On July 10, 2019, NIH issued NOT-OD-19-114 to provide clarification to the NIH grantee community on what should be reported in Other Support submissions, as well as what would be considered a foreign component on an NIH grant. NIH reminded the grantee community that they consider this a clarification of existing policy rather than an implementation of a new policy.
Other Support
This NIH Notice reiterates the NIH Grants Policy Statement Section 2.5.1, which states that other support includes all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual’s research endeavors, including, but not limited to, research grants, cooperative agreements, contracts, and/or institutional awards to ensure no scientific, budgetary or commitment overlap.
NIH further reminded applicants and grantees 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 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.).”
NIH reminded applicants that, at the time of proposal, the applicant must list “all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application 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).”
Additionally, at the “Just-in-Time” stage, applicants must report:
- “all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts.; and
- “all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.”
For these projects, applicants must provide the total award amount, as well as the number of person-months per year to be devoted to the project. Additionally, if there are any changes between the time of initial submission of other support information and the time of award, those changes must be promptly disclosed to NIH. Changes to Other Support which occur during an active award must be reported annually through the RPPR. For resources that do not easily fit into the format traditionally used to provide Other Support information, detailed information should be included in the closest format possible; if certain request data points are not applicable, simply indicate “N/A” on the Other Support document. The important thing is that the resource is disclosed to the agency.
Foreign Component
NIH also issued an explicit reminder that recipients must determine whether the activities supported by a grant include a foreign component and clarified what constitutes a foreign component. A foreign component is present when there is the existence of any “significant scientific element or segment of a project” outside of the U.S. This means either the performance of work by a researcher or recipient in a foreign location (whether or not NIH grant funds are expended), or 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).
If a portion of the project will be conducted outside of the U.S., recipients will then need to determine if the activities are considered significant. If the activities which will be conducted outside of the U.S. are considered significant, then the project includes a foreign component. This determination is not dependent on whether the foreign collaborator receives funding from the NIH grant in question. Thus, if the two criteria are met, the grant has a foreign component whether or not the foreign collaborator receives funds from the NIH grant.
NIH did clarify that in the case where all research is being conducted in the U.S and involves a researcher or other project team member who has support from a foreign source, the grant does not include a foreign component. However, this non-U.S. based resource must be reported as Other Support.
NIH has also published a website with Frequently Asked Questions. This FAQ can be found at: https://grants.nih.gov/grants/faq-other-support-foreign-components.htm.
These FAQs include important additional information about what should be included in Other Support documents, including start-up packages for investigators and institutional research grants. NIH also offers int the FAQs examples of what would be considered a “significant element of a project” when making determinations regarding foreign components.
OSP strongly recommends that all investigators and research administrators read both NOT-OD-19-114 and the associated FAQs in full.