NIH Other Support FAQs
What recent changes has NIH made to the Other Support format?
NIH has updated the format and instructions for the Other Support and Biographical Sketch pages to facilitate full disclosure of existing requirements. Requirements were clarified in the 2019 notice NOT-OD-19-114, which included disclosure of in-kind and foreign support, including support provided directly to the individual PI/key personnel (not to the institution). Details on the format changes can be found on NIH’s Other Support webpage and in the March 2021 notice NOT-OD-21-073.
What is the effective date for the new Other Support format?
The new format is required for application due dates, JIT, and RPPR submissions on or after January 25, 2022, and can be used for submissions prior to that date. The disclosure requirements detailed in NOT-OD-19-114 continue to apply regardless of whether the current or revised formats are used.
Are there additional documentation requirements with the revised format and instructions for the Other Support page?
Yes. Beginning January 25, 2022, all principal investigators and other senior/key personnel are required to electronically sign the Other Support document, prior to its submission to NIH, certifying that the information is accurate and complete. NIH and SciENcv are currently developing an Other Support template, estimated to be rolled out, at the earliest, in 2022. When NIH transitions to the use of SciENcv to generate Other Support, the signature/certification will be integrated into that process.
The revised formats require documentation of Person Months (Calendar/Academic/Summer) per budget period for each source of support listed, as well as for in-kind support, as applicable. In-kind support is included as a separate section on the Other Support form.
If other support submissions include foreign activities and resources, recipients will be required to submit copies of contracts, grants, and any other agreement specific to senior/key personnel foreign appointments, affiliations, and/or employment with a foreign institution. The supporting copies must be included with the Other Support submission to NIH beginning January 25, 2022, but also must be made available upon request beginning May 25, 2021. Penn is operationalizing this as follows:
- Foreign contracts and agreements to the PD/PI or key personnel in their individual capacity that are included in Other Support should be submitted to Penn’s Office of Research Services (ORS) with the Other Support/RPPR document.
- Penn/ORS will assist with document translation as needed and will submit the forms to NIH if requested by the agency.
- When Penn is the subawardee, please submit Other Support documents to ORS for preview prior to sharing them with the prime sponsor.
What should be disclosed in Other Support?
NIH has indicated in NOT-OD-19-114 and other resources that 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 location, including but not limited to:
- Resources and financial support from all foreign and domestic entities available to the researcher irrespective of whether provided through the applicant organization, another domestic or foreign organization, or directly to an individual.
- In-kind contributions, e.g., office/lab space, equipment, supplies, or employees or students supported by an outside source. Time and/or dollar value, or a reasonable estimate, is required.
- Includes provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, or technology).
- Note: If intended for use on the project being proposed, include as part of the Facilities and Other Resources or Equipment section and not in Other Support.
- Includes provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, or technology).
- Consulting agreements when conducting research as part of the consulting.
- Includes consulting during summer months for 9-month appointments.
- Anticipated co-authorship or joint publication is a useful indicator that the activity should be disclosed as Other Support.
Should start-up support provided by the applicant organization be included in Other Support?
Start-up packages provided by Penn should not be included in Other Support. Start-up packages from outside organizations, including foreign entities, must be included in Other Support.
Should gifts be reported in Other Support?
No, gifts should not be reported in Other Support. Gifts are resources provided where there is no expectation of anything (e.g., time, services, specific research activities, money, etc.) in return. If a gift was provided to Penn for a specific research activity or there is an expectation of an associated time commitment, it must be reported in Other Support.
Should training grants or prizes be included in other support?
No, training grants and prizes are not required to be disclosed in Other Support.
Should core facilities or shared equipment be included in Other Support?
No. Other Support includes resources uniquely available to the researcher and does not include institutional resources that are made broadly available to faculty and staff.
What should I do if I am not sure if something needs to be included as Other Support?
In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies.
What should I do if I realize that a resource was not included/reported in Just-in-Time or the Research Performance Progress Report?
Notify the appropriate school/department and/or Proposal and Award Management team contact within Penn’s Office of Research Services. They will work with you to submit updated Other Support information to NIH.
Outside Appointments, Consulting, and Collaborations
What outside/consulting activities should I report in Other Support?
When research will be conducted as part of consulting activities that fall outside of an individual’s institutional appointment, it must be reported as Other Support. Consulting roles that involve the design, conduct, or reporting of research may be considered to involve the “conduct of research.” Anticipated co-authorship or joint publication is a useful indicator that the activity should be disclosed as Other Support.
Foreign-sponsored talent recruitment program participation or paid research should be disclosed. National Security Presidential Memorandum-33, on U.S. Government-Supported Research and Development National Security Policy, defines “foreign government-sponsored talent recruitment programs” as “an effort directly or indirectly organized, managed, or funded by a foreign government or institution to recruit S&T professionals or students.”
Consulting or professional service arrangements that do not involve research or are purely advisory, do not need to be reported. Consulting engagements that are relevant to a researcher’s professional expertise should be included in the biosketch under Scientific Appointments.
If I have an unpaid (or paid) appointment at a foreign university with access to lab space, research materials, and staff, should it be reported as Other Support?
Yes. Even when not receiving monetary compensation, the lab space, materials, and staff are resources made available and/or related to your research efforts. Other payments, such as travel or living expenses associated with this appointment must also be reported.
Joint or dual appointments under formal agreements with Penn that include lab or other research space and resources (e.g., CHOP) are institutional resources and do not need to be listed in Other Support. Office/lab space provided to a researcher in support of or related to their research that is not due to a formal joint or dual appointment with Penn should be listed as Other Support.
If I have a 9-month appointment and spend two months at a foreign university during the summer conducting research under a foreign award, should this be reported as Other Support?
Yes, as it involves the conduct of research and supports and/or relates to your research endeavors.
Should service on advisory committees or boards, such as data safety monitoring committees or scientific advisory boards, be included in Other Support?
Service on advisory committees and boards does not need to be disclosed as Other Support unless it involves the conduct of research (e.g., writing protocols or analyzing data). It should be included as a “Scientific Appointment” on the Biosketch.
If key personnel on an NIH grant in the U.S. are collaborating with another scientist in the U.S. whose experiments, conducted with funds awarded to their institution, have directly benefitted their research, should this be reported as Other Support? What about collaborations with a former graduate student/postdoc or other researcher with their own lab at a non-U.S. university?
Yes. Other Support includes domestic and foreign research collaborations that directly benefit an individual’s research endeavors. Anticipated co-authorship or joint publication is a useful indicator that the activity should be disclosed as Other Support.
If the collaborator is contributing a significant scientific element to an NIH-supported project from a non-U.S. location it could be considered a “foreign component.” In such cases, prior approval would be required. Departmental or ORS staff can assist with prior approval requests. A foreign component is the performance of a significant scientific element of the NIH-supported project outside of the United States. Examples of activities that may be considered a significant element of the project include:
- collaborations 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
I have a number of long-standing collaborations with foreign scientists and entities. Do I need to be concerned about these collaborative research efforts?
NIH and other U.S. research funding agencies have indicated their continued and strong support for collaborative research efforts, both domestic and foreign. Agencies are seeking disclosure of collaborations consistent with biosketch, other support, and FCOI requirements, as applicable, to allow for appropriate funding decisions and grants management (e.g., to identify any scientific, budgetary, or commitment overlap; ensure sufficient levels of effort are committed to the project; and identify potential conflicts of interest).
Do I need to include internal Penn awards in Other Support?
Yes, internal awards need to be included in Other Support. However, discretionary or research funds provided by Penn as part of an academic appointment (e.g., named professorship) do not need to be disclosed as other support.
Should consulting activities included in Other Support display calendar months effort, or is N/A appropriate for effort, when serving as a consultant?
Consulting should include estimates for the amount paid or to be paid, rather than time and effort reflected in calendar months. Therefore, it will not count towards the 12 calendar months of effort.
Do in-kind contributions that will be used for the project being proposed need to be included in Other Support?
If the in-kind contribution is intended for use on the project being proposed, the information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated in Other Support. If an in-kind contribution is not intended for use on the project being proposed, then the information must be included as part of Other Support.
If I have an exchange student, post-doc, or visiting scholar working on research activities in my lab who is paid a salary by their home university in a foreign country, does that need to be included in Other Support?
Yes, since they are performing research activities, their work in the lab is a resource available in support of the PD/PI or other senior/key personnel’s research endeavors and must be reported as an in-kind contribution in Other Support.
A student working for class credit, including those on a student visa, is not considered in-kind support. This would be considered institutional support and therefore not reportable as Other Support. Students supported by an NIH T32 and working on an R01 with, or under the direction of, the PI or senior/key personnel are not considered Other Support.
If I am mentoring a post-doc or graduate student who is individually funded through an outside institution (e.g., foundation, home university or federal agency), does that need to be disclosed as an in-kind resource in Other Support?
If the relationship is solely a mentor/mentee arrangement, with no research activities, then it is not a resource and does not need to be reported. If the post-doc or graduate student is performing research activities in support of the PD/PI or other senior/key personnel’s research endeavors, then their support must be reported as an in-kind resource.
How should I list materials (e.g., data, samples, etc.) received from external collaborators in Other Support?
Information on materials received from collaborators that support an investigator’s research should include the source, a summary of the in-kind contribution, and the estimated value. Only resources uniquely available to the researcher (e.g., not widely or commercially available) must be reported.
How should I value tissue samples, cell lines, animal models, and other materials as an in-kind contribution toward my research endeavors?
Researchers should strive to estimate the value based on the cost of comparable materials. If there is no comparable information, indicate that there is “no market value available.”
For in-kind resources that do not have associated effort, can zero effort be entered?
Yes, for in-kind resources with no associated time commitment, researchers can list zero effort, but must provide the estimated dollar value of the in-kind resource. The effort and dollar value cannot both be zero.
Does completed in-kind support need to be included in Other Support?
No, only active and pending in-kind support must be included.
When disclosing materials received from external collaborators on Other Support how far back in time should I go? Should materials provided 20 years ago be disclosed, if they are still in use?
Materials provided within the past 3 years, that are still in use, must be included in Other Support.
Do I need to disclose unpaid volunteers working in my lab as Other Support?
Unpaid volunteers need to be disclosed if they serve as a resource available in support of an individual’s research endeavors.
Should the Other Support documents include annual total cost or only annual direct cost?
Other Support submissions should provide the total award amount, direct and indirect, for the entire project period, not just the annual budget period, as indicated in NOT-OD-19-114.
When providing the total award amount for an NIH funded grant project, should the researcher provide what was requested in the initial application, or the amount of funding listed on the current Notice of Award?
Researchers should list the total award amount, direct and indirect, for the entire project period, based on the most recent Notice of Award.
When a researcher works on a subaward to an NIH grant that is awarded to another institution, how should that information be included in Other Support?
The researcher should provide the project number and PD/PI name for the prime award. All other information, including the total award amount and person months, should be specific to the subaward.
I have a non-U.S. subrecipient for a project. How should the non-U.S. investigators report Other Support? Do they need to disclose their employment agreements with the subaward recipient institution?
The non-U.S. investigators must follow the same rules as U.S. investigators. They do not need to disclose their employment agreements with the subaward recipient institution, but they must disclose any Other Support, including any appointments with additional entities that involve research or access to resources for research endeavors.