National Institutes of Health (NIH)
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
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.).
Inappropriate foreign influence
Incidents that violate core principles and threaten the integrity and academic competitiveness of U.S. biomedical research and innovation, including:
- failure to disclose all conflicts of interest, foreign affiliations, conflicts of commitment, and other support in applications for NIH grants;
- diversion of proprietary or pre-publication information disclosed in grant applications or produced by NIH-supported research to those not authorized to receive it; and
- breaches of confidentiality in peer review.
Disclosure requirement
Full transparency in NIH applications and throughout the life of an NIH grant is critical. NIH requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest.
Protecting U.S. Biomedical Intellectual Innovation
policy updates
NOT-OD-110: Implementation of Changes to the Biographical Sketch and Other Support Format Page
Resources
Additional Clarifications to Biosketch and Other Support Policies (by NIH Staff)
FAQs: Other Support and Foreign Components
Communications
Foreign Interference in National Institutes of Health Funding and Grant Making Process: A Summary of Findings from 2016-2021 posted July 30, 2021 by Dr Michael Lauer, NIH's Deputy Director for Extramural Research
Addressing Foreign Influence and Associated Risk to the Integrity of Biomedical Research, and How You Can Help posted July 8, 2020 by Dr. Michael Lauer, NIH's Deputy Director for Extramural Research
Letter from the NIH Director notifying the research community of threats to the integrity of U.S. biomedical research.