Federal funding agencies, particularly the National Institutes of Health (NIH), require researchers to disclose all sources of support for their research activities. This is crucial for ensuring proper time commitment from principal investigators (PIs) and avoiding duplicate funding. Recent concerns about foreign influence have led to increased scrutiny and evolving requirements from federal agencies, making it essential for researchers to stay informed.

The Sponsored Projects Administration (SPA) plays a vital role in guiding researchers through these complex NIH guidelines. SPA provides resources and updates to help PIs and key personnel understand and meet their disclosure obligations regarding other support and potential foreign components in their research.

Understanding NIH “Other Support” Requirements

NIH defines “Other Support” broadly as all resources available to a researcher in support of their research endeavors, regardless of monetary value or location. This includes resources from external entities and even internal university sources in some cases.

Researchers must report detailed information for each activity considered “Other Support,” including:

• Project number
• Principal Investigator
• Source of support
• Project title
• Project dates
• Person months devoted
• Award amount

For in-kind contributions or situations where precise information is unavailable, NIH guidance advises investigators to provide their best estimates. SPA emphasizes the importance of diligent reporting and offers support to researchers navigating these estimations.

Who is Required to Report?

Reporting requirements extend beyond just the Principal Investigator. The following individuals must disclose “Other Support”:

• Principal Investigator (PI)
• All senior/key personnel (excluding Other Significant Contributors and certain training grant roles)
• Anyone contributing substantively and measurably to the scientific development or execution of the project

SPA clarifies these categories for researchers, ensuring all relevant personnel are aware of their reporting responsibilities.

When to Report “Other Support”

Disclosure is required at various stages of the grant lifecycle:

• Just-in-Time (JIT): Upon NIH request after proposal submission.
• Post-JIT, Pre-Award: If substantive changes occur after JIT but before award receipt.
• Prior Approval Requests: For substantive changes during the award period before the next Research Performance Progress Report (RPPR).
• RPPR (Annual): To report changes annually.
• Upon NIH Request: At any time if requested by NIH.

SPA assists researchers in determining what constitutes a “substantive” change and when reporting is necessary, ensuring proactive compliance.

What to Include and Exclude in “Other Support”

Items to Include:

• All proposals under consideration, ongoing projects (internal and external).
• Start-up packages, research support from non-University entities (including travel, living expenses, facilities).
• High-value materials/equipment from third parties.
• Research-related consulting activities.
• Summer research support for academic year faculty.
• Participation in foreign government “talents” programs.
• Financial support for research-related lab personnel or visitors.

Items to Exclude:

• Non-research related activities (teaching, clinical care payments).
• Support for lab personnel working independently of the reporting investigator’s research.
• University of Minnesota start-up, cost-sharing, or general lab support (some internal research grants are reportable).
• Consulting unrelated to the researcher’s own research endeavors.
• Gift funding without specific research obligations.
• Training grants where the investigator is a mentor.
• Prizes and personal royalty income.

SPA provides ongoing clarification and interpretation of these inclusion and exclusion criteria, helping researchers make accurate disclosures.

Biosketch Requirements

In addition to “Other Support,” researchers must also disclose certain information in their Biosketch:

• All positions and scientific appointments, domestic and foreign, relevant to the application.
• Affiliations with non-U.S. entities or governments, regardless of remuneration.
• Unpaid appointments providing access to research resources.

SPA emphasizes the importance of a comprehensive Biosketch that accurately reflects all relevant professional engagements.

Foreign Components and Prior Approval

Any “foreign component” of research requires prior NIH approval. A foreign component is defined as a significant scientific element or segment of a project conducted outside the United States. This includes:

1. Work performed by a researcher or recipient in a foreign location.
2. Work performed by a researcher in a foreign location employed or paid by a foreign organization.

Significant activities related to foreign components include:

• Collaborations with foreign investigators leading to co-authorship.
• Use of foreign facilities or instrumentation.
• Receipt of financial support from a foreign entity.

SPA guides researchers in determining whether their research involves a foreign component and assists with the prior approval process when necessary.

SPA’s proactive guidance and support are crucial for researchers navigating the complexities of NIH foreign influence disclosure requirements. By staying informed and utilizing SPA resources, researchers can ensure compliance and maintain the integrity of their research endeavors.