Dear Colleagues,
I am writing to provide you with important information about new federal government requirements regarding disclosure of all support for your and your colleagues’ research. This change will impact all individuals listed as Key Personnel (PI, Co-PI, Co-I and other Key Personnel) when requesting federal research funding. I have communicated with you previously about NIH and NSF disclosure requirements, and I am writing to you now as all federal agencies have begun requiring these disclosures.
Under newly-implemented federal law, all “covered individuals” on a project must disclose in all federal funding applications the amount, type, and source of all current and pending research support they receive or might receive – whether that support has already been received, is expected to be received at the time of the disclosure, or is pending (and thus not even certain).
Covered individuals are all people who contribute in a substantive, meaningful way to the development or execution of a project. Most funding agencies designate who they consider a “covered individual,” and JHURA and ORA maintain updated information on agency-specific rules. In general, any principal investigator or co-investigator and anyone who would qualify as “key personnel” are considered “covered individuals.”
Additionally, the federal definition of “research support” that must be disclosed is very broad, and means:
“all resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of (1) whether the source of the resource is foreign or domestic; (2) whether the resource is made available through the entity applying for a research and development award or directly to the individual; or (3) whether the resource has monetary value… [Research support] includes in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or students.”
This means that “research support” includes both resources that you receive through Johns Hopkins University and some resources that you may receive outside of a formal contract through JHU. For example, if visiting faculty or scholars who are supported by their home institution work in your lab on federally-funded research, that constitutes reportable support.
Finally, the federal government now requires all covered individuals to certify that they have been made aware of these disclosure requirements. You will complete this certification within the University’s proposal submission system.
JHURA and ORA have further information about the specifics of current-and-pending-research-support on their websites. In addition, members of the Provost’s office and the research administration offices are available to provide departmental briefings as needed. Thank you again for your compliance with federal laws and regulations.
Best,
Denis Wirtz, PhD
Vice Provost for Research
Theophilus Halley Smoot Professor of Engineering Science
| New Required NIH Other Support Disclosures Beginning January 25, 2022 |
| Beginning January 25, 2022 NIH will require all faculty to include disclosure copies of non-JH contracts related to foreign appointments and/or employment in their Other Support disclosures. Read the quick guide here. |
| Additionally, all faculty will be required to electronically sign their NIH Other Support disclosures using DocuSign beginning January 25, 2022. View step-by-step DocuSign instructions and watch the DocuSign training videos here. To access DocuSign, click here.
To request a new Research Admin DocuSign account for Other Support purposes, please email othersupport@jh.edu. |
| Click here to jump to JHU Guidance on NIH Proposals. |
Most federal sponsors require Senior and Key Personnel to report information about their Current and Pending, or Other Support, whether or not salary is received. “Other Support” may include resources and/or financial support, domestic or foreign, available in support of or related to a researcher’s research endeavors, regardless of whether they are awarded through Johns Hopkins, through another institution, or provided directly to the researcher.
Requirements vary by agency and funding opportunity. Check the funding opportunity announcement as well as specific agency policies and make sure information is complete, accurate, and follows sponsor guidelines.
Most sponsors also have specific requirements for the disclosure of Foreign Interests related to an investigator’s research endeavors. See the Foreign Engagement Page.
It is ultimately the responsibility of the individual researcher to ensure that the report of Other Support is complete and accurate to the best of their knowledge. Johns Hopkins researchers whose research is supported with federal funding should update and maintain their current and pending or other support documentation. Make sure to include all sources of support, foreign or domestic, including scholarships or fellowships. When in doubt, err on the side of inclusion when completing Current and Pending or Other Support documentation. Inform yourself of all sponsor requirements and follow all directions for content and format.
Review more detailed requirements for some of our major federal sponsors below.
Revised Grants.gov Application Guide Issued
NSF has published a revised version of the NSF Grants.gov Application Guide (NSF 21-084). Overall, the Guide has been updated to align with the changes to NSF’s Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 22-1). The Guide will be effective for applications submitted (via Grants.gov) or due, on or after October 4, 2021. If you have any questions regarding these changes, please contact your JHURA grants associate.
NSF Pre-award and Post-award Disclosures Relating to Biographical Sketch and Current and Pending Support
In an effort to provide the community with helpful reference information regarding pre-award and post-award disclosure information in the biographical sketch and current and pending support proposal sections, NSF has developed a disclosure table entitled, NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support, to identify where these disclosures must be provided in proposals as well as in project reports. Proposers and awardees may begin using this resource immediately to assist with completing the relevant proposal and project report sections. As a reminder, current and pending support information is used to assess the capacity of the individual to carry out the research as proposed, as well as to help assess any potential overlap/duplication with the project being proposed.
View the new table published January 10, 2022.
A revised Proposal and Award Policies and Procedures Guide (PAPPG) has been released with an effective date of October 4, 2021, and the disclosures table will be included in this revised version. As noted above, however, proposers and awardees may begin using this table immediately.
Current and Pending Support (Other Support) – Current and pending support information must be provided through an NSF-approved format for each individual designated as senior personnel on the proposal at the time of proposal submission. Current and pending support information includes all planned, pending and current projects and in-kind support that is either provided directly to the individual, or to the individual through their organization in support of that individual’s research endeavors. This includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they are in direct support of the proposed project or they have monetary value, such as in-kind support.
Examples of current and pending support include support provided through Federal, State, local, foreign, public or private foundations, non-profit organizations, industrial or other commercial organizations or internal funds allocated toward specific projects (such as Discovery Awards). When completing Current and Pending Support, the total award amount for the entire award period covered (including indirect costs) must be provided, as well as the number of person-months (or partial person-months) per year to be devoted to the project by the individual.
In-kind contributions such as office/laboratory space, equipment, supplies, employees, students that are intended for use on the project being proposed to NSF, must be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be replicated in the current and pending support submission. In-kind contributions not intended for use on the project/proposal being proposed also must be reported. If the time commitment or dollar value is not readily ascertainable, reasonable estimates should be provided.
In contrast to NIH, NSF does not consider a Postdoctoral Fellow who directly receives their own support as in-kind current or pending support.
If the project (or any part of the project) being submitted has been funded previously by a source other than NSF, information must be provided regarding the last period of funding.
Effective for all new NSF awards and funding amendments to existing NSF awards made on or after October 5, 2020, NSF has modified the Terms and Conditions of Award to include Article 38. Article 38 requires the disclosure of current support or in-kind contribution information that was not included as part of the proposal submission process. Institutions will have 30 calendar days of the identification to report undisclosed current support or in-kind contribution information using the “Other Request” category, in the Notification and Request Module, in Research.gov.
DOE Grants: Current and Pending Support – DOE has updated the requirements for disclosure of a variety of potential conflicts of interest or commitment, including participation in foreign government-sponsored talent recruitment programs. Current and Pending support is intended to allow the identification of potential duplication, overcommitment, potential conflicts of interest or commitment, and all other sources of support. The PI and each senior/key person and any proposed subaward must provide a list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; fulltime, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. All foreign government-sponsored talent recruitment programs must be identified in current and pending support.
For every activity, list the following items:
• The sponsor of the activity or the source of funding.
• The award or other identifying number.
• The title of the award or activity.
• The total cost or value of the award or activity, including direct and indirect costs. For pending proposals, provide the total amount of requested funding.
• The award period (start date – end date).
• The person-months of effort per year being dedicated to the award or activity
• Briefly describe the research being performed and explicitly identify any overlaps or synergies with the proposed research.
Current and pending support may be presented in a format developed for other agencies or generated by any software package, though SciENcv will facilitate submissions to other Federal sponsors.
See: FY 2021 CONTINUATION OF SOLICITATION FOR THE OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM
DOE Contracts: Disclosing support from “Foreign Countries of Risk”
For Department of Energy contracts, under Department of Energy Directive 486.1A (issued September 4, 2020), persons working on such contracts are required to fully disclose and, if necessary, terminate their participation in foreign government sponsored talent recruitment programs from “Foreign Countries of Risk.”
Contractor Personnel participation in any Foreign Government-Sponsored Talent Recruitment Program of a Foreign Country of Risk, as defined in Attachment 2, is prohibited. Contractor Employee participation in any Other Foreign Government Sponsored or Affiliated Activity is restricted.
The Directive further defines “Other Foreign Government Sponsored or Affiliated Activity” to include; faculty accepting employment with a foreign entity, accepting grant funding or other support (including in-kind support such as materials, space, or post docs), or accepting gifts from any “Foreign Countries of Risk.” Carefully review both the DoE Directiveand the DoE FAQs for more specifics.
Department of Defense – As part of the National Defense Authorization Act for FY 2019, the Department of Defense (“DoD”) was directed to ensure that academic institutions that participate in defense research and engineering activities have their key personnel make full disclosure of the following Other Support information:
•“A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
• Title and objectives of the other research projects.
• The percentage per year to be devoted to the other projects.
• The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
• Name and address of the agencies and/or other parties supporting the other research projects.
• Period of performance for the other research projects.”
All DoD Notice of Funding Opportunities for research and related activities will require that you disclose this information at the proposal stage. The information should cover all previous (award period ending within the past 5 years), current and pending other support. You should identify where there is possible overlap between the proposal you are submitting, and the above other support.
Supporting References:
DoD Grant Submission Instructions–See Page 14
DoD Memorandum: Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies, March 20, 2019
Last Updated: 11/24/2021
NIH Notice Published 5/5/2021: The NIH issued a notice on May 5, 2021 that updated biosketch and other support format pages and instructions are available for use in applications, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs).
Use of the new format pages is preferred immediately and required for due dates and submissions on or after January 25, 2022 (NOT-OD-21-110). This represents a change from the original May 25, 2021 requirement date for the updated formats and other support signatures. Applicants and recipients can use this time to align their systems and processes with the new formats and instructions (see the JHU NIH Guidance section below for more details). Failure to follow the appropriate formats on or after January 25, 2022 may cause NIH to withdraw applications from or delay consideration of funding.
Applicants and recipients remain responsible for disclosing all research endeavors regardless of the version of the forms used, including:
Please consult the original Other Support FAQs for additional guidance on what needs to be disclosed.
Coming soon.
Last Updated: 5/11/22
If you are submitting an Other Support document to NIH, you may find this annotated version of the NIH Other Support form helpful.
Last Updated: 12/3/2021
We are writing to update you on two upcoming changes to the NIH Other Support disclosures. First, as explained below in an email to faculty that was distributed yesterday, beginning on January 25, all faculty must include in their Other Support disclosures copies of non-JH contracts related to foreign appointments and/or employment. The faculty email below and an earlier email to Vice Deans *Forthcoming NIH Requirements Related to Other Support Disclosures explains the process by which such contracts will be (1) submitted by faculty to Vice Deans, (2) reviewed by Vice Deans, and then—if the activity is approved—(3) included in Other Support packets and transmitted by you and your teams to JHURA.
Second, as explained below, beginning on January 25 all faculty will be required to electronically sign their NIH Other Support disclosures using DocuSign. We are currently working with IT, the Office of General Counsel, and others on the process by which this will be operationalized. We will circle back with more details very soon.
JHURA will soon announce Q & A sessions to be held later this month/early January to answer any questions you may have. In the meantime, please contact us if you have any questions.
ast Updated: 10/5/2021
This message addresses the Implementation of Changes to the Biographical Sketch and Other Support Format Page (NOT-OD-21-110).
For all applications and submissions on or after May 25, 2021, JHURA and School of Medicine ORA will require the use of the new NIH Other Support and Biosketch forms, without the new signature/certification requirement. The signatures/certifications will not be required from all JHU faculty until January 25, 2022.
While NIH is not requiring use of the new Other Support and Biosketch forms until January 25, 2022, applicants are still responsible for capturing all of the necessary information set forth in their original notice (NOT-OD-21-073).
JHU has decided to delay implementing the NIH signature requirement for the Other Support page; however, all investigators remain personally responsible for the accuracy and completeness of their Biosketch and Other Support disclosures on all submissions, including proposals, JIT requests, and RPPRs.
In addition, investigators should ensure that all agreements that relate to any foreign appointment or an item listed on the Other Support page have been reviewed and approved by their Dean’s Office prior to being included in the Other Support. JHURA will not include any agreement that has not been vetted through the investigator’s Dean’s Office, but NIH may request such documents. Therefore, please be sure that all outside appointments and related agreements are on file, translated, and ready to be submitted to NIH upon request.
Information about each school’s process for reviewing foreign appointments may be found here.
Please consult the original NIH Notice and FAQs, as well as JHU’s Current and Pending Support page for additional guidance on what needs to be disclosed.
Please contact your research administration representative with any questions.
JHU NIH Proposal Preparation Instructions
March 19, 2021
Biosketch:
1. List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application 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). Please note that all affiliations should be disclosed to the administrative leadership of your Schools through the processes found here. Even if you have previously disclosed an appointment through eDisclose, you should follow this process.
2. Provide copies of the agreements associated with foreign appointments and attach to the Biosketch document in the for submission to NIH. This includes copies of contracts, grants or any other 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, grants or other agreements are not in English, translated copies must be included in the submission to NIH. You may use a machine translation service to translate the document.
Other Support:
All pending support at the time of application submission and prior to award must be reported using “Just-in-Time Procedures” by providing all information indicated above. JHU is responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award and all changes during the life of the award, including “Other Support” changes that must be assessed for budgetary or scientific overlap. Specifically, report the following:
1. All resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts.
2. All current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates. Note that any visiting post doctoral fellows or visiting scholars who are funded directly by a foreign source must be approved in advance in accordance with the JHU Visitor’s Policy and disclosed to NIH as Other Support.
3. The total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.
Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”
NIH has provided a sample Other Support form for reference.
Consult updated NIH Frequently Asked Questions (FAQ’s) on Other Support and Foreign Components
Dear Faculty Colleagues:
Beginning January 25, 2022, the NIH is implementing two changes to Other Support disclosures. As a reminder, Other Support must be disclosed at Just-in-Time when submitting K and T grants, as part of progress reports, and as otherwise required under specific funding programs.
First, you must submit to NIH copies of any contracts that are related to your foreign academic appointments. These contracts must be in English or include an English translation. All divisions have instituted a formal process, explained on the JHU Research website, for the review and approval of such appointments. You should provide your contracts alongside the relevant request form as part of that approval process. Once the appropriate vice dean has reviewed your submission and approved the external academic appointment, they will communicate that approval to you; you must then include the relevant contracts in your Other Support materials.
Second, you must electronically sign your Other Support disclosures prior to submitting to ORA or JHURA. JHU will be utilizing DocuSign for this electronic signature requirement. Further information about this requirement will be forthcoming soon.
At this time, the requirement to provide copies of contracts and an electronic signature applies only to NIH awards. It is possible, however, that other federal funding agencies may follow suit; we will update you if and when that happens. Other funders have already taken different measures to address foreign influence concerns, including NSF (by expanding the grant-related reporting requirements) and DOE (by prohibiting DOE-funded investigators from participating in foreign talent programs). Up-to-date information on these additional measures is available on the JHU Research website at the link shared above.
Finally, and as has been previously communicated to you, the NIH’s expectations with regard to Other Support disclosures have been evolving beyond the two changes articulated above. To aid in your decision making about what to include in Other Support, the university has prepared a FAQ webpage related to these changes. It is posted on the university’s website about Other Support. To the extent that your question is not resolved after reading the FAQ, please feel free to contact your divisional vice dean.
Best,
Denis Wirtz
Vice Provost for Research
Jon Links
Professor, Vice Provost, and Chief Risk Officer
*Please note that you must be connected to the JHU VPN to view the document “Forthcoming NIH Requirements Related to Other Support Disclosures”.
Dear Colleagues:
It is important that all university faculty carefully manage your academic identity so that others can find and see your work. This has become even more important as investigators are facing additional scrutiny on the completeness and accuracy of other support and biosketch disclosures. Federal agencies are increasingly asking for information so that they can accurately assess:
An effective approach to ensuring accurate disclosures while reducing burden is the use of digital persistent identifiers (DPIs), particularly the ORCID identifier (Open Researcher and Contributor Identifiers). ORCID iDs can simplify investigator reporting by saving time, ensuring accuracy, and improving the tracking of career outcomes. These unique identifiers distinguish individual investigators and can be used to connect researchers with their contributions to science over time and across changes of name, location, and institutional affiliation.
These free identifiers are assigned and maintained by the nonprofit organization ORCID. ORCID maintains a registry of unique personal identifiers, helping researchers ensure that articles, chapters, books, datasets, conference proceedings, and other research products are accurately and correctly attributed. ORCID is a widely used persistent identifier, trusted by institutions of higher education, publishers, and funders.
The JHU Provost’s Office strongly recommends faculty use ORCID for this purpose, and we anticipate that NIH and NSF will require the use of ORCID at some point.
Starting in 2017, NIH has provided investigators the option to associate an ORCID identifier with their eRA Commons Personal Profile. Since September 2020, NIH, AHRQ, and CDC have taken an additional step by requiring that individuals supported by research training, fellowships, research education, and career development awards have ORCID iDs.
ORCID iDs save time and assure accuracy when applying for research grants by feeding information to SciENcv: Science Experts Network Curriculum Vitae, which is a researcher profile system for all individuals who apply for research awards. This past October, NSF approved the use of SciENcv to create an NSF Biosketch for proposal preparation. In addition, NIH is finalizing the SciENcv template for other support and anticipates that the template will be available beginning in FY2022.
If you already have an ORCID iD, please keep it updated. You should also link your ORCID iD to JHU to prepare for possible future integration with local systems. If you haven’t registered yet, please follow the directions below.
Use the link ORCID with JHU and these directions to link your ORCID to JHU.
JHM Welch Library has additional resources including this video on using ORCID. For more information on research profiles, including ORCID, see this page.
If you have questions, please contact Jaime Blanck at the Welch Medical Library or Robin Sinn at the Sheridan Libraries.
Sincerely,
Denis Wirtz
Vice Provost for Research
Andrew Douglas
Vice Provost for Faculty Affairs
Last Updated: 10/5/2021
This message addresses the Implementation of Changes to the Biographical Sketch and Other Support Format Page (NOT-OD-21-110).
For all applications and submissions on or after May 25, 2021, JHURA and School of Medicine ORA will require the use of the new NIH Other Support and Biosketch forms, without the new signature/certification requirement. The signatures/certifications will not be required from all JHU faculty until January 25, 2022.
While NIH is not requiring use of the new Other Support and Biosketch forms until January 25, 2022, applicants are still responsible for capturing all of the necessary information set forth in their original notice (NOT-OD-21-073).
JHU has decided to delay implementing the NIH signature requirement for the Other Support page; however, all investigators remain personally responsible for the accuracy and completeness of their Biosketch and Other Support disclosures on all submissions, including proposals, JIT requests, and RPPRs.
In addition, investigators should ensure that all agreements that relate to any foreign appointment or an item listed on the Other Support page have been reviewed and approved by their Dean’s Office prior to being included in the Other Support. JHURA will not include any agreement that has not been vetted through the investigator’s Dean’s Office, but NIH may request such documents. Therefore, please be sure that all outside appointments and related agreements are on file, translated, and ready to be submitted to NIH upon request.
Information about each school’s process for reviewing foreign appointments may be found here.
Please consult the original NIH Notice and FAQs, as well as JHU’s Current and Pending Support page for additional guidance on what needs to be disclosed.
Please contact your research administration representative with any questions.
Johns Hopkins University
Research Administration
1101 E. 33rd Street, C310
Baltimore, MD 21218
(443) 927-3073
Email: jhura@jhu.eduSend an email to jhura@jhu.edu