NIH: FAQs on Reporting Other Support

1.When can we expect final information about what types of signatures are accepted?

At this time, NIH allows signatures within a flattened PDF.

Please maintain the original electronic signature so it is available upon request. We hope to have more information in May as NIH looks into the types of verifiable e-signatures it can accept.

2. How will electronic signatures on OS impact the ability to upload the Other Support to Grant Runner or ASSIST, etc.?

Other Support is typically required at the Just-in-Time (JIT) stage or as part of the Research Performance Progress Report (RPPR).

Other Support submissions at Just-in-Time and in the RPPR must be submitted as a flattened PDF, after all signatures are obtained. Applicants and recipients must maintain the original electronic signature and make it available upon request. When NIH transitions to the use of SciENcv to generate Other Support, the signature/certification will be integrated into that process.

3. When is this OS support change effective?

This is effective May 25th. We encourage everyone to make transition to the new format at that time.

NOTE: The new Biosketch format is required for submissions on/after May 25th as well, but NIH will not administratively withdraw an application for using the older format until January 25th, 2022.

4. Do collaborative research “Memoranda of Understanding” with foreign Universities count as foreign contracts?

If the MOU memorializes an understanding that rises to definition of Other Support (such as foreign affiliation, appointment or employment or foreign entity providing resources that supports or is related to Senior/Key Personnel research, and is not a gift) we recommend treating an MOU as a contract.

5. Are we required to use the old OS format through 5/24 or can we begin using the new format prior to May 25?

Yes, please use the current format until May 25th. Review more information from NIH on the correct format based on due date.

6. The employment of a foreign collaborator on an NIH grant doesn’t qualify as a foreign employment contract, right?

The employment” referred to in the question is more likely:

• An outgoing subaward
• A procurement Purchase Order (PO)

Please keep in mind that NIH has separate, but related rules concerning foreign components. If the foreign employment is under an NIH award and is considered a foreign component, prior approval to add that foreign component must be sought before engaging the foreign entity.

7. Would a student working for class credit be considered in-kind support? What about other volunteers?

A UW student (e.g. including those on a student visa) working for class credit is not considered in-kind support. This would be considered institutional support and therefore not reportable as Other Support.

A student from another institution or organization (e.g. visiting scholar) is considered in-kind support, if their work supports or is related to the Senior/Key Personnel’s research. This is a form of Other Support.

Volunteers: Gifts are not reportable as Other Support. Gifts are resources provided where there is no expectation of anything, such as time, services, specific research activities, money, etc. Therefore, if a volunteer’s time does not involve an expectation of anything in return, it is not reportable.

8. Would you consider office space at Fred Hutch or Kaiser for example, to be in-kind when a UW faculty has an appointment there?

NIH has included lab and office space as a form of in-kind support that should be listed as Other Support when it is related to the Senior/Key Personnel’s research.

However, the UW has reviewed the intent behind the NIH rule. The UW has concluded that individuals with joint or dual appointments under formal agreements with the UW, where they are provided lab space or other research space on a regular/ongoing basis are not the type of research support NIH is seeking to have listed. Rather, because the resource is by virtue of the dual/joint appointment, the UW considers this a form of institutional support which is exempt from the NIH OS requirements.

Examples of formal dual or joint appointments with UW include: FHCC, Kaiser, PNNL, Seattle Children’s.

Office/lab space provided to a researcher in support or related to their research that is not due to a formal joint or dual appointment with UW should be listed as Other Support.

9. For an NIH R01 research study with a student supported by an NIH T32, does that student need to be included as In-Kind on the R01 PI’s Other Support?

No.
Students supported by an NIH T32 and working on an R01 with or under the direction of the Senior/KP is not considered Other support. NIH specifically exempts training grants.

10. Are in-kind gifts provided from an outside organization with no value ascribed by the sponsor, such as a piece of equipment, considered in-kind or gifts for NIH Other Support?

A gift is not reportable as Other Support.
NOTE: NIH elaborates in NOT-OD-21-073 that Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as Other Support.

11. How do we address OS signatures from other institutions that are not aligned with the UW policy? For example, if they include a scanned signature when we request these for Just-In-Time or Research Performance Progress Reports?

For now, NIH accepts flattened PDFs.

All peer institutions are exploring e-signature options and most will have a compliant solution.  Whatever solution the UW is recommending or can support does not mean that collaborators must use that same solution.

We plan to publish more information and instructions on e-signature solutions as we learn more from NIH and discuss with UWIT.

12. If a Faculty member is on an international scientific advisory board, should we list it on OS regardless of the relation to research?

It is always good to err on the side of reporting membership on an international scientific advisory board. While mere membership itself does not rise to level of OS, any participation that can be perceived as relating to the Senior/Key Personnel’s research efforts or conducting research would be determined by NIH as reportable. Because that fine line can be difficult to discern, and NIH’s focus is on foreign interest, we recommend listing participation on a foreign scientific advisory board.