FAQs: NIH Other Support & Biosketches

Significant changes include a change in status of previously reported current or pending projects (for example, a pending project becomes active, a pending project is not funded, an active project has concluded, or a new project is pending). Significant changes also include new in-kind contributions, including new material or data being used to support the research endeavors of the PI or other senior/key personnel, as well as new resources associated with a current scientific appointment or a voluntary, adjunct, honorary, or visiting position. Significant changes also include new postdocs or visiting students who are self-funded working in your lab contributing to your research. See this FAQ for more information about visiting postdocs and students.

NIH has identified the following factors to consider regarding whether a particular activity or relationship creates compliance risk: 

A.  Does the relationship affect the integrity of the research by impacting established professional norms and ethical principles in the performance of all activities related to scientific research?

B.  Is there potential scientific, budgetary or commitment overlap?

C.  Is there a potential Financial Conflict of Interest?

See NIH’s “Important Applicant/Recipient Considerations”

PIs and other senior key personnel are encouraged to use DocuSign. For more information about DocuSign, see our resources and training materials here under “Columbia Materials to Assist You.”

NIH has clarified that only materials provided within the past 3 years, that are still in use, must be included in Other Support.

If this person will be self-funded, through their home institution or otherwise, you need to disclose them as an “in-kind contribution,” because they will be directly supporting your research endeavors.  You will need to include information about the source(s) of funding that may be supporting this person. However, if the relationship is solely a mentor/mentee arrangement, and this person is not supporting your research endeavors, then it is not a resource, and does not need to be reported. 

You must also follow all ISSO and other University requirements for academic visitors.  If the visitor has an affiliation with a restricted or other high-risk university, consult with the Director for Export Controls regarding possible additional compliance requirements.

It depends. 

A.  If they are working on the project being proposed, they should be disclosed in the Facilities & Other Resources section of the proposal. If they worked on an active NIH-funded project at least one person month during a reporting period, they should be included as “Participants” in section D.1 of the RPPR, regardless of the source of the compensation.

B.  If they are working on other projects in the lab, you should include them in Other Support. 

C.  If they are not contributing to your research at all, but they are simply observing, or working solely on their own projects, then you need not disclose them to NIH.

If the collaboration is “directly supporting your research endeavors,” it should be disclosed as “Other Support.”  That would be the case if, for example, it results in co-authored publications.

In addition, in some instances, such a collaboration could be considered a “foreign component,” if the collaborator is contributing a significant scientific element to an NIH-supported project from a non-U.S. location (see definition of foreign component).  In such cases, prior approval would be required. You should work with your SPA project officer on any prior approval requests.

It depends.  If the collaborations will directly support your research endeavors, you should disclose them in Other Support, under In-Kind Contributions.  This would be the case if, for example, you would include your collaborator as a coauthor on a publication or as an investigator on a sponsored project.  Similarly, if the collaboration involves provision of high-value materials, it should be disclosed like any other In-Kind Contribution.

If the collaborations do not directly support your research endeavors, then they do not need to be disclosed in Other Support.

Prizes are typically awarded to an individual to recognize their overall accomplishments or achievements, and the funds are completely unrestricted. They also typically do not require any reporting or acknowledgement in publications.  In contrast, a sponsored project has defined aims and objectives, and the funding must be expended in accordance with the project’s scope. If you have a question about whether a particular item can be excluded as a prize, please contact your SPA project officer.

You should disclose clinical trials in the same way as other projects. See also Columbia Effort Reporting FAQ No. 28 in the Total University Effort section.

Consulting roles that involve the design, conduct or reporting of research  may be considered to involve the “conduct of research.”  These would include, for example, consulting roles that warrant co-authorship or result in joint publications.  On the other hand, if the engagement is purely advisory, it should not be disclosed as Other Support.

Consulting is typically an outside activity that is not part of an individual’s Total University Effort and does not require an effort commitment.  For this reason,

NIH has stated that, “Consulting should be estimates for the amount paid, rather than time and effort reflected in calendar months. Therefore, it will not count towards the 12 calendar months of effort.”  However, as is always the case with respect to outside activities, you must ensure that any consulting engagement meets the University’s conflict of commitment requirements. See Columbia University’s policy on Outside Interests and Employment.  

These agreements need to be uploaded to Rascal for parallel compliance review:

• Contracts or other written agreements specific to an appointment with a non-U.S. entity.
• Contracts or other written agreements specific to employment by a non-U.S. entity.
• Research grants held directly through a non-U.S. entity (not through a subaward issued to Columbia)

These documents are required only for current, active appointments and/or employment with a non-U.S. entity.  Do not include agreements that are pending or not finalized.

Senior/key personnel on NIH proposals must upload required agreements to Rascal no later than the time at which they are required to provide this documentation to Sponsored Projects Administration for submission to NIH.

Submission at an earlier date will allow for more time for parallel compliance review to take place.

Go to https://www.rascal.columbia.edu/coi and select Upload Non-US Agreements from NIH Other Support for Parallel Compliance Review.

No. This requirement does not cover agreements to which Columbia is a party.

Yes. See FAQ #2 above, What types of agreements need to be uploaded to Rascal?.

If the original agreement is not in English, you must upload both the original document and an English translation. This requirement tracks NIH’s requirement for translated documents to be provided with Other Support.

You can provide machine-read translations of foreign contracts, grants, or agreements. (“Machine-read” includes the use of products such as Google Translate or Microsoft Translate.)

No. Senior/key personnel need only upload such agreements to Rascal one time in the lifetime of the agreement, but must upload any and all renewals or amendments.

If the term of an agreement has expired, or if you are trying to terminate an agreement, you are encouraged to confirm this in writing.

Yes, though this could change if other funders change their submission requirements.

ADDED 1/25/2022 - Yes, domestic and foreign subrecipients are subject to the same supporting documentation requirements for appointments or affiliations disclosed in the subrecipient investigators’ Other Support documents. The supporting documentation should accompany the subrecipient’s Other Support forms, and be included in the flattened PDF provided to SPA. If the supporting documentation is not in English, the subrecipient is responsible for providing translated copies. The supporting documentation provided by subrecipients, or other external collaborators, do not need to be uploaded in the COI module of Rascal, unlike the requirement for Columbia employees.

Yes, all subrecipient principal investigators and other senior/key personnel must electronically sign their Other Support forms, prior to their inclusion in the flattened PDF, certifying that the information is accurate and complete. Only electronic signatures will be accepted. SPA will accept any form of electronic signature from a subrecipient. Wet signatures, typed signatures, and pictures of signatures will not be accepted. Subrecipients must maintain supporting documentation to reasonably authenticate that the appropriate individual signed the form. Subrecipients must make the documentation available to SPA upon request.

Yes, when requesting Other Support materials from subrecipients, it is suggested that you communicate the following:

Suggested Text

Please provide updated NIH Other Support forms for each PI and senior key personnel. Other Support must adhere to the NIH Other Support policies and instructions. Each Other Support form must be certified by the PI and other senior key personnel using an electronic signature method that is in alignment with your institution’s practices and NIH requirements, and must include supporting documentation, which includes copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support, translated in English, as applicable. Subrecipients must maintain supporting documentation to reasonably authenticate that the appropriate individual signed the form. Subrecipients must make the documentation available to Columbia upon request.

Per NIH’s FAQs, ‘Failure to follow the appropriate formats on or after January 25, 2022 may cause NIH to withdraw applications from or delay consideration of funding.’ As a reminder, subrecipients must provide immediate notification of undisclosed Other Support to Columbia. If you discover that a PI or other Senior/Key personnel on this NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, submit updated Other Support to Columbia as soon as possible.