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Frequently Asked Questions
Other Support and Foreign Components
Initial Posting: June 19, 2019
Last Revised: August 6, 2019


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      A. Other Support

    1. Has NIH expanded the applicability of the Other Support policy?

      No. NOT-OD-19-114 is a reminder for the extramural community of NIH’s Other Support policy, and its applicability.

    2. What does NIH evaluate when reviewing Other Support submissions?

      NIH scientific program and grants management staff review Other Support information to ensure that:

      - All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported

      - Sufficient levels of effort are committed to the project

      - There is no scientific, budgetary, or commitment overlap

      - Only funds necessary to the approved project are included in the award

    3. I am a Principal Investigator on an NIH award to a domestic university and have an unpaid appointment at a foreign university. At the foreign site I have access to lab space, research materials, and staff. Should I report this as Other Support?

      Yes. While the researcher is not receiving monetary compensation, the lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts. Other payments, such as travel or living expenses must also be reported. As outlined in NOT-OD-19-114 this appointment must be reported as Other Support. NIH requires applicants to list all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application 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). 

    4. A researcher at my institution has a 9-month appointment. They spend two months at a University outside of the United States during the summer conducting research under a foreign award. Does this count as Other Support?

      Yes. Available resources in support of and/or related to an investigator’s research endeavors should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. 

    5. What if NIH determines that an institution is not complying with NIH policies for transparency and disclosure of all Other Support?

      NIH takes the issue of protecting the integrity of U.S. biomedical research seriously. When issues of noncompliance are identified, NIH will take action as outlined in the NIH Grants Policy Statement, Section 8.5. This may include withdrawing approval of the Program Director/Principal Investigator or other researchers contributing to the NIH award, imposing specific award conditions, disallowing costs, withholding future awards including the possibility of suspending or terminating the award.

       

    6. What should I do if I’m not sure if something needs to be included as Other Support?

      In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.


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      B. Foreign Components

    1. What is the definition of a foreign component, and has it changed?

      No, NIH has not changed the definition of a foreign component. NOT-OD-19-114 reminds recipients that a foreign component is the performance of a significant scientific element of the NIH-supported project outside of the United States.  Once a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component.

       

    2. What are some examples of a “significant element of a project” when making determinations regarding a foreign component?

      The recipient institution should evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. 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

      - receipt of financial support or resources from a foreign entity

    3. What is the NIH definition of a foreign institution?

      NIH defines a foreign institution as an organization located in a country other than the United States and its territories that is subject to the laws of that country, regardless of the citizenship of the proposed PD/PI.

    4. Does work being conducted in the United States ever count as a foreign component?

      Generally, no. The first step in determining if an element or segment of an NIH-funded project constitutes a foreign component is to evaluate whether the work is being conducted in a foreign country. If not, then it is considered other support and must be reported. In all cases, recipients are encouraged to discuss specifics, in advance, with your Grants Management Officer regarding proper classification of Other Support and Foreign Components.

    5. What is an example of an activity that is not a foreign component, but would meet the definition of Other Support? What is the difference?

      This response is dependent upon specific details that surrounding the activity.  For instance, one model could be that a PI on an NIH grant may have an appointment and a lab at a foreign university. The research being done at the foreign lab is unrelated to the PI’s NIH project. This would not qualify as a foreign component of the NIH research, as the foreign work is not part of the NIH-funded project. However, it is a resource made available to the researcher in support of their research. Therefore, it must be reported as Other Support. 

    6. I am the PI on a NIH grant to a domestic university. I have a visiting post-doctoral fellow in my lab, who works on my NIH grant and does all of his/her work in the United States. The fellow’s salary is paid by a foreign government. Is this a foreign component?

      In general, no. The first step in determining whether research constitutes a foreign component is to evaluate whether a portion of the research is being conducted outside of the United States. In this case, all of the work is being conducted in the US, so there is no foreign component.


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      C. Financial Conflict of Interest (FCOI)

    1. How does the NOT-OD-19-114 impact the FCOI policy?

      There has been no change to the FCOI policy. NOT-OD-19-114 serves as a reminder to the extramural community of the requirements that are outlined within 42 CFR Part 50, Subpart F, Objectivity of Research (the FCOI regulation), which specifies the requirements for investigators to disclose to their institution their significant financial interests. The requirement to disclose includes financial interests received from a foreign institution of higher education or the government of another country. This requirement is distinct from other support and foreign components.



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