06/27/2023 – Research Operations review of NIH Other Support (OS) documents is no longer required. The Institutional Compliance and Regulatory Affairs (ICRA) team has been reviewing NIH OS documents for considerations related to disclosures (or missing disclosures) of current financial interests and relationships. However, an assessment has confirmed that this review is no longer necessary as PI disclosures in ERA (COI MyDisclosures) have consistently also been disclosed by the PI on OS documents.
The work instructions for Post-Submission Actions (WI-SN-40), and the Sponsor Guidelines tab of the International Research and Global Collaborations sitelet have been updated to remove the requirement that NIH OS advanced review requirement.
NIH PIs and Units/RAs should continue to be aware of NIH OS Requirements, and be diligent in disclosing all active and pending sources of Other Support and updating their Disclosure Profiles in ERA MyDisclosures as may be required. If something should have been included in a submitted NIH OS document, but it was missing – immediately notify Research Operations as outlined in the NIH OTHER SUPPORT REQUIREMENTS AND ASU PROCESS post (excerpt below):
| Immediately notify KE Research Operations of undisclosed Other Support (i.e., information that was missing from a proposal at Just-In-Time (JIT) or a Research Performance Progress Report (RPPR) submitted on/after January 25). – Pre-Award: For proposals that have not been awarded yet, the RA should use the Notify PNT activity on the ERA Funding Proposal (FP) to route any updated Other Support documents to the Proposal GCO for submission to NIH. – Post-Award: If an investigator or RA/Unit discovers that something needs to be added/disclosed on an NIH Other Support, the RA should immediately send an updated Other Support document to their AMT Fiscal Reporting GCO and remind investigators to update their disclosure profile in ERA MyDisclosures as may be required. ASU must submit the update within 30 days of becoming aware of the non-disclosure, so do not wait until the next RPPR. Note: The updated format page and instructions must be used for all Other Support submissions, including both competing applications and the RPPR. There are no longer separate instructions for competing applications and the RPPR. | Required, if applicable |
By Research Operations