NIH GRANT APPLICATIONS - "OTHER
SUPPORT"
PURPOSE OF THIS NOTICE. UAB is issuing this notice to the UAB
Research Community based on recent NIH policy pronouncements related to the
"Other Support" section of NIH Grant Applications. It is imperative
that "Other Support" pages be completed accurately, in accordance
with the NIH instructions and this notice.
RESPONSIBILITY FOR COMPLIANCE WITH NIH "OTHER SUPPORT" REQUIREMENTS. At UAB, it is the faculty member's responsibility to ensure that their "Other Support" page is complete and accurate because the faculty member is in the best position to know or determine how their time is committed and their "real-time" and potential sources of support. By signing and submitting the NIH grant application, the faculty member and the UAB Administrative Official certify that the entire application, including the "Other Support" page, is accurate. While administrative personnel may be involved in preparation of the NIH grant applications, the participating faculty member must review the "Other Support" page to make sure it accurately reflects all of their current or pending sources of support.
NIH INSTRUCTIONS FOR "OTHER
SUPPORT"
Sources: NIH PHS 398 Instructions; NOT-OD-03-029 (2/13/03); NOT-OD-04-009
(11/26/03); NIH Grants Policy Statement (links available under "NIH Information"
on http://main.uab.edu/show.asp?durki=30265)
What MUST be listed
in Other Support? "All financial resources, whether Federal, non-Federal,
commercial or institutional, available in direct support of an individual's
research endeavors, including but not limited to research grants, cooperative
agreements, contracts, and/or institutional awards. Training awards, prizes,
or gifts are not included."
What is the purpose of the Other Support Policy? "Information
on other support assists awarding agency staff in the identification and resolution
of potential overlap of support. Overlap, whether scientific, budgetary, or
commitment of an individual's effort greater than 100 percent, is not permitted.
The goals in identifying and eliminating overlap are to ensure that sufficient
and appropriate levels of effort are committed to the project; that there
is no duplication of funding for scientific aims, specific budgetary items,
or any individual's level of effort; and only funds necessary to the conduct
of the approved project are included in the award."
When must "Other Support" pages be submitted? Unless otherwise
specified in a specific RFA or BAA, "Applicants should not include information
on other support in the PHS 398 competitive grant application submission,
but should be prepared to follow "just-in-time" procedures to submit
current other support information upon the request of NIH Institute/Center
staff when the application is under consideration for funding. Grantees must
also report any changes in other support as a part of the annual progress
report."
Who are "Key
Personnel"? "The PI and other individuals who contribute to
the scientific development or execution of a project in a substantive, measurable
way, whether or not they receive salaries or compensation under the grant."
Typically these individuals have doctoral or other professional degrees, although
individuals at the masters or baccalaureate level may be considered key personnel
if their involvement meets this definition. Consultants also may be considered
key personnel if they meet this definition. "Zero percent" effort
or "as needed" is not an acceptable level of involvement for key
personnel."
Who are the personnel for whom Other Support information is required? "Information on active and pending other support is required for key personnel, excluding consultants."
UAB QUESTIONS AND ANSWERS ON "OTHER SUPPORT" (available on OGCA's web site at http://main.uab.edu/show.asp?durki=30265)
1. Which individuals must complete the "Other Support" page? Key Personnel, as defined in the NIH Guidebook (see previous page), excluding consultants. Key Personnel include the PI and others who contribute to the project in a "substantive, measurable way." The instructions state that consultants do not have to complete "Other Support" even though they are Key Personnel.
2. Is "Other Support" limited to grants in which the individual receives direct salary support? No. "Other Support" includes ALL financial resources received in direct support of research (including pass-through funding). This includes grants for which the individual does not receive salary support under the grant.
3. Is "Other Support"
limited to grants in which faculty are required to commit a stated percent
effort of time? No. If an individual receives funding for a grant in which
that individual will or may expend some research effort, even if a percent
effort is not submitted to the sponsor, the grant must be listed as "Other
Support."
5. What percent effort must be listed on the "Other Support" page? For an active project, the NIH grant application states that the level of effort (even if unsalaried) as approved for the current budget period should be listed. For pending projects, the NIH grant application states that the level of effort as proposed for the initial budget period should be listed. If the individual's actual percent effort on an active project differs from the originally approved percent effort, the individual should list both, i.e., 40% (50% approved). (Note: a reduction in the effort of key personnel of 25% or more from the originally approved effort level on an NIH grant must be approved by NIH). For grants that did not require submission of a stated percent effort or do not contain an "approved" level of effort, the actual/expected effort percentage should be shown. The percent effort on "Other Support" pages should be consistent with the percent effort shown on "Effort Reports" for purposes of salary allocation, unless there is a reasonable explanation for why the percent efforts are different.
6. Must a definite percent effort be assigned to the PI and Key Personnel for each source of "Other Support"? Yes. However, see # 7 below for instances in which little or no time is spent on a grant. Note also that NIH recently clarified its policy so that the percent effort assigned to Key Personnel on the proposed grant as part of the grant application (separate from the "Other Support" page) can no longer by "0%" or "as needed." A percent effort, no matter how small, must be assigned to Key Personnel for the proposed grant.
7. What if an individual
may spend very little or no time on a grant, such as an industry-sponsored
clinical trial? For industry-sponsored clinical trials in which there
will only be a very small and/or unpredictable amount of effort devoted to
each trial, NIH has said it will accept the following form language where
the aggregate percentage is 10% or less:
"In addition to the grants listed above, Dr. ____ is involved in clinical
trials. The cyclic and unpredictable nature of the activities in these trials
make it impossible to assign a precise percent effort for each trial. Dr.
____ has reviewed his/her clinical study obligations and confirms that the
aggregate effort on all trials listed below does not exceed _____% of institutional
effort."
Each industry-sponsored clinical trial must continue to be listed under this
paragraph and all other information on "Other Support" must still
be provided for each clinical trial.
8. What are other examples of "Other Support"? Grants from the HSF General Endowment Fund in direct support of research; grants from private foundations, such as the American Heart Association in direct support of research; and any other funding in direct support of research.
9. Should service on an Advisory Committee established pursuant to a specific research protocol be listed as "Other Support"? Yes. Even if this is an individual's only commitment to the protocol and there is no compensation furnished to the individual, service on an advisory committee should be listed as "Other Support." As described for industry-sponsored clinical trials in which little effort is required (#7, above), individuals may aggregate the percent effort for all advisory committees. Service on NIH Advisory Committees does not have to be listed as "Other Support."
10. What if a faculty member has a joint UAB/VA appointment? All faculty members with a joint UAB/VA appointment must include the UAB/VA Joint Appointment Memorandum of Understanding ("VA MOU") with submission of the Other Support page. The Institutional Effort listed for research grants on the VA MOU must be consistent with the percent effort for those same research grants as listed on the Other Support page.
11. Who is responsible for accurate completion of the "Other Support"? At UAB, Faculty are responsible for ensuring the "Other Support" section is completed accurately because they have the most current "real-time" information. Non-faculty identified as key personnel are each responsible for their own "Other Support" representations.
12. Who is available to assist with questions about what is required to be listed as "Other Support"? The Office of Grants and Contracts Administration is available to respond to any questions about what is required to be listed as "Other Support". They may be reached at 934-5266. Information is also available on OGCA's web site at http://main.uab.edu/show.asp?durki=30265.