New NIH Guidance on Foreign and Domestic Activities
On September 13, 2019, Vice President for Research Christopher J. Cramer and Associate Vice President for Research Pamela Webb sent the following memo to the research community at the University of Minnesota.
NIH recently issued Guide Notice NOT-OD-19-114 to remind investigators about the need to report foreign and domestic activities germane to their sponsored projects through careful documentation of other support, foreign components, and adherence to financial conflict of interest reporting processes (e.g., REPA reporting).
NIH requires this information to prevent scientific, budgetary, or commitment overlap, and to ensure proper oversight of financial conflicts of interest before and while NIH funds are being expended. NIH views these updated instructions as “clarifications” rather than policy changes, although in practice there do seem to be some significant alterations, summarized here.
Your help is needed to make sure that we are properly reporting to NIH. Please review this Guide Notice and its accompanying FAQs carefully so that your NIH proposals, just-in-time submissions, and continuation progress reports (RPPRs) are fully accurate and complete. As a PI/PD or as senior/key personnel, note that you remain personally responsible for the completeness and accuracy of your documents, even if departmental research administrative staff have assisted you in document preparation.
In addition, please remember to limit acknowledgments in published work (e.g., peer reviewed journal articles) to only those projects that actually supported the work discussed in the paper.
If you have any questions, please contact your SPA grant administrator and they will, if need be, solicit input from NIH. You may also visit our NIH Guidance web page to keep track of the latest guidance offered by NIH and other federal funding agencies. NIH is actively continuing to refine their guidance on these topics and additional information will be furnished once it is available.
Thank you for your attention to this new guidance and your help in properly reporting all activities to NIH.
Christopher J. Cramer
Vice President for Research
Associate Vice President for Research