Objective

In addition to completing UT outside interest disclosures pursuant to GE0002, UT personnel who participate or propose to participate in federally sponsored projects must complete disclosures to sponsors as required by the sponsoring agency and in accordance with the agency’s policies, rules, and regulations. Information on current, pending, and other support assists sponsoring agency staff in the identification and resolution of potential conflicts of interest and overlap of support.

Applicants and awardees of funding opportunities sponsored by the National Institutes of Health (NIH) must comply with NIH’s Other Support (sometimes referred to as “current and pending support” or “active and pending support”) requirements.

Scope

This Policy Procedure applies to all UT personnel required by NIH to complete Other Support, including all faculty and researchers identified as Senior/Key Personnel on NIH research applications and awards. Defined terms used herein shall carry the meaning defined by NIH in the NIH Grants Policy Statement.

Procedure

1. What is Other Support? NIH requires full transparency in the disclosure of all sources of research support, foreign components, and financial conflicts of interest for Senior/Key Personnel on research applications and awards using NIH’s Other Support disclosure process. 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 but is not limited to:
   1. Resources and/or financial support from all foreign and domestic entities, that are available to the researcher. This includes, but is 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.). Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.
   2. Consulting agreements, when the PD/PI or other Senior/Key Personnel will be conducting research as part of the consulting activities.
   3. In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees, visitors engaged in research, or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.
      
      If any Other Support involves a foreign contract, grant, or any other form of agreement between the disclosing Senior/Key Personnel and a Foreign Organization, a translated copy of the foreign contract, grant, or agreement must be provided to NIH as part of the PDF following the Other Support format page. Machine translations are acceptable.
      
      Other Support does not include training awards, prizes, or gifts (i.e., resources provided without the expectation of time, services, research activities, money, or anything else in return).
2. Who Must Submit Other Support Disclosures? Other Support disclosures must be submitted by anyone required by NIH. NIH generally requires disclosures from:
   1. All individuals designated in an application as Senior/Key Personnel, except
      1. Program Directors, training faculty, and other individuals involved in the oversight of training grants, and
      2. Individuals categorized as Other Significant Contributors.
   2. All Senior/Key Personnel, excluding consultants, in progress reports when there has been a change in active Other Support, except Program Directors, training faculty, and other individuals involved in the oversight of training grants.
3. How and When are Other Support Disclosures Submitted? Other Support Disclosures must be submitted at the time, and in the form, required by NIH.
   1. As of the effective date of this Policy Procedure, NIH requires the submission of Other Support utilizing the NIH-specific format page and associated instructions.
   2. All pending support at the time of application submission and prior to award must be reported using Just-in-Time Procedures. If Other Support, is obtained after the initial NIH award period, from any source either through the institution or directly to Senior/Key Personnel, the details must be disclosed in the annual research performance progress report (RPPR). Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on Administrative Requirements Changes in Project and Budget NIH Standard Terms of Award.
   3. Senior/Key Personnel shall ensure they understand NIH’s Other Support requirements and contact the appropriate office of sponsored projects if they have questions. Additional resources are available in Section 5 below.
4. Training Requirements. Each UT Campus and Institute must implement trainings to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the 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.
5. Additional Resources.
   1. NIH Other Support Page
   2. NIH Other Support FAQs
   3. NOT-OD-25-133
   4. NIH Grants Policy Statement (GPS), Section 2.5.1 “Just-in-Time Procedures”