NIH Disclosure Checklist
The OSP checklist is intended to be a high level decision making tool to assist Dartmouth researchers who are compiling and submitting information to fulfill NIH, NSF or other agency requirements for reporting other support. Information concerning proposals and awards made to Dartmouth College can also be obtained from the Office of Sponsored Projects.
We encourage researchers to review agency instructions and forms and work with their department grant manager and OSP if there are specific questions or scenarios. The following questions may prompt you to consider specific scenarios that you may have not considered need to be included in your Biosketch, Other Support/Current and Pending Support or the Facilities, Equipment & Other Resources pages/sections.
Question 1. Visitors
Do you have any visiting postdoctoral fellows, visiting students, or visiting scholars
involved in research in your lab who are paid directly, in full or in part, by any
non-Dartmouth organization, institution, company or government ("Entity")?
If NO, proceed to Question 2. If YES, you need to report visitors if involved in your research on your Other Support. Specific NIH FAQ may relate to visitors:
NIH FAQ A21. If a PD/PI or other senior/key personnel is mentoring post-doc or graduate students who are individually funded through an outside institution) e.g. foundation or home university), does that need to be disclosed as an in-kind resource in Other Support?
NIH FAQ B.6 If a PD/PI or other senior/key Personnel has an exchange student or post-doc working on research activities in their lab who is paid a salary by their home university in a foreign country, does that need to be included in Other Support?
Question 2. Postdocs and Students
Are there any Dartmouth registered postdoctoral fellows or students involved in research for your lab supported in full or in part by any non-Dartmouth organization, institution, company, or government ("Entity") including fellowships?
If NO, move to question 3. If YES, you need to report on Other Support if involved in your research. Specific NIH FAQ may relate to Postdocs and Students:
NIH FAQ B. 7. If a PD/PI or other senior/key personnel is mentoring post-doc or graduate students who are individually funded through an outside institution (e.g. foundation, home university or Federal Agency), does that need to be disclosed as an in-kind resource in Other Support?
Question 3 In-kind Support *
Do you have access to "in-kind" resources in support of your research endeavors that are obtained through a collaboration, appointment, or relationship with an outside institution, organization, or company ("Entity")? Examples of "in-kind" resources include lab or office space, specialized equipment, research data, or materials
*In-kind Contributions: Non-cash contributions from external third parties.
If NO, move to question 4, If YES, you will need to include In-kind support in Other Support and also, if related to an external appointment include on your Biographical Sketch accordingly. Per NIH Other Support Instructions: In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.
Specific NIH FAQ may relate to In-kind resources from outside entities:
NIH FAQ C1 Do in-kind contributions that will be used for the project being proposed need to be included in Other Support?
NIH FAQ C2. If an in-kind contribution is listed in Facilities and Other Resources or Equipment, does it also need to be included in both Other Support?
NIH FAQ C 3. For in-kind resources that do not have any associated effort, can researchers enter zero effort?
NIH FAQ C 4. How should researchers list materials (e.g., data, samples, etc.) received from external collaborators on Other Support?
NIH FAQ C 5. Does completed in-kind support need to be included in Other Support?
NIH FAQ C 6. Do applicants and recipients need to disclose unpaid volunteers working in a lab as Other Support?
NIH FAQ C 7. When disclosing materials received from external collaborators on Other Support how far back in time should recipients go? Should materials provided 20 years ago be disclosed, if they are still in use?
Biosketch Reminders. If your access to in kind resources are obtained through an appointment, or relationship with an outside institution, organization, or company ("Entity"), you may need to include such appointment on your biographical sketch.
Foreign Components: If the in-kind support meets the definition of a foreign component, you may need to indicate as such in the application, RPPR or seek prior approval during the funding period. NIH definition of a foreign component:
NIH requires recipients to determine whether activities it supports include a foreign component, defined as: The existence of any “significant scientific element or segment of a project” outside of the United States, in other words
1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
2. 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.
See NIH FAQ II. 1. What is the definition of a foreign component, and has it changed?
Question 4 Affiliations & Appointments*
Do you hold a paid or unpaid appointment, position, or affiliation ("Appointment")
at any Entity other than Dartmouth?
*This includes unpaid Appointments such as "guest", "adjunct", "honorary", or "visitor" titles.
If NO, click to question 5, If YES, please review the information below and report accordingly and obtain and provide copies of any related contracts.
Per Notice No. NOT-OD-21-073 biosketches must include all current positions and scientific appointments* both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
*“Scientific appointments” may include appointments at any institution (regardless of the title of the appointment), where you are directly involved in any of the following activities:
- the design, conduct, or reporting of academic activities either independently or in support of someone at the other institution.
- providing advice for establishing research programs or laboratories.
- the preparation of proposals, progress, and final reports.
- assisting in the guidance or training of postdoctoral scholars, graduate, and undergraduate
or helping other researchers in attaining the goals of research projects
- Also report all appointments at foreign institutions given for the purpose of serving on a thesis committee or a peer review committee.
Foreign Appointments: Copies of contracts for SKP appointments/employment at foreign institutions will be provided as described below. Per Other Support instructions:
For Other Support submissions that include foreign activities and resources, recipients are required to submit copies of contracts, grants, or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation. If they are not in English, recipients must provide translated copies.
The supporting documentation must be provided as part of the Other Support PDF following the Other Support Format page. See NIH Other Support page for forms, instructions, and other resources.
NIH Other Support FAQ that relate to positions and appointments:
NIH FAQ B 11. I am a Principal Investigator on an NIH award to a domestic university and have an unpaid appointment at a foreign university. At the foreign site I have access to lab space, research materials, and staff. Should I report this as Other Support?
NIH FAQ B 13. A researcher at my institution has a 9-month appointment. They spend two months at a University outside of the United States during the summer conducting research under a foreign award. Does this count as Other Support?
NIH FAQ D 1. What types of foreign contracts are applicants and recipients required to submit with Other Support?
Question 5. Outside Research Roles -
Except for proposals or awards processed through Dartmouth as subcontracts, has another institution identified you as the PI, Co-PI, investigator, or other key personnel on a project (proposed or awarded)?
If NO, proceed to Question 6, If YES, this is an unusual situation and issues related to commitments should be discussed with the Office of Sponsored Projects.
Question 6 Outside Programs & Activities - Are you involved in a non-Dartmouth program or activity that provides you with compensation, research or office facilities, sponsored or reimbursed travel, honorary funding, or any type of benefit in exchange for teaching or mentoring students, performing research for another institution, or publishing research results naming your affiliation at the other institution ("Outside Activity")?
If NO, proceed to Question 7, If YES, this is an unusual situation and issues related to commitments should be discussed with the Office of Sponsored Projects.
Question 7 Personal Financial Interests
Have you personally received any payments ("Financial Interest") (e.g., salary, consulting fees, stock/stock options, honoraria, gifts, or sponsored or reimbursed travel) from a non-Dartmouth entity that will be used to support your research endeavors?
If NO, skip to summary on completing Other Support.
Report accordingly on Other Support. A Personal Financial Interest must be disclosed in Other Support only if personal financial interests are used to benefit your own research endeavors.
Report in Dartmouth's Conflict of Interest system as part of your financial interest disclosure Information concerning Dartmouth's COI Policy and reporting system can be found at this link.
Summary to Complete NIH Other Support
If any of answers to questions 1 to 7 above are yes and you need additional guidance from OSP, please don't hesitate to contact us.
1. Use NIH Format. Follow NIH instructions and use current format page which can be found at this link.
2. Disclose ALL active and pending sources of Other Support including items flagged in questions 1 -7 and also:
- All active and pending grants, whether or not they are based at Dartmouth
- Internal awards in direct support of a specific research project (e.g. internal pilot award)
- General start-up/reserve funding from Dartmouth
- Institutional resources, such as core facilities or shared equipment that are made broadly available, which should be listed in Facilities and Other Resources
- Non-research consulting activities
- Training awards
- Gifts, which are defined as “resources provided where there is no expectation of anything (e.g., time, services, specific research activities, money, etc.) in return.” Under NIH guidance, “[a]n 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 such.”
3. Provide to OSP copies of contracts, grants or any other agreement specific
to senior/key personnel appointments and/or employment for a foreign institution to be submitted as part of the Other Support PDF
–If not in English, copies must be translated
4. Sign Other Support:
- Each person to electronically sign their own Other Support
- Wet/Scanned signatures WILL NOT be accepted by NIH
- OSP recommends using Adobe sign.
- Adding signature image in Word document is not verification
5. Send completed and signed Other Support pages to OSP for record keeping and submission to NIH (for subawards also send to OSP prior to submission to prime grantee institution)