Memo to Faculty Proposing Research Funded by NIH: Disclosure of Foreign Financial Support, Foreign “Talents” Programs, and Other In-Kind Support

On July 10, 2019, the National Institutes of Health (NIH) issued Notice NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interest and Foreign Components. The Notice:

• Reminds institutions to report “all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.”
  
• Issued associated FAQs on Other Support and Foreign Components
  

File in the NIH ERA when “Just in Time” supplemental files are required. File when changes to other support occur via the annual RPPR.

Filings should include:

• Foreign Components: activities that include the existence of any "significant scientific element or segment of the project" outside of the United States, including but not limited to performance of work by a researcher in a foreign location employed or paid by a foreign organization, whether or not NIH grant funds are expended.
• Other Support: 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 resource 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.). See Other Support for more details.
  
• Effective May 25, 2021 filings may be made using the new Biosketch and Other Support Forms. Effective January 25, 2022, use of these forms is mandatory.
• If NIH asks you to provide 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, coordinate any production of documents with the Associate Vice President for Research and Innovation, Sponsored Programs by emailing osp@vt.edu.
• When filing, link to the Just In Time help page or submit as part of your RPPR.

If you have questions about these requirements, please see the Virginia Tech‘s Foreign Influence in Federally Sponsored Research website: Faculty and Staff Foreign Interest Disclosure Responsibilities: When and How to Disclose to NIH.

You may contact OSP Pre-Award directly for questions about these disclosure requirements or OESRC directly at oesrc@vt.edu for general questions about foreign influence.