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
  • current academic, professional, or institutional appointments, paid or unpaid, and whether full-time, part-time or voluntary
  • 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)

When to Disclose

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

Other Support

What to Disclose

  • all current and pending projects, regardless of whether the support is provided through Ohio State, through another organization, or directly to the individual, and regardless of whether the project has monetary value. Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the individual
  • 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)
  • in-kind contributions (e.g., office/laboratory space, equipment, supplies or employees) not intended for use on the project/proposal
  • visiting scholars working in labs funded by an external entity
  • students and postdoctoral researchers funded by an external entity
  • consulting involving research activities that falls outside of an individual’s appointment; separate from the institution’s agreement
  • travel supported/paid by an external entity to perform research activities with an associated time commitment
  • startup packages from organizations other than the Ohio State startups

NIH requires supporting documentation, including copies of contracts, grants or agreements related to key personnel’s foreign appointments or foreign employment. 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 and Resources

What to Disclose

  • institutional resources, such as core facilities or shared equipment that are made broadly available
  • in-kind contributions by outside sources intended for use on the project being proposed (Include a letter of collaboration from each collaborator.)

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, which is expected to be implemented by no later than September 30, 2025, NIH will fund foreign components that are structured as independent subprojects directly linked to the prime award.

Until the details of the new foreign collaboration award structure are released, NIH will not issue awards (new, renewal or non-competing continuation) that include a subaward to a foreign institution to domestic (U.S.) or foreign (non-U.S.) institutions. This applies to all foreign monetary collaborations. In addition, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project.

Review the Foreign Subaward Award Structure Policy

Resources