IU Implementation

IU Implementation of Other Support Requirements

In anticipation of NIH's January 25, 2022 deadline, IU has elected to implement key requirements early effective December 1, 2021.

PI Signature
Use of Forms G's format for Other Support & Biographical Sketch

Additional Information and resources can be found on NIH’s Other Support Page

Who is and is not required to report Other Support?

Reporting of Other Support is required for all individuals designated in an application as senior/key personnel—those devoting measurable effort to a project.
Information on Other Support is not specifically requested for individuals involved in Training Grants, including Program Directors, training faculty, and other individuals involved in the oversight of training grants.
Other Support is not required to be submitted for individuals categorized as Other Significant Contributors.

What must be reported as Other Support?

Other Support includes all financial resources whether or not funded through the University. Examples include:

Resources and/or financial support from all foreign and domestic entities, that are available to the researcher.
Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities. Non-research consulting activities are not Other Support.
In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source.

What is excluded from Other Support?

Other Support does not include:

Institutional resources
- Such as core facilities or shared equipment that are made broadly available and start-up packages
- These resources should be listed under Facilities and Other Resources.
Training awards
Prizes
Gifts
- Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return.
- Please note that an item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as such.
Endowed chair funds
Consulting activities where the PD/PI or other senior/key personnel is not conducting research (e.g. no authorship or co-authorship of publications is anticipated form the activity).

NIH Biographical Sketch Requirement Changes

Section A: May include details on ongoing and completed research (past three years). Note: This information was previously included in Section D.
Section B: Renamed “Positions, Scientific Appointments, and Honors” and should include:
- All positions, both domestic and foreign
- All scientific appointments (new requirement), both domestic and foreign
- All affiliations with foreign entities or governments
- All titled academic, professional, or institutional appointments whether or not renumeration is received
Section D: Research Support and/or Scholastic Performance’ has been removed, except for applications for fellowships, dissertation research grants (e.g. R36), and research supplements to promote diversity in health-related research from undergraduate through post-doctoral levels.

What is a Foreign Component?

A Foreign Component is defined as the existence of any "significant scientific element or segment of a project" outside of the United States.

Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/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 project staff (including visiting faculty, scientists, etc.) leave the country to return home due to COVID-19 and continue to work on the project, whether paid by the project or not, this could qualify as a foreign component and would require prior approval from the NIH IC.

For Postdoctoral scholars that are required to work on their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined this scenario does not constitute the performance of a significant element or segment or the project outside the US. Therefore, this is not considered a foreign component and does not require prior approval.

See: NIH NOT-OD-19-114, NIH COVID-19 FAQs

What are some examples of a "significant element of a project" when determining if a foreign component exists?

Evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. Consider and identify relationships, existing and potential, that may impact research integrity, financial conflict of interest, and/or overlap.

Some examples of activities that may be considered a significant element of the project include, but are not limited to:

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

Does a Foreign Component need to be included in Other Support?

The Foreign component should be part of the proposal, R&R Other Project Information Form, not the Other Support document. The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, as outlined in the NIHGPS, Section 8.1.2, Prior Approval Requirements. Principal Investigators should work with their OCGA Team to submit the prior approval request.

If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.

For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI's NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI's grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.

IU Implementation