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Policy No: 2132
Responsible Office: Research & Economic Development
Last Review Date: 10/22/2025
Next Required Review: 10/22/2030
Policy No: 2132
Responsible Office: Research & Economic Development
Last Review Date: 10/22/2025
Next Required Review: 10/22/2030

NIH Other Support Reporting Requirements and Process

1. Purpose

This policy ensures institutional compliance with , with particular emphasis on the preparation, training, and certification of Other Support documents. The purpose of disclosure is to prevent scientific, budgetary, and commitment overlap and to ensure the integrity of the research enterprise.  This policy establishes roles, responsibilities, and procedures to safeguard the integrity of National Institute of Health (NIH) funded research and to ensure timely and accurate adherence to federal guidance.

2. Applicability

This policy applies to all Principal Investigators (PIs), key personnel, departmental research administrators, and central office staff involved in the management, oversight, and reporting of NIH-funded projects affected by NOT-25-133.

3. Definitions

Other Support: Any resources provided to an individual to support research endeavors, regardless of whether they have monetary value.
 
Senior/Key Personnel:  The Program Director/Principal Investigator and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically, these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition. Senior/key personnel must devote measurable effort to the project whether or not salaries or compensation are requested. "Zero percent" effort or "as needed" are not acceptable levels of involvement for those designated as Senior/Key Personnel.

4. Policy Guidelines

The NIH requires researchers to disclose all Other Support, including resources from both domestic and foreign entities. The institution is responsible for ensuring these disclosures are accurate and complete, while the individual investigator is responsible for disclosing their own information to the institution. Immediately notify Sponsored Projects Administration of undisclosed Other Support (i.e., information that was missing from a proposal.  Just-In-Time request or a Research Performance Progress Report.
 
The NIH notice mandates a written policy that includes the requirement of NIH recipients to provide training to all faculty and researchers identified as on the requirement to disclose all research activities and affiliations (active and pending) in Other Support.  This requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see ") in order to provide a comprehensive plan in the area of disclosure requirements for recipients.
 
4.1  Responsibilities
 
4.1.1  Principal Investigators (PIs)
      • Complete institutional training on Other Support disclosure and certification requirements annually;
      • Certify that Other Support submissions are accurate, current, and complete at the time of submission;
      • Promptly disclose new support, in-kind resources, or changes consistent with NIH expectations;
      • Maintain copies of certified Other Support documents in project records.
4.1.2  Senior/Key Personnel (as defined by NIH)         
      • Participate in required training and follow institutional standards for disclosure and certification of Other Support.
4.1.3  Institutional
      • Develop and deliver required training on Other Support, including examples of compliant disclosures and certification procedures;
      • Provide templates and system guidance to ensure consistency of reporting;
      • Monitor Other Support submissions for completeness and certification prior to institutional endorsement;
      • Maintain central records of all Other Support certifications;
      • Report systemic risks or repeated noncompliance to institutional leadership.
4.1.4  Training
  • Annual training on Other Support requirements is mandatory for all PIs and key personnel;
  • Training will cover definitions, required disclosures (including in-kind support), common errors, and certification responsibilities.
4.1.5  Certification
  • All Other Support documents must be appropriately electronically signed and dated by the PI or key personnel prior to submission;
  • Certifications affirm that the document is complete, accurate, and includes all required disclosures;
  • Central office will retain central copies.
4.1.6  Submission and Review
  • Administrators submit Other Support documents through Sponsored Projects Administration (SPA) for institutional endorsement;
  • SPA reviews for completeness, certification, and compliance with NIH standards;
  • Submissions lacking certification will not be processed.

5. Procedures

NIH regularly updates its standard instructions and sample document for Other Support. The NIH also updates a Disclosures Table that outlines what information must be disclosed and which section of the proposal is most appropriate for the disclosure.
 
5.1  Other Support Document Requirements
 
5.1.1  Use of SciENcv to generate Other Support.
 
5.1.2  Follow the format and instructions outlined in NIH Guidance.
 
5.1.3  Disclose ALL active and pending sources of Other Support, including:
      • Sponsored projects/proposals;
      • External consulting, when an investigator will be involved in the design, conduct, or reporting of research as part of the consulting activities (e.g., work that may result in publication in an academic journal, designing a protocol, data analysis, serving on a steering committee for a clinical trial);
      • In-kind (i.e., non-monetary) resources that meet all the following criteria:
        • Are uniquely available to the researcher;
        • Were provided by a non-USA entity (either domestic or foreign); 
        • Were provided in the past three years;
        • Are not being used on the proposed project;
        • Aside from the proposed project, are being actively used in support of any of an investigator’s other research endeavors;
        • Examples of In-kind resources include, but are not limited to:
          • Personnel (e.g., visiting scholars, visiting students, supported by a non-EU entity);
          • Space;
          • Equipment;
          • Materials;
          • Supplies.
        •  
        • Note: In-kind resources intended for use on the proposed project should be included as part of the 'Facilities and Other Resources' or 'Equipment' section of the application and not 'Other Support.'
      • Active/pending sponsored project total award amount.
    •  
      • Note: For subawards, only the total subaward amount needs to be included
      •  
    • 5.1.4  Flatten Other Support PDFs after signature.
5.1.5  Supporting documentation in the form of English-language versions of any Other Support from entities outside the United States, including, but not limited to:
      • contracts;
      • grants; 
      • any other agreements specific to appointments, affiliations, and/or employment with an institution or entity outside the U.S.
    •  
      • Note: Google translations, or similar, are acceptable but certified translations may be required upon request.
5.2  Training Requirements
 
The University has confirmed that a module on Research Security training meets the training requirements and aligns with broader federal mandates.  To complete the Research Security training that fulfills the requirements of NIH, NSF, and USDA:
    • Visit CITI Program;
    • Log in using your university credentials or create an account affiliated with the 海角视频;
    • Scroll to the bottom and Select “Add a Course”;
    • Under the “Other Courses” section, choose Research Security: A Basic Course;
    • Once completed, your training record will be automatically generated. The certification should be uploaded at the time of proposal submission (as required by NIH) to the applicable project in Cayuse for compliance and reporting.

6. Enforcement

Noncompliance with this policy, including failure to attend training or certify Other Support, may result in corrective action up to and including suspension of proposal submissions or spending authority on affected awards.  Proposals lacking the required certification(s) will not be submitted to the sponsor.

7. Related Documents

 
7.1  Related Regulations and/or Policies
 
7.2  Other Related Documents and/or Procedures
 
7.3  References