NIH Guidance

Last updated 12-8-2020

The National Institutes of Health (NIH) issued notice NOT-OD-19-114 on July 10, 2019 as well as FAQ that are intermittently updated, reminding research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.” 

Please take your time to review the notice and the FAQ in their entirety to ensure compliance in your NIH submissions.   Of particular interest in the above resources, the NIH clarified the definitions of “Other Support” and “Foreign Component,” as well as the information that should be included in a Biosketch. 

Researchers and research administrators should discuss any questions regarding disclosure requirements with their ORPA representative.

BioSketch

Biosketches should list all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application.  This includes:

  • affiliations with foreign entities or governments and 
  • 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.)
Other Support

NIH defines “Other Support” or “current and pending support” or “active and pending support” as information relating to other active and pending support that is requested by the NIH as part of the Just-in-Time procedures for grant applications or in progress reports.  The NIH uses this information to ensure there is no scientific, budgetary, or commitment overlap. 

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.” Resources that may be considered Other Support include, but are not limited to:

  • Grants or contracts from federal or government agencies;
  • Grants or contracts from corporate, nongovernment or foreign entities;
  • Grants or contracts through other institutions, including institutions in foreign countries;
  • In-kind lab space, office space, scientific materials; and
  • Personnel/staff supported by sources other than the project being proposed.

Other support should be disclosed when requested at "Just-in-Time" and updated in the annual Research Performance Progress Report (RPPR).

Foreign Component

A Foreign Component, according to the NIH Grants Policy Statement,  is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”

Activities that would meet the definition of foreign component include, but are not limited to:

  • Human or animal research conducted overseas;
  • Extensive foreign travel for data collection, surveying, sampling, and similar activities;
  • Collaborations with investigators at a foreign site 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; or 
  • Any activity that may have an impact on U.S. foreign policy.

There are multiple ways in which foreign components should be disclosed, including: 

  • Identifying a foreign component in an NIH grant application;
  • Listing a non-U.S. performance site (e.g., a foreign consultant or subawardee);
  • Listing foreign professional appointments, relationships and activities in a biosketch;
  • Answering “yes” to the question on the R&R Other Project Information Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”; and
  • Describing each foreign component separately in Section G.9 of the annual Research Performance Progress Report.

Principal Investigators (PIs) and research administrators should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If an omission or error in a previously submitted proposal is identified, the PI should contact their departmental grants administrator and their ORPA representative for assistance in correcting the error.