Yes, this appointment must be reported as Other Support. While monetary compensation is not received, the lab space, materials, and staff are resources provided in support of and/or related to the research efforts. Other payments, such as travel or living expenses must also be reported. NIH, NSF, and DoD require applicants to list all positions and scientific appointments, both domestic and foreign, that are held by senior/key personnel. This includes affiliations with foreign entities or governments, such as 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).

A researcher at my institution has a 9-month appointment. S/he spends 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, this would be considered Other Support. 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.

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

Err on the side of disclosure. Federal agencies require complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic. If you have any questions about whether something should be reported, please contact the Program Officer.

How does the Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114) impact the FCOI policy?

There has been no change to the FCOI policy. Investigators are still required to disclose to their significant financial interests to their institution. This 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.

The addition a new foreign component requires prior NIH approval.

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. If noncompliance is identified, potential action by NIH 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, per NIH Grants Policy Statement, Section 8.5.

View All FAQs