Other Support Disclosure Policy

Statement of policy

Summary of contents/major changes

1. Purpose of Policy

   To ensure institutional compliance with NIH requirements for disclosure of Other Support, as outlined in NIH Notice NOT-OD-25-133. This policy mandates training and disclosure protocols for all Senior/Key Personnel involved in NIH-funded research. 

   This policy applies at the time of an NIH grant application, Just-In-Time (JIT) submission, Research Performance Progress Report (RPPR), other NIH-related milestones, and when there are significant changes to a Senior/Key Person’s support, even when outside of regular NIH reporting cycles. 

2. Stakeholders Most Impacted by the Policy

   This policy applies to all WMU faculty, staff, and students who serve as Senior/Key Personnel including Principal Investigators (PIs), Investigators, and other individuals contributing significantly to NIH-funded or proposed to be funded projects. 

3. Key Definitions

   1. Other Support: Includes all resources (financial or in-kind) made available to a researcher in support of or related to their research activities, regardless of monetary value or institutional affiliation. Other Support includes, but is not limited to: 

      1. All active and pending sponsored projects and awards (domestic and foreign); 

      2. All research-related appointments and positions, whether compensated or uncompensated; 

      3. In-kind contributions (e.g., lab space, equipment, personnel, data, materials);

      4. Consulting, honorary, or visiting positions that provide research resources; and 

      5. All agreements or contracts supporting these activities 

   2. Senior/Key Personnel: Individuals who contribute to the scientific development or execution of a project in a substantive, measurable way. 

4. Full Policy Details

   1. Implementation

      Prior to the submission of an NIH grant application, Just-In-Time (JIT) submission, Research Performance Progress Report (RPPR), other NIH-related milestones, and when there are significant changes to a Senior/Key Person’s support, even when outside of regular NIH reporting cycles, the following is required. 

      1. The following disclosure obligations: 

         1. All Senior/Key Personnel must disclose Other Support using NIH’s current format

         2. Other Support disclosures must include active and pending support from domestic and foreign sources. 

         3. Supporting documentation for the Other Support disclosures (e.g., contracts, agreements) must be provided, if not already managed in the Office of Research and Innovation, and translated into English, if necessary. 

      2. The following training requirements: 

         1. All Senior/Key Personnel must complete training on NIH disclosure requirements for Other Support. WMU requires completion of this requirement via CITI (Collaborative Institutional Training Initiative).

            Contact the Office of Research Compliance at  @email to confirm the required course(s) which will meet this requirement. 

         2. Refresher training is required annually or upon significant updates to NIH disclosure policies. 

   2. Communication

      The Office of Research and Innovation (ORI) will review Other Support disclosures for completeness and potential overlap or conflicts with existing commitments. If discrepancies or concerns are identified, ORI will coordinate with the investigator to correct them and, if necessary, report inconsistencies to NIH in accordance with NOT-OD-25-133. 

   3. Exceptions

      This policy applies to all Senior/Key personnel on a NIH funded project.  As this is associated to federal regulations, exceptions are not anticipated. 

5. Accountability

   WMU Community: For students, failure to follow this Policy could result in sanctions under the Student Code, including expulsion.  For administrators, faculty, and staff, failure to comply with this Policy could result in disciplinary measures up to and including dismissal, in accordance with Human Resources policy and applicable bargaining agreements.   

   Additional consequences for non-compliance include: NIH may suspend, terminate, or take enforcement actions against awards if required disclosures are incomplete or inaccurate. WMU will fully cooperate with NIH in resolving any identified compliance issues. The University may also decide to withdraw a previously submitted NIH grant application or choose not to submit a proposal for funding to the NIH.