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M-Inform is the university's outside interest disclosure system.
(UMICH uniqname and password required)
NIH Other Support Reporting (ORSP)
Other Support by Any Other Name...
U-M uses the term "Other Support" in general reference to federal agencies' synonomous terms. This includes NSF's and DoD's "Current and Pending Support," NASA's "Ongoing/Pending Support," and more variations.
U-M Review Process
As a U-M investigator, many of the outside activities, relationships, or interests ("outside activities") you disclose to the University in M-Inform should also be reported to federal sponsors in sponsor documentation (e.g., Biosketch, Other Support, Current & Pending, and Facilities, Equipment, or Other Resources). See the Disclosure Matrix for details.
The U-M COI Offices assist U-M investigators with both outside activity disclosures and sponsor reporting obligations for international engagements by reviewing:
- Outside activity disclosures in M-Inform, including those involving an institution, government, or company located outside the U.S.
- Supporting documentation uploaded into M-Inform with a disclosure of an outside activity with a non-US entity (U-M disclosure requirement as of July 2021).
Examples of supporting documentation include, but are not limited to, original and English translations of contracts, grants, appointment/acknowledgement letters, statements of work, emails detailing the outside activity, and any other agreements with a non-US entity.
As part of this review, the COI Offices may advise investigators as to which:
- Outside activities should be included in their sponsor documentation, and how to meet federal agency requirements.
- Supporting documentation also should be included in their Other Support for NIH.
- Reviewing sponsor documentation at Just-In-Time (JIT) for NIH or at the time of award initiation for other federal agencies to ensure that all the required international outside activity information is appropriately disclosed to U-M and reported to the sponsor.
Many federal agencies require investigators to report other sources of support as part of proposal submission, award negotiation, and/or progress report processes. This requirement assures the funding agency that:
- It is not providing support for research where there is any scientific, budgetary, or commitment overlap with other supported research,
- All resources available in support of the investigator's research are being reported regardless of whether they are received directly by the investigator or through the institution, and
- The participating personnel have sufficient capacity to conduct the work that the agency will be funding.
NIH and NSF guidance on reporting other sources of support highlight the research institution's responsibility, as the applicant and recipient of federal funding, to ensure that all information submitted to the funding agency for a proposal or grant are complete and accurate and to establish institutional processes to "ensure individual investigators make all appropriate disclosures to [the institution] regarding other support, affiliations, and financial interests".
U-M meets this institutional responsibility through the use of M-Inform and the review functions of the departments, ORSP, and the COI Offices.
U-M Investigator Responsibilities
- Upload supporting documentation into M-Inform for those outside activities that involve a non-US entity if you have active NIH funding (direct or prime), or plan to submit a funding proposal to NIH within the fiscal year.
- Work with the COI Offices' Other Support Review team to resolve any questions or concerns regarding appropriate reporting of outside activities in sponsor documentation and supporting documentation.
- Compile your Biosketch for submission to a federal sponsor with your proposal.
- Compile your Other Support / Current & Pending document according to the federal agency's process.
- Provide updates regarding active sources of Other Support/Current & Pending via annual progress reports (RPPR) for the project.
- Immediately notify the Other Support Review team at Other.Support.Questions@umich.edu if previously undisclosed sources of Other Support were not correctly included in the initial proposal, JIT, RPPR, etc.
An international entity is one located outside of the United States (US).
"International" in this context does not refer to an entity that does business internationally, but rather to an entity that is formed outside the United States.
If an investigator signs a contract/agreement with a U.S. subsidiary of an international "parent" company, the U.S. subsidiary is not considered an international entity.
An appointment by itself would not be an entry in the Other Support document (although it would appear on the Biosketch).
However, active/pending projects that result from a non-U-M appointment must be included in Other Support. In this case, the non-UM appointment information acts as detail for the entry of the active/pending project.
In addition, any non-monetary resources (e.g., space, equipment, personnel) that result from the non-U-M appointment that are actively being used in relation to any of an investigator's research endeavors should be included as “in-kind” resources in Other Support. Again, the appointment information provides detail for the resource entry.
See Common Other Support Examples (Word, download).
- If a non-monetary resource will be used in the proposed project, include it in the Facilities, Equipment, or Resources section of the application rather than in Other Support.
- Non-UM appointments, even if unpaid, should be reported in M-Inform as an outside activity. Start-up funding as well as salary, should be included in the value disclosed.
- Any active appointment should be included on an investigator's Biosketch (including VA appoitments).
U-M's current interpretation of NIH guidance is that for external consulting activity to be included in Other Support, it must:
- Involve the design, conduct, or reporting of research; and
- Be current or ongoing; and
- Contribute tangible work to the research.
- Developing a research protocol
- Analyzing data from a research project
- Serving on a steering committee for a research project
- Work that results in publication of research (e.g., in an academic journal, at conferences, etc.) such that your contribution is cited in the publication.
High-level activity, such as a one-time phone conference to discuss the feasibility of a research concept or to provide subject matter expertise, is not considered an activity that needs to be reported as Other Support.
If the consulting activity is independent of an investigator's U-M appointment, then list effort as zero Person Months. However, the Other Support entry should still include the dollar amount for the consulting activity.
Yes. For consulting related to a specific non-UM research project, include the total dollar amount for the project in Other Support.
To report non-project-specific consulting, enter the dollar amount of the investigator's consulting activity.
To be included in Other Support, an in-kind (i.e., non-monetary) resource must meet all the following criteria:
- The resource is uniquely available to the researcher, and
- The resource has been provided by a non-UM entity (either domestic or foreign) within the past three years, and
- The resource will not be used on the proposed project.
- The resource is being used actively in support of any of an investigator's other research endeavors (aside from the proposed project).
Types of in-kind resources include, but are not limited to:
- Personnel (e.g., visiting scholars, visiting students, supported by a non-UM entity)
In-kind resources intended for use on the proposed project should be included in the 'Facilities and Other Resources' or 'Equipment' section of the application and not as part of Other Support.
No, regardless of the value, if the in-kind resource meets these criteria, it should be reported in Other Support.
If the visitor is made available at no cost to U-M to support any of the U-M investigator’s research endeavors, they are considered an in-kind resource and must be included in the Other Support document.
If the visitor will be working on the proposed project, and are not a budgeted resource, then they should be included in the Facilities and Other Resources section of the proposal application.
The researcher should provide the project number and PD/PI name for the prime award as the "Source of Support" on the NIH Other Support template. All other information, including the total award amount and person months, should be specific to the subaward.
A digital signature is required, using an electronic signature software application. The University of Michigan recommends using the SignNow application.
- A scanned copy of an ink signature is NOT acceptable.
- A typed name name of an investigator is NOT acceptable.
- A .jpg, .png. or other type of image of an investigator's signature is NOT acceptable.
For SignNow guidance see the:
Yes, but with qualifications. Use Adobe's Prepare Agreement option under the Sign menu and the Insert Digital Signature function to ensure the required audit trail is assigned. Do not use Adobe's "Fill & Sign" or "Sign Yourself" options.
NIH requires that "[a]pplicants and recipients maintain supporting documentation to reasonably authenticate that the appropriate individual signed the [Other Support] form." In this case, supporting documentation is interpreted to mean an audit trail associated with each application of an electronic signature. The individual is responsible for locating and providing a signature's supporting documentation upon request from NIH or others. When using Adobe, the PDF file, electronic signature, and audit trail are stored locally (e.g., on an individual's computer drive).
U-M recommends using SignNow to sign Other Support documentation. As UM-supported software, the PDF file and correspondiing signature supporting documentation is stored centrally and availalble through SignNow.