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OSR Science and Security Training

Introduction to Guidance on Science and Security

Collaborations are often the cornerstone of success in the research community and the University remains strongly committed to that idea by encouraging and supporting collaborative efforts worldwide. Concerns have been raised by Federal entities that certain international activities have begun to threaten the integrity of the U.S. research enterprise and they are taking steps to ensure more transparency and better security of confidential information and scientific data.

These concerns are commonly referred to as “Science and Security”. Another name you may have heard, used often by the media, is “Foreign Influence”. It is important that all faculty and staff understand these concerns and the impact on the research efforts at the University. To that end, the Office of Sponsored Research has provided the following information.

Last updated: 06/23/2021

National Institutes of Health (NIH)

National Science Foundation (NSF)

Department of Defense (DoD)

Department of Energy (DoE)

National Aeronautics and Space Administration (NASA)

Last updated: 04/01/2020

Primary Concerns

  • Perceived Failure by Researchers to Fully Disclose Available Resources
  • Sharing of Confidential Information in the Peer Review Process
  • Loss of Intellectual Property

Direct Impacts to Research Enterprise

  • Increased scrutiny of university and researcher activities by Federal agencies
  • Various Federal agencies are coming out with their own guidelines regarding Science and Security
  • Lack of detail in the new or clarified Federal guidelines, particularly those from NIH

Current Impacts to Proposals / Projects

  • Clarified Requirements for NIH Other Support documents
  • Increased Expectations for capturing updated information on RPPR’s
  • Greater scrutiny over the use of foreign components and the requirement to get prior approval if award is active
  • Greater scrutiny of intellectual property terms during negotiations involving international sponsors

Targeted or Sensitive Research Areas

The following areas of research have been identified by the Federal Government as areas facing potential security threats:

  • Information technology
  • Energy-efficient and new-energy automobiles
  • Computer numerical control machine tools and robotics
  • Electric power equipment
  • Aerospace Equipment
  • New and Advanced Materials
  • Marine engineering equipment and high-tech ships
  • Biomedicine and high-performance medical instruments
  • Advanced rail transportation equipment
  • Agricultural equipment
  • Artificial intelligence and machine learning technology
  • Position, navigation, and timing (PNT) technology
  • Microprocessor technology
  • Advanced computing technology
  • Data analytics technology
  • Quantum information and sensing technology
  • Logistics technology
  • Additive manufacturing (e.g. 3D printing)
  • Brain-computer interfaces
  • Hypersonics
  • Advanced surveillance technology

Last updated: 06/23/2021

Other Support Documents

UPDATE: NIH has new requirements and templates for Other Support and Biosketch information that will be required beginning January 25, 2022. We encourage you to begin using them now. Please click here to view the latest training update.

NIH has clarified the requirements for Other Support. They include ALL resources made available to a researcher in support of and/or related to ALL their research efforts.

Financial Resources

  • Your externally funded active and pending awards, including those made directly to UNC-Chapel Hill by a Federal agency or made by another entity using Federal funds (e.g. active and pending direct awards, incoming subcontracts, pilot project funding provided by NC TraCS Institute, etc). Be sure to include both domestic and foreign awards and use TOTAL budget.
  • Funded service agreements to the University that involve you, because the funding organization must report these to the federal government through Open Payment disclosures.
  • Your funded external activities that directly impact your research or are research related. Federal guidance in this area continues to change so we recommend including research-related funding, even if the funds aren’t used to directly support your research, to be fully transparent.
  • Financial resources provided to another party in support of your research or research project (e.g. a grant to another University who donates some of the funds to you for specific use in your project).
  • Your startup funds provided by an entity other than UNC-Chapel Hill.

NOTE: NIH no longer requires gifts to be reported but you MAY report them if you want, especially if the gift directly subsidizes your research in some way. NIH also no longer requires you to report training grants or prizes.

In-Kind Resources

  • Lab or office space that you use outside of UNC-Chapel Hill to conduct research (e.g. a lab at a pharmaceutical company or other University). UNC-Chapel Hill resources should be placed in the Facilities and Other Resources section of your application.
  • High value scientific materials that are not publicly available and are given to you or your project for use in your research (e.g. drugs, mouse lines, assays, etc.). NIH has not defined “high value” so err on the side of caution. This includes materials provided to another party in support of your research or research project (e.g. free drugs provided to one of your collaborators who then provides them to you).
  • Collaborators whose efforts support your research in some way. If you have many collaborators, you may use a summary statement to describe them. See the example in the FAQ section on the OSR Science and Security webpage noted in the links section of this presentation.
  • Visiting Faculty/Scholars/Scientists/Post-Docs whose efforts support your research, regardless of funding sources, and undergraduate and graduate students whose efforts directly support your research but whose salary isn’t paid by your projects or who aren’t paid at all.

NOTE: Any domestic or international position you hold, including honorary, adjunct, or others should be placed in your biosketch, including those related to external activities.

Resources provided to another party in support of your research or research project(s)

The responsibility for the accuracy of your Other Support lies with YOU and you alone.

NOTE: Per the new NIH requirements that take effect on January 25, 2022, you will have to certify your Other Support document via signature, provide supporting documentation in certain situations, and alert your central research administration when your Other Support information changes so they can notify NIH.

UNC Templates and Resources

General

NSF has officially issued its Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 22-1), which includes new Biosketch and Pending and Current Support (aka Other Support) requirements, increases the biographical sketch page limit to three and adds the NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support. This new PAPPG will become effective on October 4, 2021.

NSF has designated the National Institutes of Health’s SciENcv (Science Experts Network Curriculum Vitae) as an NSF-approved format for submission of biographical sketch(es) and is encouraging its use to prepare a biographical sketch for inclusion in proposals to NSF. More information can be found here.

NSF released the JASON Report in December 2019, which provides a comprehensive overview of fundamental research security risks and makes recommendations for ways to improve security without compromising the inherent goals of fundamental research.

Due to the COVID pandemic, NSF has chosen to delay the new PAPPG requirement to use their designed Biosketch and Current and Pending Support formats until October 1, 2020. All other requirements outlined in the June 1 PAPPG release remain in place.

Current and Pending Support

Your NSF Current and Pending Support document now needs to include ALL resources made available to you in support of and/or related to ALL your research efforts. Responsibility for the accuracy of your Current and Pending Support lies with you and you alone.

Financial Resources

  • Your externally funded active and pending awards, including those made direct to UNC Chapel Hill by a Federal agency or made by another entity using Federal funds (e.g. incoming subcontracts). Be sure to include both domestic and foreign awards and use TOTAL budget.
  • Funded service agreements to the University that involve you, because the funding organization must report these to the federal government through Open Payment disclosures.
  • Your funded external activities that directly impact your research or are research related. Federal guidance in this area continues to change so we recommend including research-related funding, even if the funds aren’t used to directly support your research, to be fully transparent.
  • Your startup funds provided by an entity other than UNC-Chapel Hill.
  • Gifts given to you or UNC Chapel Hill that are used to support your research and require specific obligations and staff time commitments.

In-Kind Resources

  • The same types of in-kind resources listed in your NIH Other Support should also be used in your NSF Current and Pending Support though where they are placed in the NSF Current and Pending Support differs depending on how the resource is used. See below:
    • If the In-Kind contribution is NOT specifically related to the proposed project AND has associated staff time commitment, you must report it in the Current and Pending Support section.
    • If the In-Kind contribution IS specifically related to the proposed project, regardless of staff time commitment, you must report it in the Facilities, Equipment & Other Resources section.

NOTE: Any domestic or international position you hold, including honorary, adjunct, or others should be placed in your biosketch.

On February 1, 2019, DOE issued a memo mandating that “DOE federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.” These requirements (italicized and underlined), as listed below, are excerpted directly from the DOE terms:

  • Individuals that worked on project, with the following information:
    1. Provide the name and identify the role the person played in this project.
    2. Indicate the total number of months (including partial months) (Calendar, Academic, Summer) that the individual worked on this project.
    3. Identify the person’s state, U.S. territory, and/or country
    4. Have other collaborators or contacts been involved?

The Department of Education is currently updating their Section 117 guidance and receiving feedback from various organizations. No release date for the updated guidelines has been announced yet. These guidelines apply to organizations, not individuals.

The Department of Education has released new guidance regarding their Section 117 reporting that organizations must complete. For those interested, more details can be found here.

Last updated: 05/25/2021

What steps is the University taking in response to the Science and Security issue?

The Vice Chancellor for Research Office has issued guidance to campus and established a dedicated website. A National Security Working Group has also been convened with cross-university membership. OSR has also issued guidance to campus and established a dedicated website dedicated to their area of responsibility.

I’ve been hearing a lot about China’s Talent Recruitment Plans. What exactly are they? [Updated: 1/28/2020]

China’s aim is to be the world’s leader in science and technology (S&T) by 2050. To achieve its goal, China has implemented a government campaign to recruit talent and foreign experts from around the world. One way they do this is through approximately 200 different talent recruitment plans that have recruited over 7,000 participants. These participants are often foreign-trained scientists and experts who provide China access to know-how, expertise, and foreign technology, often before this knowledge and technology is ready to be released or published by the participants themselves.

Is the Thousand Talents Plan one of China’s talent recruitment plans? [Updated: 1/28/2020]

Yes, the Thousand Talents Plan is China’s largest and most successful talent recruitment program and is the one under the heaviest scrutiny by U.S. Federal Government agencies, including national security agencies. It is also of great concern to many other world governments.

Why does the government consider the Thousand Talents Plan a risk? [Updated: 1/28/2020]

Thousand Talents Plan (TTP) targets U.S.-based researchers and scientists, regardless of ethnicity or citizenship, who focus on or have access to cutting-edge research and technology. In addition, TTP contracts have language that differs from U.S. research values in many ways that can raise concerns. A few examples of this are:

  • they require the individual to observe relevant laws of China, which are often at odds with the laws of the U.S.;
  • they often indicate that all intellectual property rights are owned by China;
  • they encourage shadow labs in China where the researchers work can be performed by others;
  • they require the individual to serve in a prominent position within their research field;
  • they require the individual to recruit postdoctoral students into their labs;
  • they often require the individual to not disclose the relationship or contract to unrelated parties;
  • they often require the individual to not reveal the financial aspects of contracts to their U.S. employers;
  • they often require comingling the results of research they do as part of the talent plan vs the research they do in the U.S. creating overlap situations;
  • they require a significant time commitment and create conflicts of commitment.

I’ve been approached by a possible international visiting scholar who would like to work in my lab for a bit. What kind of information should I consider before submitting a request for approval? [Updated: 1/28/2020]

There are several questions that should be asked to help determine if a visiting scholar would be appropriate to work in a UNC lab. They include, but are not necessarily limited to, the following:

  • What country is the visiting scholar coming from?
  • What is the source of funding for the visiting scholar?
  • Is the visiting scholar or their organization on the Federal restricted list?
  • What activities in the UNC lab(s) are of interest to the visiting scholar?
  • What would the official scope of work be for the visiting scholar and how does it relate to projects already underway in the UNC lab(s)?
  • Will any UNC or UNC researcher intellectual property be used, shared with, or licensed to the visiting scholar’s University?
  • Will the UNC researcher be sharing materials, compounds, or data from their lab with the visiting scholar?
  • Will the visiting scholar bring any intellectual property, materials, or data with them?
  • Will the visiting scholar bring proprietary or controlled materials with them?
  • Will the visiting scholar have access to any proprietary or controlled information while here?
  • Will the visiting scholar have access to any specialized facilities on campus?
  • What agreements are needed to manage any of the exchanges noted in questions 6 through 11?
  • Are joint publications with the visiting scholar anticipated? If so, are all parties clear on that?
  • Which offices at UNC need to be informed of this relationship – e.g. who needs to approve the appointment, a visa, use of intellectual property, use of facilities, etc.
  • Are there UNC policies on visiting scholars and if so, is this request within the bounds of those policies?
  • What visas or other government approvals are required?
  • What training/orientation should be provided for the visiting and the lab regarding UNC policies? Regarding the role of the visiting scholar in the laboratory?
  • Is any research being done in in the UNC lab(s) that has restrictions on foreign nationals, publications, export control, etc.? Be sure to consider both internal and external-funded research when answering this question.
  • Will the visiting scholar be working on any NIH awards? If so, OSR needs to clear it through NIH first per their new requirements.

Also keep in mind that, under current NIH requirements, if the visiting scholar comes the UNC researcher will need to report that on their Other Support and may also have to report them on other Federally-funded proposal documents.

If I have questions about visas, should I talk to OSR or another UNC office?

Any questions regarding visas for students or scholars should be directed to the International Student and Scholar Services, a unit in UNC Global.

Are the talent programs run by the Chinese government the only talent programs that exist?

No, many countries offer various types of talent programs. One example is Russia, which offers what they call a Mega-Grant competition.

What is the definition of a data steward?

Current policies identify several different roles within data security, and data steward is one of those. This is someone who is assigned to oversee particular types of data within the University, for example, Lauren Grazia is the data steward for FERPA data.

Where is the social security number/information saved?

On the safe computing site, under protect University data you find the Data Protection purchasing guide. At the bottom of that page is a listing of the different data types; click on Social Security numbers and then it will list those that have been approved.

Is it true that there may be more federal requirements for Universities related to Science and Security?

Yes. Currently there are several Congressional legislative acts working their way through the process that may affect Universities. The OVCR and Federal Affairs office are monitoring these carefully and will provide updates to campus when appropriate.

What if NIH determines that an institution is not complying with NIH policies for transparency and disclosure of Other Support?

NIH takes the issue of protecting the integrity of U.S. biomedical research seriously. When issues of non-compliance are identified, NIH will take one or more actions, depending on the severity and duration of the non-compliance. This may include withdrawing approval of the Program Director/Principal Investigator or other researchers contributing to the NIH award, imposing specific award conditions, disallowing costs, withholding future awards including the possibility of suspending or terminating the award.

Is the total budget reported for the current budget period or for the whole project period?

The total budget should be reported for the entire project period.

How do we report grant involvement where someone is a mentor on a grant where their effort is listed as zero calendar months?

Typically, on your other support document, you’re only reporting individuals that have measurable effort. So, this individual would not be included as a mentor.

If a vendor is located in a foreign country and materials are purchased from them, but there is not a subagreement in place would that still be considered a foreign component?

It would not be considered a foreign component; it would just be a vendor purchase to provide materials for the project. The key is that you are paying for the materials.

A PI has transferred institutions and is bringing equipment with them that were bought with startup funds at their previous institution, would we consider that to be in-kind?

OSR would not consider that to be in-kind, because once the equipment is transferred it becomes UNC property. It could be put under the facilities and resources section instead of the Other Support, because once it’s absorbed into the University then it becomes a University resource.

One of my faculty members has a permanent study section appointment for which she receives a payment. Should this appointment be listed on the NIH Other Support or Biosketch document?

Since NIH will be aware of any payments made to study section appointees, this appointment should be listed on the Biosketch document.

I have already reported this information as a Conflict of Interest (COI). Do I still have to include the information in the Other Support section?

Yes. Some situations (gifts of dollars, materials or paid teaching) that are reported as possible COIs may also have to be included as other support as defined by the sponsor. In COI, the University is trying to determine if the financial or personal interest could affect or create some bias in the research. Then the University reports its determination.

For Other Support, the federal sponsor is looking at the total scope of your commitments and what resources, either from the University or elsewhere, are contributing to all your research.

Who can I ask about what needs to go into an Other Support document?

You can consult with OSR or the Sponsored Programs Office (if you’re a School of Medicine employee).

I have hundreds of collaborators I work with. Do I really list all?

In situations like this, we recommend a summary approach. Instead of listing all the collaborators, summarize them into groups with relevant details for each group and a promise to provide full details upon request. For example, you might say:

“Prevention Trials Network Collaboration: 20 sites involving 12 domestic institutions and 8 foreign institutions, approximately 150 investigators in total, considered collaborators because we share ideas and data that directly benefits my research. Full details can be provided upon request.”

Are personnel named on the proposal considered collaborators?

No, if they are named in the proposal, they are not considered collaborators.

Do I have to list UNC in-kind space/lab resources under Other Support since I already list them in the Facilities and Other Resources page?

No. If you’ve already listed UNC in-kind resources in the Facilities and Other Resources section, you do not need to list them in your Other Support.

Do I need to list the space/lab resources of my subcontractors on my Other Support?

No, because your subcontractors are considered part of your “project team” and not a specific resource to you.

If I am performing work under a University approved EPAP, do I need to report my income for that work on my Other Support? [Updated: 04/16/2020]

Yes, if your external activity directly impacts your research. Federal guidance in this area continues to change so we recommend including research-related funding also, even if the funds don’t directly impact or support your research, to be fully transparent.

Are Co-Authors on publications automatically assumed to be collaborators for Other Support purposes?

No, they aren’t. A researcher should determine if their working relationship with the co-author benefited any of their research (not just the project in question) and if so, they should include them, their institution, and the nature of the collaboration. If they didn’t but were listed on the publication for a different reason (perhaps because they mentioned a post-doc and reviewed their science), then they would not need to be considered a collaborator.

Are startup funds to be listed as Other Support?

Yes, BUT only if they were received from an entity other than UNC-Chapel Hill.

Are internal university grants to be listed?

Yes. NIH now defines Other Support as all resources in support of all research for an investigator, irrespective of whether the resource is provided through the applicant organization or an outside entity.

Are service agreements considered part of Other Support?

If the duties of the service agreement are being performed as part of a University sponsored project, then yes. If they are being performed under a University-approved EPAP, then no.

When I should I notify NIH that my Other Support information has changed?

That depends on the timing of your Other Support changes. If the changes occurred shortly after a JIT request was received for one of your applications, you should work with OSR or SPO to send an updated Other Support to NIH as soon as possible. If it occurred during an active award period, you can update it when you submit your RPPR unless the changes are significant.

Has NIH expanded the applicability of the Other Support policy?

Yes, with the release of Notice NOT-OD-21-073, NIH has changed the Other Support requirements. Please click here to see the latest training update.

What does NIH evaluate when reviewing Other Support submissions?

NIH scientific program and grants management staff review Other Support information to ensure that:

  • All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
  • Sufficient levels of effort are committed to the project
  • There is no scientific, budgetary, or commitment overlap
  • Only funds necessary to the approved project are included in the award

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?

Yes. While the researcher is not receiving monetary compensation, the lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts.

I am key personnel on an NIH grant in the United States. I am collaborating with another scientist in the US, whose experiments have directly benefitted my research. Their experiments were conducted with funds awarded to their institution. Should this be reported as Other Support?

Yes. Other Support includes domestic research collaborations that directly benefit the researcher’s research endeavors.

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?

Yes. Available resources in support of and/or related to an investigator’s research endeavors should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period.

What should I do if I’m not sure if something needs to be included as Other Support?

In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.

If you have a visiting scholar that was on the grant in years one and two, if the visiting scholar is not on the project for year three, do we report this on the RPPR?

If you didn’t report the visiting the scholar in the previous RPPR’s, you should just place a note on the current RPPR letting NIH know that you had a visiting scholar working on the project previously, who they were, and what their role was.

Should the PI submit their revised other support immediately or should they wait until the RPPR?

NIH says that if there are significant changes they want us to provide updated documents as soon as possible. If they are not significant, we can do it at the RPPR stage. The researcher should be the person responsible for defining if the change is significant as only they would know whether the change is significant to their research or not.

Should the resources, both foreign and domestic, be written out for each active award or can they be summarized in one section?

This is captured in the new/updated Other Support template, in which there is a separate section where you can identify those elements.

RPPR Other Support documents historically have only included active grant funding not pending projects. Has this changed or are pending projects now required to be listed?

That has not changed. Our sample template is designed for a JIT submission but can be used for RPPR’s also by removing the pending section. Be sure to modify it for any other unique requirements NIH has for your RPPR also.

Do we have to include domestic and foreign sections for the RPPR?

Yes, you should include both domestic and foreign information in your RPPR. Using our sample template, with the pending section removed, will make that easier for you.

If there is an unpaid intern on the agreement who only works for a specific time, how long should they be reported on the RPPR?

OSR recommends going back one to three years for students and collaborators of that nature. But we’re allowing the researcher to make the final determination because we don’t have definitive guidance from NIH.

NIH recently updated their Other Support template, but it looks like it does not capture their new requirements. Is that true?

The changes NIH made in 2020 did not capture their new requirements. However, the newest change made in 2021, which will be required beginning January 25, 2022, does incorporate the new requirements.

For faculty whose support often fluctuates from month to month due to the nature of their role on a project (e.g. biostatisticians who work heavily when data is ready to be analyzed but might be more idle at other times), should we continue to list projects on their Other Support that they are key personnel on but are currently a 0.0 FTE on the project?

Yes, you should still list those projects on their Other Support since they are an official member of the research team.

Added 05/25/2021

How long is an Other Support document valid for once it has been signed and dated?

The Other Support document is considered a “living document” meaning is it constantly updated. The document is valid if the information continues to remain accurate. When the document is submitted to the NIH it is a “snapshot” of information that is to be accurate on the day it is submitted.

Why are supporting documents not required according to the NIH Other Support instructions page?

The NIH instructions do not use an asterisk to identify required items, but they do state the following for supporting documentation:

  • Provide copies of contracts/grants/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts are not in English, individuals must provide translated copies.
  • Supporting Documentation should be provided as a PDF following the Other Support form.

Will the 3-page limit for K awards still be in effect?

The current version of the Career Development Instructions for NIH and Other PHS Agencies still indicate each mentor/co-mentor(s)’s “Current & Pending Support” attachment is limited to 3 pages. Until this changes, the page limit is still in effect.

If the 3-page limit for K awards is still in effect, what aspects of the new format must be included and what can be excluded?

The NIH has not provided any guidance on what should be included and can be excluded. Consider reasonable transparency and focus on including information that will support the candidate.

The NIH Other Support Format page shows a two-column table to be used for Person Months. Can I include effort information in the rows of the completed budget period, or do I have to remove the information?

Because the NIH Other Support Instruction page states “… for the current budget period and indicate the proposed level of effort for each remaining budget period …” the instructions do not talk about completed budget periods. UNC-CH will accept effort tables that either include or do not include information in the completed budget periods.

If an award, such as an equipment award, provides zero dollars for salary support, do we still include the award in the effort table?

Yes, the Person Month section is indicated as a required field. Zero person months would be used to indicate no effort.

  • Do not confuse “salary support” with “effort devoted” to the project.
  • Remember, UNC has a minimum effort requirement for a PI of 1% (0.12 Calendar Months) of effort on most sponsored projects.

When the Investigator’s salary is above the salary cap or a department chooses to cost share some of the salary, should the amount above the cap or cost shared be reported as in-kind Support when effort is devoted to an award?

No, payroll above salary cap or voluntarily cost-shared is NOT considered in-kind Support.

My clinical trial is active, but we have not accrued patients yet and have not charged any investigator effort to the salary category of the Project ID. Should we list zero calendar months of effort?

Do not confuse “salary support” with “effort devoted” to the project.

Have you devoted any effort to the clinical trial?

  • If so, you will have to provide the actual (not aggregate) amount of effort devoted to the project.

If an NIH grant has been through multiple renewals do we include the total amount awarded from all renewal segments awarded to date when listing the total award amount?

No, provide information for only the current ACTIVE competitive segment.

I expect the sponsor to reduce the PENDING award amount from what was proposed. Should I report the Total Award Amount of what was proposed, or should I report the estimated amount that is expected?

  • For the PENDING award, report the Total Award Amount proposed.
  • For an ACTIVE award, report the actual Total Award Amount from the Competitive Segment (project period) of the initial Notice of Award.

Both the “Project/Proposal Start and End Date: (MM/YYYY), if available, and Total Award Amount” (including Indirect Costs) include the term “Competitive Segment”. My NIH Notice of Award has a Budget Period Start Date – End Date as well as a Project Period Start Date – End Date. What period do we include for the term “Competitive Segment”?

Include only the ACTIVE “Competitive Segment”.

Will an updated version of the Other Support sample be available to the campus community via the OSR web site?

Yes, a sample of the completed template and the official NIH template, that takes effect on January 25, 2022, is available on the OSR Forms and Tools webpage in the Other Support and Biosketch section. While the new template is not required until January 25, 2022, we encourage individuals to transition to the new template now.

The new Other Support sample document contains headers and footers. Is this new and should we include the header and footer in our updated Other Support document?

No, do not include the header and footer in your updated other support document.

Should the Other Support overlap statement include future years of the grant or just the current year?

The overlap statement should address ANY potential overlap for the entire award.

Does the updated format change constitute a change in active other support that must be reported on the RPPR?

No, the updated format change does not constitute a change in the active other support and does not require reporting on the RPPR.

With the changes to Other Support requirements are there any differences between what is reported for JIT versus what is reported on an RPPR? Will we only include Active and Pending when submitting Other Support for JIT and will we only include Active and Completed when submitting Other Support for an RPPR?

No. Whereas prior to the recent change, only active and pending support were included on JIT and active and completed on the RPPR, now under the NEW Other Support Format Active, Pending and Completed Support (completed within the past three years) for all senior/key personnel are required to be included.

  • This is good news as it means that the researcher will have to maintain ONLY one version of Other Support.

If a UNC faculty member is a Co-PI on a Multi-PI award and also the PI on the related incoming subcontract award, should the full amount of the prime and subcontract awards be included or just the incoming subcontract amount?

Only the amount for the incoming subcontract should be used in this case.

How many years of collaborative support should be listed on an Other Support document?

NIH has not given us a defined timeline. We recommend including ONLY ACTIVE collaborations. The definition of “active” in this case can be determined by the faculty member but if in doubt, please consult either SPO or OSR.

A collaborator section is not included in the new updated Other Support instructions and sample. Does this mean we no longer have to provide that information?

No, NIH has made it clear in other forums/presentations that they want to see collaborator information also so even though it is not on the new sample or instructions, it should be included.

I have an EPAP (External Professional Activity for Pay) that is from a university outside of the US. It’s not part of my UNC work. Do I need include as a foreign component to an active award?

No. Foreign components, as defined by NIH, are specific to the NIH-funded project. EPAPs, by their nature, are for activities that are not part of your UNC work.

The EPAP is not related to the current proposal. Do I need report it as a possible COI?

Perhaps. If you’re funded by NIH, you may need to report the travel based on the COI Travel Disclosure Decision Tree. If the EPAP overlaps in anyway with your current portfolio, you should report it to the COI Program so it can be evaluated.

I am the PI on a NIH grant to a domestic university. I have a visiting post-doctoral scholar/student in my lab, who works on my NIH grant and does all of his/her work in the United States. The scholar/student’s salary is paid by a foreign government. Is this a foreign component?

In general, no. The first step in determining whether research constitutes a foreign component is to evaluate whether a portion of the research is being conducted outside of the United States. In this case, all of the work is being conducted in the US, so there is no foreign component.

I am a PI on an NIH award to a domestic university. I will have a visiting scholar/student joining my lab whose salary will be supported by a foreign university. Do I need NIH prior approval before the scholar/student can work on my NIH funded research?

Since specific circumstances may vary, it would be best to discuss with your Grants Management Officer. Please contact your Sponsored Projects Specialist so they can coordinate a call involving you and the NIH Grants Management Officer.

I have a foreign visiting scholar/scientist/faculty/post-doc in my U.S. lab who is working on my research project. Is their work a foreign component? Does it matter who pays their salary?

No, because they are performing their work on your project in the United States. It does not matter who pays their salary; it’s based on where the work is being performed. However, they should be reported on your Other Support document.

I have a foreign visiting scholar who has gone back to his home country. I’d like him to still work on my project. Would their work be considered a foreign component?

If their work is determined to be a significant scientific element of your project, then yes, their work would be considered a foreign component and would require prior approval from NIH.

Do I need NIH prior approval to add a foreign component to an active award?

Yes. You’ll need to submit a prior approval request to OSR who will review it and send it to NIH. Work cannot begin on the foreign component until NIH approves it.

Do I need NIH prior approval before a foreign visiting scholar/scientist/faculty/post-doc can work on my NIH funded project?

It depends. NIH has requested that we discuss it with your Grants Management Officer first. In these cases, you should reach out to OSR with relevant information on the visitor and they will contact NIH on your behalf.

Are international co-authors on publications automatically considered foreign components of the project?

Mostly likely yes unless we can make a sound argument that the contribution of the co-author didn’t represent a significant scientific element (keep in mind that one of the examples “defining” that phrase is being a co-author on a publication tied to the project).

Does NIH consider foreign travel for consultation to be considered a foreign component?

No, they do not.

What is the definition of a foreign component, and has it changed?

No, NIH has not changed the definition of a foreign component. NOT-OD-19-114 reminds recipients that a foreign component is the performance of a significant scientific element of the NIH-supported project outside of the United States. Once 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. If both criteria are met, then there is a foreign component.

What are some examples of a “significant element of a project” when making determinations regarding a foreign component?

The recipient institution should evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. Some examples of activities that may be considered a significant element of the project include, but are not limited to:

  • collaborations with investigators at a foreign site anticipated to result in co-authorship
  • use of facilities or instrumentation at a foreign site
  • receipt of financial support or resources from a foreign entity

What is the NIH definition of a foreign institution?

NIH defines a foreign institution as an organization located in a country other than the United States and its territories that is subject to the laws of that country, regardless of the citizenship of the proposed PD/PI.

Does work being conducted in the United States ever count as a foreign component?

Generally, no. The first step in determining if an element or segment of an NIH-funded project constitutes a foreign component is to evaluate whether the work is being conducted in a foreign country. If not, then it is considered other support and must be reported. In all cases, recipients are encouraged to discuss specifics, in advance, with your Grants Management Officer regarding proper classification of Other Support and Foreign Components.

What is an example of an activity that is not a foreign component, but would meet the definition of Other Support? What is the difference?

This response is dependent upon specific details that surrounding the activity. For instance, one model could be that a PI on an NIH grant may have an appointment and a lab at a foreign university. The research being done at the foreign lab is unrelated to the PI’s NIH project. This would not qualify as a foreign component of the NIH research, as the foreign work is not part of the NIH-funded project. However, it is a resource made available to the researcher in support of their research. Therefore, it must be reported as Other Support.

How does the NOT-OD-19-114 impact the FCOI policy?

There has been no change to the FCOI policy. NOT-OD-19-114 serves as a reminder to the extramural community of the requirements that are outlined within 42 CFR Part 50, Subpart F, Objectivity of Research (the FCOI regulation), which specifies the requirements for investigators to disclose to their institution their significant financial interests. The requirement to disclose includes financial interests received from a foreign institution of higher education or the government of another country. This requirement is distinct from other support and foreign components.

As a researcher, do I have to file a report in response to Section 117?

No, the U.S. Department of Education’s Section 117 requirements are organization-specific requirements. The University has to file reports related to it but individual researchers do not.

Do we need to report internal awards for NSF?

Yes, you should report internal awards. NSF adopted the NIH definition and says that current and pending support should include all resources in support of all research, which includes both internal and external.

Last updated: 05/25/2021

To further assist researchers and research administrators in remaining informed about our shared responsibility to safeguard the security of our science and comply with federal requirements, OSR will begin a series of informational trainings on several topics in this area.

Format

OSR will provide a combination of computer based training (CBT) and live webinars to share information on Science & Security at UNC. This will include major areas of impacts, sponsor specific information and best practices.

Trainings

SessionDescriptionDateTimeFormat
Intro to Science & SecurityBackground on the development and renewed interest in foreign influence in research.April 9, 2020CBT
Other SupportUpdates and guidance on the changes in Other Support requirements.
Click here for the presentation.
April 9, 20202:00 - 3:00 PMWebinar Recording
Data SecurityThis presentation will focus on why securing unpublished and controlled research data is so important, will provide information on state and federal data security requirements as well as foreign travel tips, and provide a guide to Information Security resources available at UNC.September 24, 20202:00 - 3:00 PMWebinar Recording
Updated NIH Other Support and Biosketch InformationThis presentation focuses on updates in the NIH Notices that impose additional reporting requirements for the Biosketch and Other Support.May, 2021Presentation