The document provides an in-depth overview of the institutional considerations and practical approaches to implementing the National Institutes of Health (NIH) Guide Notice NOT-OD-21-073, which outlines NIH policies related to reporting of Other Support, financial conflicts of interest, and foreign components in research. Moderated by Kristin West, with panelists from Columbia University, Yale University, and Caltech, the presentation discusses the transition to new NIH biosketch and Other Support forms, emphasizing necessary adaptations for compliance that became effective from May 2020 and are mandatory from January 2022. The content focuses on the challenges institutions face in interpreting and implementing these requirements, highlighting the need for robust policies, interdepartmental coordination, and comprehensive training for faculty and administrators. Key considerations include distinguishing between external consulting and internal commitments, the valuation and reporting of in-kind contributions, differentiating gifts from grants, and the classification of clinical trials and collaborations.
The document underscores the complexity of managing disclosures given disparate data sources and varying institutional systems, and provides examples of tools and processes developed at leading universities, such as Caltech’s redesigned disclosure systems and Stanford’s External Activities Questionnaire, to facilitate compliance. It advocates for fostering positive international research collaborations while maintaining transparency and accountability. Additionally, the presentation offers guidance for clear communication and ongoing education to adapt to evolving federal requirements, and references various tools, FAQs, and institutional resources designed to assist researchers and compliance officers in meeting the new standards.
