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Disclosure of Other Support Policy

Adopted 9/10/2025

Policy Purpose and Scope

To ensure compliance with requirements from the National Institutes of Health (NIH), any researcher designated as Senior/Key Personnel on NIH‑funded grants must disclose all “Other Support”; meaning all resources, financial or non‑financial, provided to the individual in support of or related to all their research activities; regardless of monetary value, institutional origin, or current institution affiliation.

Aligned with NIH Notice , effective October 1, 2025, the University must establish and enforce a policy and training protocol ensuring Senior/Key Personnel fully understand their disclosure responsibilities.

Policy

This policy applies to:

  • All NIH grant applications, Just‑In‑Time (JIT) submissions, Research Performance Progress Reports (RPPRs), and other institutional milestones where Other Support disclosure is required.
  • All individuals classified as Senior/Key Personnel per NIH definitions.

Definitions

Senior/Key Personnel: 

The program director/principal investigator (PD/PI) and 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.

Other Support:

Also referred to as “current and pending support,” it comprises all resources made available to the researcher that support or relate to all their research endeavors. Irrespective of source (e.g., foreign, domestic), institutional affiliation, or monetary value, other support includes, but is not limited to, financial support, materials, personnel support, or foreign or domestic resources. 

Training: 

Mandated by NIH NOT‑OD‑25‑133, institutions are required to deliver training to all Senior/Key Personnel regarding Other Support disclosure duties.

Supporting Documentation:

Includes contracts or agreement copies for foreign appointments or employment, translated into English.

Requirements

The University will provide and require training for all Senior/Key Personnel on the institutional Other Support disclosure policy and NIH requirements. The multimodal training via a Research Security Training course in CITI will cover the principles of research security and Other Support disclosure, and will include:

  • A clear explanation of what qualifies as Other Support.
  • Instructions on transparency and timely updating mechanisms.
  • Procedures for reporting undisclosed Other Support.
  • Guidance on supporting documentation (e.g., translation of foreign agreements).

Institutional Other Support Disclosure and Training Requirements

At Time of Application:

Senior/Key Personnel must submit Other Support information using NIH’s current format pages, covering all active and pending support. Senior/Key Personnel must also complete the Research Security Training course in CITI which covers the principles of research security and Other Support disclosure.

At Time of Award:

Senior/Key Personnel must submit updated Other Support information using NIH’s current format pages, covering all active and pending support.

At RPPR Stage:

If there’s a change in active Other Support since the last reporting period for any Senior/Key Personnel, updated Other Support information must be submitted with the RPPR.

Late or Undisclosed Support:

If the University later identifies previously undisclosed Other Support by a Senior/Key Person on an active NIH grant, the updated Other Support must be submitted immediately to the assigned NIH Grants Management Specialist.

Supporting Documentation for Foreign Relationships

For any foreign appointments or affiliations disclosed as Other Support, copies of relevant contracts or agreements must be included. Non-English documents must be accompanied by translated copies.

Compliance Monitoring & Non-Compliance

Compliance with this policy will be monitored by the Office of Research and Innovation through maintenance of training records, and review at time of application and time of award. Non-compliance may result in delayed proposals, denial of proposal submission, institutional notification to NIH, or disciplinary measures as outlined in the University Policy Library. [v] Requirements for institutional notification to NIH are delineated in NOT-OD-21-073.

Related Policies

The terms of this Policy are not intended to replace other University policies or applicable laws and regulations. Researchers listed as Senior/Key Personnel must complete training in the appropriate disclosure of other support as outlined by the National Institutes of Health.

NOT-OD-25-133: NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements

Other Support | NIH Grants & Funding

Other Support and Foreign Components Frequently Asked Questions (FAQs) | NIH Grants & Funding

Research Security Training (Combined) | CITI Program

[v] Procedures for Disciplinary Action | Policy Library | 91做厙

NOT-OD-21-073: Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021