effective 1/25/22

• Updated  forms are required for Biosketches, Other Support, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs).  
• Copies of contracts, grants or any other agreement involving a foreign appointment and/or employment with a foreign institution included as Other Support. must be submitted as "supporting documentation". 

Disclosure Guidance 

NIH Policy & Compliance Overview: Protecting U.S. Biomedical Intellectual Innovation 

Examples of What to Disclose to NIH about Senior/Key Personnel on Applications and Awards  

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

NIH Chart: NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support

The below chart is for educational purposes, NIH strongly encourages use of their chart.

What to Disclose	Where to Disclose	When to Disclose
Outside appointments, both paid and unpaid.	Biosketch	Proposal, JIT Request*, RPPR*
International collaborations with activities performed at locations outside of the U.S. whether or not grant funds are expended.	Foreign Component	Proposal, JIT Request, or Prior approval for existing projects
All resources available to the researcher or key personnel in support of and/or related to all research endeavors, regardless of monetary value or location of resource.	Other Support	Proposal, JIT Request, RPPR
International visiting scholars, students or collaborators in your facilities (including labs) that support your research (not key personnel)	Other Support	Proposal, JIT Request, RPPR

*  JIT Request means "Just in Time Request". RPPR means "Research Performance Progress Report."

Key Definitions

Foreign Component 

NIH(  NOT-OD-19-114 ) defines a foreign component as:

The existence of any “significant scientific element or segment of a project” outside of the United States, in other words:

1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
2. performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

"Significant scientific element or segment of a project"

According to the    NIH:

Activities that would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. Examples of other grant-related activities that may be significant are:

• collaborations with investigators at a foreign site anticipated to result in co-authorship;
• use of facilities or instrumentation at a foreign site; or
• receipt of financial support or resources from a foreign entity.

Foreign travel for consultation is not considered a foreign component.

Other Support 

Also known as "current and pending" or "active and pending" support.    

NIH (  NOT-OD-19-114) defines other support as: 

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 resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).