Foreign Influence Client Alert
On July 10, 2019, the NIH released NOT-OD-19-114, Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components. This notice provides clarification and guidance around what NIH considers Other Support and Foreign Components.
NIH has made clear that this notice is not considered a change in policy, but rather a reminder of existing NIH policies. Notably, there is no compliance date listed in the notice, further indicating that NIH intends that these points have always stood as requirements. However, the research community has inconsistently interpreted the definition of Other Support and Foreign Components when compared against this notice, as well as broader federal sponsor requirements and other recent updates from federal sponsors such as NSF.
In any case, there are still many areas of uncertainty as it relates to institutional approaches to identifying and managing foreign influence on federally sponsored grants and contracts. Key questions Huron is tracking include:
- What information about institutional support should be disclosed as Other Support (e.g., dollar value, time period, etc.)? And how will institutions identify and track this information to enable reporting as Other Support?
- What changes in Other Support are considered “substantive changes” that now require prior approval by NIH?
- What does this extra reporting mean for compliance and pre-award roles and responsibilities for proposal review and submission? How can these offices verify the completeness and correctness of Other Support and the Biographical Sketch?
- What kinds of internal controls should institutions consider to hold investigators accountable for accurate disclosure and reporting (e.g., how can institutions determine if projects have an unfunded foreign component, how can institutions verify and monitor Other Support provided by external organizations and individuals, etc.)?
Huron will continue to follow developments in this area and across the foreign influence topic and provide updates and added perspective as we see how this notice resonates and is put into practice in the research community. If you do have immediate concerns about how this impacts your institution’s practices, contact one of our leaders today.
To review published information from NIH and NSF regarding this topic, reference links are listed below:
NIH Frequently Asked Questions: Other Support and Foreign Components (continuously updated)
NSF Proposal and Award Policies and Procedures Guide (anticipated effective January 2020)
Federal Register Comment Request; NSF PAPPG (closes July 29, 2019)
NSF Dear Colleague Letter: Research Protection (July 11, 2019)