The NIH Grants Policy Statement (NIHGPS) outlines policy requirements that serve as the terms and conditions of NIH grant awards. By accepting an award, recipients agree to comply with the requirements in the NIH Grants Policy Statement unless the notice of award states otherwise.
Recipients of NIH grant awards must comply with all applicable U.S. Federal statutes, regulations and policies. If a recipient fails to comply with the terms and conditions of the award, NIH may take one or more enforcement actions which include disallowing costs, withholding of further awards, or wholly or partly suspending or terminating the grant.
On this page
In addition to the NIH grants policies and information provided on this page, researchers should be familiar with the following:
- NIH Financial Conflict of Interest (FCOI) Regulation; note: SFU’s U.S Public Health Service (PHS) -compliant FCOI policy
- Human Subjects Education Requirement
- Requirements for NIH Notification of Removal or Disciplinary Action Involving Program Directors/Principal Investigators or other Senior/Key Personnel
- Public Access Policy
Disclosure of Other Support
NIH requirements
Other Support is defined as “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” (please see NOT-OD-21-073).
All individuals designated in an NIH application as senior/key personnel are required to use the updated Other Support Format to report all current and pending support for:
- proposal applications (when explicitly stated in the Funding Opportunity Announcement),
- just-in-time requests, and
- Research Performance Progress Reports (RPPRs)
due on or after January 25, 2022.
As of January 25, 2022, investigators are required to:
- electronically sign their respective Other Support declarations prior to submission, certifying that the statements therein are true, complete, and accurate; and
- submit supporting documentation in relation to funding/research support. This includes English language "copies of contracts/agreements 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". [source] Contracts with Canadian entities and awards of Canadian funding agencies are considered foreign contracts/awards vis-à-vis NIH.
Note: SFU researchers are not required to submit copies of their employment agreements with SFU.
For more information, please refer to NIH Other Support page.
Additional resources:
- Frequently Asked Questions (FAQs): Other Support and Foreign Components
- SFU Research Services Training slides on Other Support (.pdf)
SFU Requirements
Please note that all Other Support forms MUST be reviewed by SFU Research Services prior to submission to NIH.
SFU Research Services is available to assist members of the SFU research community in compiling and preparing supporting documentation to be submitted with the Other Support form. To request support, please email ors@sfu.ca as soon as possible, but no later than 15 days prior to the due date of your submission.
Researchers who prepare supporting documentation without the assistance of Research Services must email the following documentation to ors@sfu.ca no later than 5 business days prior to the submission due date:
- the completed and signed Other Support form, and
- supporting documentation for all non-U.S. sources of support listed in the Other Support form for all senior/key personnel listed on the application/award letter.
If any Senior/Key Personnel on the project disclose Other Support information outside of Just-in-Time or the RPPR submission, the Principal Investigator needs to inform SFU research Services at ors@sfu.ca immediately upon receiving the information about the disclosure. Please note that SFU is required to submit updated Other Support to the Grants Management Specialist named in the Notice of Award within 30 days as it becomes known.
Summary & tips
Completing the Other Support form
To complete the form, follow the format and instructions outlined by the NIH.
Tips
- Split information into four main separate sections, listed in the following order:
- Active
- Pending
- In-kind contributions
- Active
- Pending
- Overlap
Do not omit any of these sections from the Other Support form. If a section will be empty, enter “NONE” under the applicable heading.
- Investigators need to note their eRA Commons ID in the Other Support form. If the submitting investigator does not have an eRA Commons ID, please contact ors@sfu.ca.
- All active/pending sponsored projects need to include the total award amount (direct + indirect costs). For subawards, only the total subaward amount needs to be included.
- Devoted effort must be measured using “person months.” NIH and other PHS agencies use the concept of “person months” as a metric for determining percentage of effort. For additional information, including examples of how to calculate person months, see the NIH Usage of Person Months webpage, which includes a Percent of Time & Effort to Person Months Calculator (.xls).
- If you are receiving an in-kind support, provide an estimate for its dollar value. If the time commitment or dollar value is not readily ascertainable, reasonable estimates should be provided.
What to disclose
Disclose ALL active and pending sources of Other Support, including but not limited to:
- Sponsored projects/proposals (including projects not administered through SFU or conducted as part of Investigator’s appointment at SFU).
- Consulting agreements, when the investigator will be conducting research as part of the consulting activities. Non-research consulting activities do not need to be disclosed.
- Financial support for research personnel, and contribution of high-value materials and/technologies that are not freely available.
- In-kind support, including but not limited to:
- Personnel (e.g., visiting scholars, employees or students, supported by a non-SFU entity)
- Space
- Equipment
- Materials
- Supplies
Notes:
- In-kind support not intended for use on the active project/pending proposal must be reported in Other Support form.
- In-kind support intended for use on the active project/pending proposal, such as institutional resources (e.g., shared core facilities or shared equipment), should be listed in the Facilities and Other Resources document, and need not be replicated on the Other Support form.
- Other Support does not include training awards, prizes, or gifts.
Signing
All investigators required to submit Other Support form must also electronically sign their respective documents using an e-signature service (e.g. Adobe Sign, DocuSign, PandaDoc or similar). After signing, flatten the Other Support form.
Notes:
- A typed name is not an electronic signature and is not acceptable.
- Wet (ink) signatures are not acceptable.
- Flatten the PDF after signature.
Attaching supporting documentation
For Other Support submissions that include foreign activities and resources, recipients are required to submit copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation. If they are not in English, recipients must provide translated copies. This supporting documentation must be provided as part of the Other Support PDF following the Other Support Format page.
Notes:
- Google translations, or similar, are acceptable but certified translations may be required upon request from NIH.
- Contracts with non-US entities, including contracts with Canadian entities and awards of Canadian funding agencies, are viewed by NIH as foreign contracts/awards and are subject to the supporting documentation disclosure.
- SFU researchers are not required to submit copies of their employment agreements with SFU. However, SFU researchers must disclose employment agreements or appointment letters (e.g., an adjunct appointment letter) issued by other Canadian organizations if the applicable activities or resources are reported in Other Support.
Undisclosed support
If any investigator on the project disclose Other Support information outside of Just-in-Time or the RPPR submission, the PI needs to inform SFU Research Services at ors@sfu.ca immediately upon receiving the information about the disclosure.
Intellectual Property Policy
NIH Intellectual Property (IP) Policy (please see: https://grants.nih.gov/policy/intell-property.htm; and 8.2.4 Inventions and Patents (nih.gov) ) requires a recipient institution to obtain an assignment of rights to patentable results, or any novel variety of plant protectable under the Plant Variety Protection Act created or first conceived to practice in the course of the NIH-funded research (“NIH Results”)
To comply with the NIH requirements, Research Services requests that NIH-affiliated researchers at SFU email ors@sfu.ca with the following:
- Notification that they have created or are in the process of creating:
- research results that are or may be patentable, or
- any novel variety of plant which is or may be protectable under the Plant Variety Protection Act
- Written disclosure of NIH Results
- Notification of intent to publish NIH Results
- Questions as to whether research results are patentable
Data management and sharing policy
The effective date of the NIH Data Management and Sharing (DMS) Policy is January 25, 2023, unless otherwise stipulated by NIH. (See policy NOT-OD-21-013)
This policy applies to all NIH research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data. Note that the DMS Policy does not apply to research and other activities that do not generate scientific data. (i.e. research training, fellowships, infrastructure development, and non-research activities.) For more details, see Research Covered Under the Data Management & Sharing Policy.
DMS Plans should describe how data will be managed and appropriately shared. See Writing a Data Management & Sharing Plan for details, sample plans and an optional format page which includes six elements recommended to be included in a Data Management and Sharing Plan. Guidance on planning and budgeting and selecting a data repository are available on the NIH Scientific Data Sharing website. Application Guide instructions have been updated to provide instructions for DMS policy implementation.
Reminder: NIH Policy for Data Management and Sharing effective on January 25, 2023.
Additional resources:
- DMS Policy Overview
- DMS Policy FAQs
- Learning Resources including 2-part webinar series on DMS Policy
- Statements and Guide Notices
If you need support, consultation and feedback on your data management planning, please email the SFU Library Research Data Management team at data-services@sfu.ca.