Effective October 1, 2025
This page establishes requirements for disclosure of other support for all individuals designated in an application as senior/key personnel and authorized organizational representatives, in compliance with the NIH Grants Policy Statement (GCP).
Definitions
Other Support: Includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes:
- Resources and/or financial support from all foreign and domestic entities that are available to the researcher. This includes, but is not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.). Institutional resources, such as core facilities or shared equipment that is made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.
- Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities and the activities fall outside of their appointment at the applicant or recipient institution.
- In-kind contributions, e.g., office/laboratory space, equipment, supplies, or employees or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.
- Other support does not include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything (e.g., time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as Other Support.
Scope of disclosure: Researchers must report all Other Support. This includes resources made available to them in support of or related to their research endeavors, whether those resources have monetary value or not, and whether they are internal or external to UMass Amherst.
- This includes, but is not limited to, foreign or domestic funding, in-kind contributions (e.g., equipment, reagents, personnel, space), consulting arrangements involving research effort, and institutional support when it is directed to that individual.
- Exemptions include standard institutional resources (e.g., centrally available core facilities) and gifts without expectation of service.
- Senior/Key personnel disclosing other support that includes foreign activities and/or resources will provide copies of contracts, grants, or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution. These copies are provided as part of the Other Support PDF following the Other Support Format page as supporting documentation. If they are not in English, recipients must provide translated copies. This does not include personal service contracts, or employment contracts for fellows supported by foreign entities.
Training requirement: UMass Amherst requires completion of the Research Security Training (Combined) Course, available in CITI. Completion of this training by all NIH Senior/Key Personnel within the previous 12 months is required at the time of submission, and annually thereafter.
Procedure for Senior/Key Personnel:
- All Senior/Key Personnel must fully disclose all resources that support or relate to their research at (1) Just-in-Time (JIT) submission; (2) Research Performance Progress Reports (RPPRs); (3) Upon NIH request; (4) Updates: If something was missed or changes, submit promptly
- All Senior/Key Personnel must certify the accuracy and completeness of their Other Support disclosures.
- All Other Support disclosures shall be submitted following NIH format requirements (e.g., Just-In-Time or in RPPRs) with supporting documentation for foreign agreements or appointments.
- If undisclosed Other Support is subsequently identified, Senior/Key Personnel, in collaboration with the Office of Post Award Management (OPAM), must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.
Integration with NIH submission and reporting:
- UMass Amherst has established internal proposal review procedures to ensure consistency, completeness, and compliance prior to NIH submission. While the content of personnel documents remains the responsibility of the principal investigator or researcher.
- No NIH proposals will be submitted without the completion of the research security training for all UMass Amherst employees.
- No NIH proposals will be submitted without the required personnel documents including the appropriate sections, signatures and certifications
Compliance and consequences:
- Noncompliance with these UMass Amherst requirements and NIH requirements may place awards at risk, result in audit findings, or trigger NIH corrective action.
- The Office of Pre-Award Services (OPAS), in collaboration with the Office of Research Compliance (ORC), will monitor compliance, provide guidance, and address questions or potential disclosures.