On July 10, 2019, the Office of the Director, National Institutes of Health (NIH) issued Notice NOT-OD-19-114 to provide additional guidance and clarification to universities and faculty regarding the disclosure of Other Support, Foreign Components, and Significant Financial Interest. The University of Pittsburgh continues to be supportive of global research, and we want to assist our faculty in continuing to be active participants in the international research community. To that end, we welcome the opportunity to help you better understand the NIH’s expectations regarding disclosure and to assist you with compliance.
Below are links to the Notice, as well as helpful NIH FAQs with hypotheticals regarding appointments at other institutions and lab personnel. Faculty with NIH funded grants who have undisclosed Other Support or Foreign Components will need to make disclosures to the NIH. The Notice provides guidance on a variety of scenarios, including but not limited to the following:
- Grant applications under review at NIH and pending award: Disclosures should be made using the “Just-in-Time Procedures” included in the Notice. Disclosures should be reviewed in advance by the Office of Sponsored Programs.
- Active grants: Disclosures should be included in your next Research Performance Progress Report (RPPR).
- Former grants: Disclosures will be made as requested by the NIH with the assistance of Pitt’s Office of Sponsored Programs.
University of Pittsburgh Resources
- University of Pittsburgh Managing International Research and Engagement website
- COI guidance for disclosures (03-12-2021)
- Reviewing Disclosures by Pitt Supervisors: Presentation : Slides (PDF). (03-12-2021)
- Email from Dr. Rob Rutenbar regarding Management of NIH Disclosures (07-17-2019)
- Memo from Dr. Rob Rutenbar to Faculty, Staff, and Graduate Students regarding Your Responsibilities Regarding Disclosure and Reporting Requirements Related to Foreign Engagements with Pitt Research (01-18-2019)
NIH Notices and Resources
- NOT-OD-21-122 Announcing New Inbox for Inquiries Related to Changes to Biographical Sketch and Other Support Format Page (05-24-2021)
- NOT-OD-21-110 Implementation of Changes to the Biographical Sketch and Other Support Format Page (04-28-2021)
- NOT-OD-21-073 Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 (03-12-2021)
- NIH Disclosure Examples (PDF) (08-08-2019)
- Clarifying Long-Standing NIH Policies on Disclosing Other Support by Mike Lauer (07-11-2019)
- NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (07-10-2019)
- FAQ related to Other Support and Foreign Components
- Protecting U.S. Biomedical Intellectual Innovation - Examples of What to Disclose to NIH about Senior/Key Personnel on Applications and Awards
Other Agency Resources
- DoD: Other Support Requirements effective 4/20/2019 (PDF)
- NSF
- Chart on Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support (PDF) (updated 04-21-2022)
- Frequently Asked Questions (FAQs) Regarding Current and Pending Support (PDF) (updated 01-11-2022)
- PAPPG (NSF 20-1) Frequently Asked Questions on Current and Pending Support (PDF) (06-01-2020)
This website will continuously be updated with additional information to support faculty in complying with NIH requirements. Questions regarding disclosures may be sent to the following dedicated account: Fundingagencydisclosures@pitt.edu, and a member of the Office of Sponsored Programs team will respond to you within one business day. We look forward to assisting and supporting your international research endeavors.