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

What to Disclose

NIH requires applicants and recipients to determine whether research activities include a foreign component. A foreign component is defined as “the existence of any ‘significant scientific element or segment of a project’ outside of the United States.” This includes:

  • performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended
  • performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended

Examples of a foreign component include, but are not limited to:

  • the involvement of human subjects or animals at a foreign location
  • extensive travel by recipient project staff for data collection, surveying, sampling and similar activities at a foreign location
  • collaborations with investigators at a foreign site anticipated to result in co-authorship (including visiting personnel who will continue work on the project outside the U.S.)
  • use of facilities or instrumentation at a foreign site
  • receipt of financial support (including travel support) or resources from a foreign entity; or samples provided to a foreign entity for additional award-related research

If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. See item B2 in the NIH FAQS for further guidance how about to determine if activities are significant.

Note: If an activity does not meet the definition of foreign component because all research is being conducted within the U.S., but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support. For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI’s NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI’s grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.

When to Disclose

A foreign component must be disclosed in Item 6 of the Research & Related Other Project Information Form at the time of application. Applicants must check “yes” if the project includes a foreign component and must include a Foreign Justification attachment in Field 12, Other Attachments.

Foreign components also must be disclosed in in Section G.9 of Research Performance Project Reports (RPPRs). For more information, see the RPPR Instructional Guide, p. 99.

The addition of a foreign component to an ongoing NIH grant requires NIH prior approval, as outlined in Section 8.1.2, Prior Approval Requirements.

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