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NIH Policies on Other Support, Foreign Components, and Financial Conflicts of Interest


Memo to MSU Principal Investigators and Key Personnel who have been named on proposals and/or awards to NIH

NIH issued a notice, NOT-OD-19-114, on July 10th as a reminder of their policies on Other Support, Foreign Components and Financial Conflicts of Interest.  Although the notice is written as a reminder, we believe there are changes to current practice and have highlighted some of the changes below. 

Other Support

NIH’s definition of Other Support is: “Includes all financial resources, whether Federal, non-Federal, commercial or organizational, available in direct support of an individual’s research endeavors, including, but not limited to, research grants, cooperative agreements, contracts, or organizational awards.”  The notice below deletes the word “financial” from the definition and indicates that the following items must also be included in Other Support:

  • Positions and scientific appointments that are relevant to an application, including affiliations with foreign entities or governments, regardless of whether or not remuneration is received.  This includes unpaid appointments that provide access to lab space, research materials, and staff.
  • Startup packages used for research endeavors.  NIH has indicated they plan to clarify that startup funding at the domestic applicant institution would not need to be included.
  • Consulting that is in “any way” related to a faculty member’s research endeavors, regardless of whether or not remuneration is received.
  • Research conducted during the summer semester for faculty members with an Academic Year appointment, regardless of whether or not remuneration is received.
  • Participation in a foreign “talents” or similar program.
  • High value resources (people, materials, equipment) for use on the project.

NIH has also changed the amount and effort that should be reflected on the Other Support form.  Rather than only including the current budget period, they indicate that the total award amount for the entire award period covered (including Facilities and Administrative costs), as well as the number of person-months per year to be devoted to the project, should be included.  For activities/resources that cannot be quantified, we are expecting additional guidance from NIH, but in the meantime, we would suggest reflecting N/A when “not applicable” and providing a related description, such as there is no cost associated with the activity/resource.

NIH has also stated that if an investigator is unsure of whether or not to include something on their Other Support document, to err on the side of disclosure.

We encourage you to read the full NIH Notice, NOT-OD-19-114, to keep apprised of NIH’s interpretation of their policies on Other Support, Foreign Components and Financial Conflicts of Interest.  They have also posted a list of FAQ’s that you may find helpful.  If you have questions on Other Support or Foreign Components, please contact your OSP Proposal Team.  If you have questions related to Financial Conflicts of Interest, please contact the COI office.

Twila Fisher Reighley, Asst. Vice President for Research and Innovation

Katie Cook, Director, Office of Sponsored Programs

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