What to Disclose to NIH about Senior/Key Personnel on Applications & Awards
Requirements for Disclosure of Other Support, Foreign Relationships and Activities, as well as Conflicts of Interest
Full transparency in NIH applications and throughout the life of an NIH grant is critical. NIH requires the disclosure of all research support including other support, foreign components, in-kind, and other resources. NIH uses this information when making its funding decisions to determine if the research being proposed is receiving other sources of funding that could be duplicative, has the necessary time allocation and resources to conduct the research. Additionally, NIH requires recipient institutions and investigators to comply with the requirements of 42 CFR 50, Subpart F, the Financial Conflicts of Interest (FCOI) Regulation. The information provided in the table below does not expand nor change the FCOI requirements outlined in the FCOI regulation nor have any changes been made to the regulations. Applicants and recipients can refer to the NIH Grants Policy Statement 4.1.10 Financial Conflicts of Interest.
Read further for more information on the National Institute of Health Website
Examples of What to Disclose to NIH about Senior/Key Personnel on Applications and Awards
Table 1: Recipients Must Report
| Type of Activity | Report in Biosketch / Application | Report as Foreign Component in Application | Obtain Prior Approval and Report as Foreign Component in RPPR | Report as Other Support (JIT) | Report as Other Support (RPPR) | Review for potential FCOI | |
| All positions and affiliations, including volunteer positions, relevant to the application | X | X If personal payments to the individual |
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| Relevant appointments at foreign institutions – even if labeled as “guest,” “adjunct,” “honorary,” with or without salary support | X |
X If personal payments to the individual |
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| The number of person-months devoted to projects, even if there is no salary support or direct personal payments to the scientist | X | X If new |
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| Income, salary, consulting fees, and honoraria in support of an individual's research endeavors | X | X If new |
X | ||||
| Participation in a foreign talent or similar-type programs | X | X If new |
X | ||||
| Ongoing and completed research projects from the past three years that the applicant wishes to highlight | X |
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| All resources and other support, both domestic and foreign, for ongoing research projects, including those conducted at a different institution | X | X If new |
X | ||||
| In-kind contributions from domestic and foreign institutions or governments that support research activities | X | X If new |
X | ||||
| Performance of any significant part of an NIH project outside of the US, whether or not funds are expended |
X | X If new |
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| Post-doc, student, or visiting scholar supported by a foreign government or institution | X | X If new |
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| Travel paid by a foreign institution or government over $5,000 per year | X | ||||||
| Financial interests received from a foreign Institution of higher education or a foreign government | X | X |