We write to remind you of three important NIH requirements: (1) disclosure of “Other Support;” (2) prior approval for “Foreign Components;” and (3) disclosure to Columbia of all Financial Interests related to your institutional responsibilities, including honoraria or other compensation and sponsored travel provided by non-U.S. institutions of higher education.
The following is NIH’s definition of Other Support, as clarified in the recently updated NIH Grants Policy Statement (GPS) for FY 2020:
- “Other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”
- “This includes resources and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.)”
(GPS Sec. 2.5.1, emphasis added)
We expect additional guidance regarding Other Support requirements in the next few months. However, please note that NIH is paying particular attention to appointments and affiliations at entities other than the applicant institution, even where unpaid or honorary, and especially when such an affiliation is listed on a publication that acknowledges NIH funding. If you have an appointment or affiliation that affords access to resources for research, you must include it in the Other Support disclosure. If the appointment does not afford access to resources, you must nonetheless disclose it, e.g., in your Biosketch.
NIH has not yet updated its instructions or forms for submission of Other Support or Biosketches; in the meantime, please follow the above guidance in the existing forms. If you have questions about whether or where to disclose a particular item, please contact your SPA Project Officer, and err on the side of transparency.
We also remind you that NIH requires prior approval for all Foreign Components involved with NIH-funded research. A Foreign Component is defined as:
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.
Even if your original proposal did not include a foreign component, sometimes a project may evolve to include one. If that is the case, you must obtain approval from NIH before the performance of any work on the NIH project begins in a foreign location.
If you believe you may need to obtain approval for a “significant scientific element or segment” of an NIH project to be performed outside the U.S., please contact your SPA Project Officer as soon as possible.
Disclosures of Outside Financial Interests Related to Your Research
Columbia policy has long required disclosure at least annually of all outside Financial Interests related to a researcher’s institutional responsibilities. This definition is broad. If you are being asked to participate in an outside activity because you are a professional in your field at Columbia, then it may reasonably appear that the requested activity is related to your Institutional responsibilities and you should disclose it. This includes any payments and sponsored travel from:
- U.S. and non-U.S. companies, foundations, and professional societies
- non-U.S. institutions of higher education
- non-U.S. government entities
All disclosures are made through Rascal. If you are unsure about what to disclose, err on the side of transparency. If you have questions, please contact the Office of Research Compliance and Training.
We will continue to keep you updated as we receive new information. For additional information and resources on science and security, please visit Columbia’s website dedicated to this topic: https://research.columbia.edu/science-security.
Vice President for Research Administration
Vice President for Research Compliance, Training, and Policy