This document, produced by the Council on Governmental Relations (COGR), provides interpretative guidance for research institutions on the evolving disclosure requirements related to “Other Support” for grants funded by the National Institutes of Health (NIH), with additional contextual references to policies from the Department of Defense (DOD), National Science Foundation (NSF), and Department of Energy (DOE). The guidance responds to heightened federal concerns regarding potential undue foreign influence and the necessity for comprehensive disclosure to assess both scientific and budgetary overlaps and to prevent conflicts of interest or threats to national and economic security.
The analysis synthesizes the current understanding of NIH’s expectations for disclosure, highlighting the need for transparency in reporting all sources of research support, whether monetary or in-kind, from domestic or foreign sources, and regardless of whether the support is internal or external to the applicant institution. Key points include the requirement for key personnel to report all research-related funding and resources (excluding non-research consulting and broadly available, institution-wide resources), clear distinction on the disclosure of training awards, gifts, prizes, and start-up packages, and specific attention to appointments, affiliations, and foreign components. The document urges institutions to maintain accurate classification and internal guidance, educate principal investigators on compliance, and monitor for future regulatory changes, while emphasizing that COGR’s interpretations are subject to further clarification by NIH.
