NOT-OD-19-114: Reminders of NIH Policies on Other Support and on Policies related to Financial Conficts and Foreign Components
- RA Town Hall 09/09/19 slide deck ONLY SIDES related to the review of the NIH notice - NOT-OD-19-114
- COCR - Commentary on Disclosing Other Support and Other Resource in Research Funded by the National Institute of Health
OSR will not enforce using Total Costs in Other Support until NIH udpates the GPS and/or OS Templates and Examples
Other Support Resources
- Webinar: Other Support, Related Effort and RMS systems: A webinar recording from the training opportunity describing other support, all personnel reports, effort reporting and over of RMS systems.
- Presentation:Other Support, Related Effort and RMS systems: Slide Deck from the training opportunity describing other support, all personnel reports, effort reporting and over of RMS systems.
- Sample JIT Other Support Document with Notes: An example of an Other Support document to be used during Just-in-time (JIT), with footnotes defining key terms in the document.
- Sample JIT Other Support Document with no Notes: An example of Other Support Document with notes removed, and text hidden.
- Blank JIT Other Support Document
- Sample RPPR Other Support: An example of an RPPR Other Support Document: An example of an Other Support document to be include as part of an NIH Progress Report (RPPR). Also includes an example of how to include Industry Clinical Trials on the Other Support Document.
- DOD Example
- Sample JIT Other Support for K award with Complemetary Support
- Sample JIT Other Support for K award with Concurrent Support
- Sample JIT Other Support for K award wtih Complementary and Concurrent Support
- Sample JIT Other Support fro VA Joint Appointment
- Summary of NIH Policy regarding Senior/Key Personnel and Investigator:
This chart provides definitions, who designates, requirement, and references for proposals, other support, prior approval and COI.
- Summary of NIH Policy regarding Other Support vs. Biosketch: Contains a quick reference chart (page 1) and a detailed chart (page 2)
All financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards.
Training awards, prizes and gifts are not included.
Other sponsors will vary, always follow sponsor guidlines.
Information on other support assists awarding agency staff in the identification and resolution of potential overlap of support. Overlap, whether scientific, budgetary, or commitment of an individual's effort greater than 100 percent*, is not permitted. The goals in identifying and eliminating overlap are to ensure that sufficient and appropriate levels of effort are committed to the project; that there is no duplication of funding for scientific aims, specific budgetary items,
or an individual's level of effort; and only funds necessary to the conduct of the approved project are included in the award.
* Be aware of appointment type and clinical, teaching, and/or administrative requirements; effort may need to be capped at 95% (11.4 Calendar months) to allow time for those activities. Learn more about the 95% rule here.
If the PI's level of effort changes by 25% or more than what was proposed PRIOR APPROAL is required from NIH. Go here to learn more about changing effort levels on an award.
An entry should include the information necessary to properly identify the project and its relevance to the investigator’s work in terms of purpose, role and salary support. Typically, this information includes (numbered items in this list are referenced in sample):
- Funding identification number (e.g. grant number as assigned by the funder), if applicable
- Last name of the principal investigator of the project
- Dates of entire project
- Effort level of this person on this project (calendar months)
- Project’s direct expense for the current project year
- Project title
- Brief narrative of project
Sample Other Support entry:
Include all current support and calendar months devoted to a project (paid, unpaid, and cost-share). If there is a no-cost extension in effect, be sure to change the end date to reflect the no-cost extension period.
Tip: Be consistent with presentation. Though not required, it is better if all dates are presented in the same format. If possible, use MM/DD/YY.
Pending (for JIT Other Support):
Include any pending proposals (i.e.: proposals that have been submitted and the start-date has not lapsed) that include any salary support for the individual. These entries should look very similar to the active support entries. Include the start/end dates for the entire project, the person’s effort (in calendar months) and the total direct expense for the first project period of the proposal.
Sample Pending Support entry:
Inactive (for RPPR Other Support):
Previous active grants that have terminanted within the year since last reported Other Support.
Identify any scientific, budgetary, or commitment overlap that would occur if the current proposal were approved. Then state how it would be resolved. The goals in identifying and eliminating overlap are to ensure that sufficient and appropriate levels of effort are committed to the project; that there is no duplication of funding for scientific aims, specific budgetary items, or an individual’s level of effort; and that only funds necessary to the conduct of the approved project are included in the award.
Budgetary overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salary) are requested in an application but are already provided for by another source.
Commitment overlap occurs when a person’s time commitment exceeds 100 percent (i.e., 12 person months), whether or not salary support is requested in the application. While information on other support is only requested for Senior/key Personnel (excluding consultants), no individuals on the project may have commitments in excess of 100 percent or 12 person months.
Scientific overlap occurs when: (1) substantially the same research is proposed in more than one application or is submitted to two or more different funding sources for review and funding consideration, or (2) a specific research objective and the research design for accomplishing that objective are the same or closely related in two or more applications or awards, regardless of the funding source. Potential scientific overlap is to be addressed by the SRG only by its identification in an Administrative Note in the Summary Statement.
Sample Overlap entries:
OVERLAPThere is commitment overlap for Dr. XYZ between 5R01WE1234546-01 and the application under consideration. If this application is funded Dr. XYZ will request approval to reduce his effort on 5R01WE1234546-01 to 2 caledar months. If other pending applications are funded, Dr. XYZ will reduce his effort appropriately.
There is scientific overlap commitment overlap for Dr. XYZ between aim 1 of 5R01WE1234546-01 and aim 2 of the application under consideration. If this application is funded, Dr. XYZ’s effort will be adjusted on 5R01WE123456-01 to remove the overlap.
As noted above, the Institute/Center’s scientific program and grants management staff will review other support information prior to award.
Resolution of overlap occurs at the time of award in conjunction with applicant institution officials, the principal investigator, and awarding agency staff. NIH staff continue to monitor changes to other support information throughout the project as part of the annual progress reviews.
Q: What should the budget amount during a NCE, the last year’s direct cost, or what is remaining?
A: The direct costs from the last year.
Q: When should we remove something from the pending section?
A: Either if the start date has already passed, or if the PI hears from the sponsor that it will not be funded.
Q: Do you need prior approval from the NIH’s GMS for subsumed effort on a K award?
A: No, subsumed effort is complementary effort and does not require prior approval but you do need approval for concurrent effort. For more information go here: http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch12.htm (see 184.108.40.206 and 220.127.116.11)
Q: If my faculty is a co-investigator on a grant, should I list the annual direct costs for the whole project, or for just his/her portion of the project?
A: The annual direct costs for the whole project. If this is a large project grant (for example a P50), list only projects/core that the faculty member work on, list the annual direct costs for the project/core.
Q: How do I get previous copies of NIH RPPR progress reports?
A: NIH RPPR progress reports are uploaded to eProposal. To find documents in eProposal follow this guide. Search by the A#. (Need to update the eProposal guide, then I will add link guide on the iris-help website. )
Q: Should I Submit the Other Support directly to NIH, or should it go to the RSC?
A: Submit the Other Support to the RSC. The RSC will submit to NIH.
Q: Do we need prior approval for an increase of effort?
A: For NIH, no. You only need prior approval for REDUCTIONS of 25% or more (if they are listed as Key Personnel in the Notice of Award). If not NIH, please check the sponsor policy.
Q: What if we have received prior approval to reduce effort?
A: This is the new baseline of effort. If you make further reductions, you need to ask for prior approval if you reduce by 25% of this NEW approved effort level.
Q: What should I do if NCE is pending?
A: Keep it listed in the active section. Put the proposed new dates and next to the dates, put in Parentheses, NCE Pending.
R01 HL 0000002 (Anderson) (AXXXXXX) 03/1/10– 02/28/16(NCE Pending) 5.60 calendar
Other Support format page: http://grants.nih.gov/grants/funding/phs398/othersupport.pdf (note: this predates the electronic submissions for NIH. When you use this format, delete the headers and footers prior to submitting).
Usage of Person Months: http://grants.nih.gov/grants/policy/person_months_faqs.htm