Disclosing Activities to NIH

National Institutes of Health (NIH) requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards. NIH uses this information when making its funding decisions to determine if the research being proposed is receiving other sources of funding that could be duplicative, if the investigator(s) have the necessary time available to complete the research, or if financial interests may affect objectivity in the conduct of the research. Guidance for disclosing all sources of support is provided below. 

• Other Support instructions
• Other Support format
• Biosketch instructions
• Biosketch format
• NIH Disclosures

Where should the information be disclosed? Use the helpful table below.

Disclosing Activities as Other Support

NIH requires senior/key personnel to disclose all resources made available to them in support of or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of the performance site of the research. Even if the researcher performs the activity outside of the researcher’s UF appointment period (e.g., a nine-month faculty member conducts the activity during the summer months or as part of activities for a start-up company) or at a location other than UF, the researcher must disclose the activity. The required NIH Other Support format can be found here.

For Other Support submissions that include foreign activities and resources for which the investigator has an affiliation, appointment and/or employment with a foreign institution, investigators are required to attach all contracts, grants or other appointment agreements as supporting documentation. If the documents are not in English, investigators must also provide translated copies. This supporting documentation must be included with the Other Support forms and flattened into a single PDF.

When a PI or other senior/key personnel on an active NIH grant failed to disclose Other Support information in the Just-in-Time or the RPPR, as applicable, UF must submit updated Other Support to the NIH as soon as it becomes known. If you have an undisclosed international engagement, email ufproposals@ufl.edu immediately so that it is appropriately disclosed to NIH.

Examples of Other Support include, but are not limited to:

• Resources and/or financial support from all foreign and domestic entities that are available to the researcher. This includes but is not limited to:
  • Financial support for laboratory personnel (i.e. anyone working in your lab, including those who identify as “self-funded”)
  • Provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.)
• Consulting agreements, when the researcher 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 personnel (including students) supported by any entity other than UF. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the researcher must provide reasonable estimates.
• Note: Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.

NIH requires senior/key personnel to submit Other Support as part of the Just-in-Time procedures. All other support indicated above must be included in that process. Researchers are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award. Submission of JIT or any changes must be routed through DSP.

All Other Support submissions must be electronically signed by the person for whom the report is submitted. Any electronic signature must be affixed (physical signature scanned or affixed with digital writing device, Adobe signature, DocuSign, etc.) before the submission is flattened into a single PDF. An administrator pasting an image of signature onto the documents or signing on behalf of an investigator in any way is not allowed. After signing ensure the document has been flattened (see instructions).

After the initial NIH award, researchers must disclose changes in Other Support in the annual research performance progress report (RPPR). Additionally, any substantive changes must have prior approval. Email ufawards@ufl.edu if you identify any substantive changes.

Links:

• https://grants.nih.gov/grants/guide/notice-files/NOT-OD-21-073.html
• https://grants.nih.gov/grants/forms/othersupport.htm

Disclosing Activities in the Biosketch

Researchers must include all current positions, scientific appointments and affiliations in their Biosketch.

The NIH Forms-H guidance clarifies that within the ‘Positions, Scientific Appointments, and Honors’ section of the Biosketch, researchers must list in reverse chronological order all current positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes 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).

Disclosing Foreign Activities to NIH as Foreign Components

NIH defines “foreign component” as the performance of any significant scientific element or segment of a project outside of the U.S., either by UF (including any UF employee), by a subrecipient, or by a researcher employed by a foreign entity, whether or not grant funds are expended. There is a 2-part test for determining whether an activity meets the definition of foreign component: (1) whether a portion of the project will be conducted outside of the U.S. and (2) whether that portion of the project is significant. 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; or
• Receipt of financial support or resources from a foreign entity.

At the time of application submission, if there is an anticipated foreign component, researchers must check “yes” to question 6 on the “R&R Other Project Information” form, “Does this project involve activities outside of the United States or partnerships with international collaborators?” and include a “Foreign Justification” attachment in Field 12 “Other Attachments.” The Foreign Justification should describe the special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting. This information must match the information provided in the UFIRST Proposal on page 3.0.

If researchers want to add a foreign component to an ongoing NIH award, UF must receive prior approval before adding the foreign component. To seek prior approval, researchers must submit their request through UFIRST as an Award Modification and must include information to allow DSP to support the process identified in NIH GPS Section 8.1.2. Prior Approval Requirements.

For questions about disclosing international engagements to UF, please visit International Engagement and Collaborations.

Last updated 7/26/24