Working with Federal Agencies

Disclosing Activities to NIH

NIH requires disclosure of biographical, other support and foreign component information in proposals and post-award progress reports.

Biosketch

What to Disclose

Senior and key personnel are required to provide a Biosketch that includes:

  • professional preparation (e.g., educational degrees)
  • organizational affiliations and appointments
  • all academic or institutional appointments and positions, paid or unpaid, full-time, part-time, or voluntary
  • professional appointments that were active during the previous three years
  • current or pending participation in, or application to, programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs (Disclosure placement may be contract dependent)
  • a list of products that demonstrate the individual’s qualifications to carry out the project

When to Disclose

Biosketches are required to be submitted at the time of proposal. 

Other Support

What to Disclose

  • all current and pending resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of (i) whether the source is foreign or domestic; (ii) whether the resource is made available through the entity applying for a research and development award, another organization or directly to the individual; or (iii) whether the resource has monetary value; 
  • current or pending participation in, or application to, programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs (Disclosure placement may be contract dependent)
  • with an estimated dollar value of $5,000 or more, directly supporting the individual’s research and development efforts, not intended for use on the project/proposal being proposed, and having an associated time commitment. Examples include the provision of (office/laboratory space, equipment, supplies, or employees, or students
  • postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whose research activities are not intended for use on the project/proposal being proposed and have an associated time commitment
  • consulting that falls outside of an individual’s appointment; separate from the institution’s agreement. For example, when any of the following scenarios apply: i) the consulting activity will require the senior/key person to perform research as part of the consulting activity; ii) the consulting activity does not involve research, but is related to the senior/key person’s research portfolio and may have the ability to impact funding, alter time and commitment efforts, or otherwise impact scientific integrity; or iii) the consulting entity has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement
  • travel supported/paid by an external entity to perform research activities with an associated time commitment
  • startup company based on non-organization-licensed IP 
  • startup packages from organizations other than Ohio State
  • monetary donations that support an investigator’s research activities, that are given with an expectation

NIH requires supporting documentation, including copies of contracts, grants or agreements related to key personnel’s foreign appointments and/or employment with a foreign institution for all foreign activities and resources reported in Other Support. An English translation must be provided if the original documents are not in English.

Current and pending support must be signed, dated and certified to indicate it is true, complete and accurate.

When to Disclose

Other Support is submitted with the application and prior to award using “Just in Time” procedures. Any newly obtained Other Support should be disclosed in the next Research Performance Progress Report (RPPR).

The university is required to immediately notify NIH of any Other Support that should have been disclosed but was not disclosed. Investigators should immediately contact their Sponsored Program Officer (SPO) if they become aware of undisclosed Other Support. The SPO will assist with proper NIH notification.

Facilities, Equipment and Other Resources

What to Disclose

  • institutional resources, such as core facilities or shared equipment that are made broadly available
  • in-kind contributions with an estimated dollar value of $5000 or more that support the research activity for use on the project/proposal being proposed
  • postdoctoral scholars, students, or visiting scholars who are supported by an external entity, and whose research activities are intended for use on the project/proposal being proposed 

When to Disclose

Facilities and resources are disclosed at the time of proposal. Any new contributions should be disclosed in progress reports.

Foreign Components

On May 1, 2025, NIH announced an updated policy on foreign subawards.  NIH will establish a new award structure that will prohibit foreign subawards from being nested under the parent grant. Under the new structure, NIH will fund foreign components that are structured as independent subprojects directly linked to the prime award.

Review the Foreign Subaward Award Structure Policy

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