NIH Other Support Policy

NIH Other Support Reporting Requirements and Process

I. Purpose and Background

This policy provides institutional guidance on reporting Other Support to the National Institutes of Health (NIH). NIH requires Other Support disclosures for all individuals designated as Key Personnel on grant applications.

Effective October 1, 2025, Key Personnel must complete training on Other Support disclosure requirements, as outlined in NIH Guide Notice NOT-OD-25-133, “NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements.”

As recipients of NIH funding, CU Anschutz and CU Denver are committed to full compliance with federal requirements. While this policy focuses on NIH, investigators should be aware that other sponsors may have similar disclosure requirements. CU Anschutz | CU Denver expects compliance with all applicable sponsor policies.

II. Policy

A. NIH Other Support Reporting Requirements

Accurate preparation and disclosure of Other Support is a critical responsibility of Principal Investigators (PIs) and Key Personnel. NIH typically requires Other Support at the following stages:

• Just-in-Time (JIT)
• Annual Research Performance Progress Reports (RPPR)

CU Anschutz | CU Denver requires timely and accurate disclosure of all resources supporting research activities, including:

1. External Funding Sources
• Federal (e.g., NIH, DoD)
• State (e.g., Colorado agencies)
• Non-federal (e.g., foundations, societies)
• Industry-sponsored agreements (SRAs, CTAs)
2. Internal Awards
• Competitive institutional grants (e.g., pilot awards)
3. In-Kind Contributions
• Lab space, equipment, supplies, personnel
• High-value resources not freely available (e.g., unique cell lines)
4. Support for Non-Employee Scientists
• Visiting scholars or NES funded externally (domestic or foreign)
5. Consulting Arrangements
• If involving research activities

Note: NIH does not require reporting of gifts, training awards, or prizes—defined as resources with no expectation of return.

For foreign resources, NIH requires documentation (e.g., contracts, agreements, appointment letters) and translations if not in English.

B. Responsibilities of PIs and Key Personnel

• Disclose new sources of Other Support to CU Anschutz | CU Denver immediately upon awareness.
• Collaborate with Department Administrators, the Office of Grants and Contracts (OGC), or the Research Compliance Office to determine NIH reporting obligations.
• Participate in the preparation and attestation of Other Support documentation.
• Complete institutionally assigned NIH Other Support training.

Failure to complete training may delay project setup, fund expenditures, or continuation of awards.

III. Process

A. Submission to NIH

Other Support must be submitted:

• At JIT, when requested
• With the annual RPPR
• As needed, when new support arises during the project period

NIH may also require Other Support at the proposal stage, as specified in certain funding announcements (e.g., DP1, DP2, S10, or for Mentors on K awards). These may involve special formats that differ from standard NIH instructions.

IV. Training Requirement

CU Anschutz | CU Denver will offer training through the CITI Program, which is developing a module aligned with NIH’s new requirements.

To be in compliance with the NIH policy, please complete:  “Research Security Training (Combined Course)”
 Click here for instructions on accessing the course in CITI.