH does not require reporting of appointments that involve only a mentor/mentee arrangement that is unrelated to the senior/key personnel's research activities. Per the June 2022 chart, NIH states " Mentoring as part of an appointment, or mentor/mentee arrangements that do not involve the individual's research activities" and checks the box "Disclosure Not Required" See https://grants.nih.gov/grants/forms/NIH-Disclosures-Table.pdf

PIs must enter ALL positions and appointments in the Disclosure of Financial Interest and Commitments (DFIC) to correctly populate the Biosketch and Other Support application in access.caltech.edu.

Changes effective January 25, 2022 (postponed from May 25, 2021):

Section A

  • 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

  • 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)."

Section D

  • 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.

NIH references:

Consider using ORCiD Open Researcher and Contributor ID - a unique, persistent identifier free of charge to researchers. More information may be found at: https://libguides.caltech.edu/orcid.

Foreign Components

NIH requires grantees to seek prior approval of when a non-US entity will perform a significant part of an NIH-funded project, regardless of whether NIH funds will be used to support that work.

Caltech should evaluate the activity conducted outside of the United States within the context of the project as a whole and determine 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.

NIH references:

Complying with NIH Policy when Completing Just-In-Time (JIT) Submissions

Institutional Financial Resources

Note that some Institutional resources must also be disclosed in addition to the traditional forms of support.

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, e.g., when the awards are used for a project that has a (1) defined scope of work; (2) budget; (3) effort commitment by the PI; or (4) defined 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 delivered 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.

Start-up funds

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.

Other Support

ATTENTION: 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)

Other Support and Biosketches must be provided for all senior/key personnel. Other Significant Contributors must also update their Biosketches during the JIT process

NIH defines the term "Other Significant Contributors" as Individuals who have committed to contribute to the scientific development or execution of the project, but are not committing any specified measurable effort (i.e., person months) to the project. These individuals are typically presented at "effort of zero person months" or "as needed." Individuals with measurable effort may not be listed as Other Significant Contributors (OSCs). Consultants should be included if they meet this definition.

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.

Re-Organization of Form

Signature Block Added

  • All PD/PIs, other senior/key personnel, and other significant contributors 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

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:
- financial support for laboratory personnel, including visitors and volunteers- postdoctoral fellowships paid directly to a researcher funded by a foundation or other organization if the person is performing research activities in support of your research endeavors- the provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.), provided within the last three years, and that are still in use.
  • 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.
- report collaborators with whose experiments directly benefit your researchor- provide you with "high value" materials, samples, etc. that have been provided to you in the last three years, and that are still in use.  Be sure to include such materials that you would plan to acknowledge as contributions to your work in a publication.

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

NIH references:

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 (RPPR)

Changes in Other Support information must be updated annually for the PD/PI, those individuals considered by Caltech to be key to the project.

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 there is more than one, the first one listed will have primary responsibility for the project and the submission of reports.

Beginning in May 2022, 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?" See page 94 of the guide.

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 is 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.

NIH references:

NIH and Other PHS Agency Research Performance Progress Report (RPPR) Instruction Guide June 2022

Other Support Instructions (updated continuously)

Frequently Asked Questions (FAQs) - Other Support and Foreign Components (updated continuously)

NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support (updated June 2022)

Foreign Interference (previously Protecting US Biomedical Intellectual Innovation (updated August 2022)

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114)

Additional Relevant Agency Notices:

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.

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.