NIH Other Support

NIH requests Other Support for:

• All individuals designated in an application as senior/key personnel devoting measurable effort on the project.
• All senior/key personnel, excluding consultants, in progress reports (RPPR) when there has been a change in active other support.
• Not required to submit Other Support:
  • program directors, training faculty, and other individuals involved in the oversight of training grants.
  • individuals categorized as Other Significant Contributors.

Other Support is typically requested at the Just-in-Time (JIT) stage as well at the time of the RPPR.

Other Support must include the following. See “resources to report” for further clarification.

• Active support
• Pending support
• In-kind support
• Foreign appointments and contract documentation (subject to NIH criteria)
• Investigator signature
• Completed or inactive support is no longer required as part of Other Support.

Information about each support item includes:

Project number
Contact Principal Investigator
Source of support
Title of project/subproject
Dates of approved/proposed project
Total award amount for the entire award period covered (including facilities and administrative costs)
Person months per year
Indication of whether the listed award overlaps with proposed project

From the NIH Other Support FAQ:

1. Do in-kind contributions that will be used for the project being proposed need to be included in Other Support?
   If an in-kind contribution, such as technology, chemicals, etc. is intended for use on the project being proposed to NIH in the application, the information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated on Other Support.
2. If an in-kind contribution is listed in Facilities and Other Resources or Equipment, does it also need to be included in both Other Support?
   If an in-kind contribution is not intended for use on the project being proposed, then the information must be included as part of Other Support. If the in-kind contribution is intended for use on the project being proposed, then information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated on Other Support.

Overlap of support is other support duplicating research or budgetary items already funded by an NIH grant. Overlap also occurs when any project-supported personnel has time commitments exceeding 12 person months.

• Scientific Overlap is when substantially similar research is proposed in more than one concurrent PHS grant application.
• Budgetary Overlap indicates other support duplicating budgetary items already funded by an NIH grant.
• Commitment Overlap occurs when any project-supported personnel has time commitments exceeding 12 person months, regardless of how the effort is being supported or funded.

Resources

• How to Address Overlap in Other Support -WU OVCR
• NIH Glossary: Overlap of Support, Scientific Overlap

A foreign component is the existence of any “significant scientific element or segment of a project” outside of the United States, in other words:

• 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.

For NIH, when a segment of the research is performed outside of the U.S., the following activities would constitute a foreign collaboration that must be disclosed as a foreign component:

• Research involving human subjects or animals.
• Extensive travel for the purpose of data collection, surveying, sampling, and similar activities (excluding foreign travel for consulting).
• Collaborations with investigators anticipated to result in co-authorship.
• Use of facilities or instrumentation.
• Receipt of financial support or resources from a foreign entity.
• Any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.

Example A: 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.

Lab personnel who are trapped outside the U.S. due to COVID-19 but are working on your research remotely, whether or not paid by the project, may qualify as a foreign component and needs prior approval.

NIH has determined that postdocs who 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, does not represent the performance of a significant scientific element or segment of the project outside the US, as outlined in the NIH Grants Policy Statement definition of a foreign component. (NIH FAQs on COVID-19).

For more about what constitutes a foreign component, see the NIH Grants Policy Statement and NIH NOT-OD-19-114 and NIH FAQs on COVID-19.

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 requires NIH prior approval, as outlined in the NIH Grants Policy Statement, Section 8.1.2 , Prior Approval Requirements. Work with your department administrator 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 the activity includes a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.

Example A-2: 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.

References: UCSF Office of Sponsored Research, the NIH Grants Policy Statement, NIH FAQs on COVID-19.