Other Support Training and Disclosure Policy

Policy Date: October 1, 2025

Purpose

To implement the National Institute of Health’s (NIH) requirement that funding recipients (a) provide training to all Senior/Key Personnel on Other Support disclosure obligations and (b) maintain a written and enforced policy ensuring accurate, complete, and timely disclosures in NIH submissions.

Scope

This policy applies to all faculty, researchers, and personnel identified as Senior/Key Personnel on NIH proposals and awards.

Policy Statement

Training Requirement: All Senior/Key Personnel must complete NIH-compliant training on Other Support disclosure before being included on an NIH submission.

• The University of Nevada, Reno accepts the CITI “Research Security Training (Combined)” course as satisfying this requirement.
• Training must be current within 12 months prior to proposal submission and refreshed annually or upon significant NIH policy changes.

Disclosure Process:

• Other Support disclosures must include all active and pending resources, whether monetary or in-kind, internal or external, domestic or foreign.

Sponsored Projects will review disclosures for adherence to NIH formatting and submission requirements, and to confirm that a disclosure has been provided. Sponsored Projects does not verify the substantive accuracy or completeness of the information disclosed; accuracy remains the responsibility of the Senior/Key Personnel.

Institutional Enforcement:

• Proposals lacking compliant training or complete Other Support will not be submitted to NIH.
• Departments and colleges are expected to support compliance by ensuring their investigators complete requirements in a timely manner.

Roles & Responsibilities

• Senior/Key Personnel: Each Senior/Key Personnel listed in an NIH proposal or award must complete NIH-compliant training on Other Support disclosure within the required timeframe. Senior/Key Personnel are responsible for providing complete and accurate Other Support disclosures at proposal, Just-in-Time, and RPPR stages, and for updating disclosures within 30 days of any changes.
• The University: Ensures that all Senior/Key Personnel on NIH proposals are made aware of NIH’s Other Support requirements under NOT-OD-25-133 and that they are in compliance with those requirements prior to submission. The University will maintain a written, enforced policy and supporting procedures to meet NIH expectations.
• Sponsored Projects: Ensures that Senior/Key Personnel on NIH proposals are compliant with training and disclosure requirements. Ensures that required Other Support disclosures are submitted in NIH-required formats, are present at the time of proposal/award submission, and conform to sponsor instructions. OSP does not determine whether the content of the disclosures is accurate or exhaustive; that responsibility rests solely with the Senior/Key Personnel.
• Vice President for Research and Innovation: Is the University’s research security point of contact with responsibility for implementation and oversight of the University’s Research Security Plan and this policy.

Definitions

• Other Support: All resources made available to a researcher in support of, and/or related to, their research endeavors, regardless of monetary value and regardless of whether they are based at the University. Includes active and pending support; in-kind contributions (e.g., lab space, personnel, materials); and outside affiliations.
• Senior/Key Personnel: As defined by NIH, individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant (e.g., PI/PD, MPI, key personnel responsible for design, conduct, reporting).

Non-Compliance

Failure to comply with this policy may result in:

• At the proposal stage: Delays or prevention of NIH proposal submission.
• At the award stage: Withholding institutional approval to access or spend NIH funds.

Sponsor consequences: NIH may withdraw applications, suspend awards, or impose additional oversight if disclosures are found incomplete or inaccurate.