In follow-up to the Office of Research email announcement on August 7, 2024, this article describes in more detail the NIH’s Other Support document and the importance of research and budgetary overlap disclosures for UCSF Principal Investigators (PIs) and senior/key personnel.

NIH Other Support

The NIH Other Support document is provided to the NIH at Just-in-Time (JIT) submission and lists all other sources of PI and senior/key personnel research funding and their relation to the NIH research award under consideration. Other Support disclosure is part of NIH’s stewardship of public funds to ensure that Federal dollars are being requested for research that is distinct and not funded on other awards.

UCSF PI and senior/key personnel are responsible for determining whether there is scientific and budgetary overlap of the proposed NIH award with grants and awards listed on their Other Support document. Overlap is allowable in certain circumstances but must be disclosed at JIT and addressed with the NIH prior to award finalization. The PI and senior/key personnel signatures on their Other Support form certifies that the information provided is correct and complete (see detailed NIH instructions here).

Additionally, UCSF has administrative controls in place (e.g., reviews, approvals, trainings) to support researchers in this process. The UCSF process, roles, and responsibilities for completing Other Support is described in detail in the Office of Sponsored Research’s (OSR’s) Service Partnership Agreement (SPA). In 2022, former EVCP Daniel Lowenstein wrote an article in Espresso on this topic, and the Office of Sponsored Research (OSR) conducted an Other Support-focused training at the Research Administrators Town Halls: December 13, 2023 (Slide Deck - Slides 55-63, Recording - hour mark 1:03:20) and June 20, 2024 (Slide Deck - Slides 33-42, Recording - hour mark 43:32). 

UCSF Non-compliance and NIH Requested Corrective Actions

The NIH has recently contacted UCSF regarding two cases of undisclosed overlap on Other Support documentation submitted at JIT and has requested a corrective action plan to ensure future compliance.

In their letter, the NIH specifically noted that UCSF’s failure to identify errors and discrepancies in the Other Support documentation called into question UCSF’s policies and procedures for verifying the accuracy and validity of administrative, fiscal, and programmatic information submitted through the Just-in-Time process.

A lack of appropriate policies and procedures to manage NIH awards could result in the imposition of Specific Award Conditions (SACs) removing administrative flexibilities for all UCSF grant awards.

Interim Review Process and Future Planning

As described in the Office of Research August 7 email, OSR has instituted an interim email verification of Other Support process asking all UCSF PIs and other senior/key personnel, department post award administrators, and department chairs or chair delegates to review Other Support prior to JIT submission.

Responsibility for accurate current and pending support and overlap disclosure still sits with the PI and senior/key personnel; it is hoped however, that this interim review process will assist in ensuring UCSF compliance. Please recognize that this interim process does not change the existing roles and responsibilities outlined in the OSR SPA. Rather, it confirms that the department has reviewed the completed Other Support and, if necessary, requested additional information or corrections to content before submission (e.g., if Other Support includes projects with matching titles, but no disclosure of overlap).

As the largest public recipient of NIH funding, UCSF must be a model for stewardship of NIH funding. OSR is currently reviewing UCSF’s processes and controls for Other Support documentation (including determination of scientific overlap) to respond to NIH’s concerns. OSR will work with key UCSF stakeholders to develop and communicate any necessary changes to the OSR SPA. We thank you in advance for your understanding and partnership in this important effort.

Please join us on for an Off-Cycle RA Town Hall for an overview of NIH Other Support and to get your questions answered. 

• Topic: Off-Cycle RA Town Hall: Other Support
• When: 8/28/24 10:00am-11:00am

Townhall Slide Deck (Requires UCSF MyAccess) and Town Hall Video Recording (Requires UCSF MyAccess)