Sponsored Research

Research CCHIP 028

Clarification or Change in Procedure (CCHIP)

Other Support Disclosures & Research Security Training

OVERVIEW/PURPOSE

This CCHIP establishes the 911爆料网鈥檚 (USF) internal control to implement the National Institutes of Health鈥檚 (NIH) new training requirement for Other Support (OS) disclosures and to strengthen compliance with NIH OS rules. It is not a broad USF policy; it is a procedure change to protect proposal timelines, ensure accurate NIH disclosures, and reduce enforcement risk. Effective October 1, 2025, NIH requires recipients to (i) train all Senior/Key Personnel on OS disclosure requirements and (ii) maintain a written and enforced policy on OS disclosures. 

DEFINITIONS 

Senior/Key Personnel 鈥� Faculty and researchers identified by NIH who contribute in a substantive, measurable way to the project and are integral to meeting project deliverables.
Other Support (OS) 鈥� All resources made available to a researcher in support of or related to all research endeavors (active or pending), regardless of monetary value and regardless of location; includes in-kind contributions and relevant consulting when research is performed. 

Just-in-Time (JIT) 鈥� Post-review pre-award submissions requested by NIH via eRA Commons.

Research Performance Progress Report (RPPR) 鈥� Research Performance Progress Report (annual, interim, or final reports).

Authorized Organizational Representative/Signing Official (AOR/SO) 鈥� The University-designated Authorized Organizational Representative/Signing Official for NIH submissions.

AUTHORITY & REFERENCES
  • (released July 17, 2025; effective October 1, 2025) 鈥� Training plus written/enforced policy on OS disclosures.

  • 鈥� OS definition/instructions; NIHGPS 搂8.4.2 鈥� Record retention (aligns to 2 CFR 搂200.334 default 3-year retention). See also Research CCHIP #007. 
CLARIFICATION/CHANGE

Beginning October 1, 2025, USF will:

  1. Require OS training for all NIH Senior/Key Personnel before JIT or award actions. Sponsored Research may enforce this via proposal/award routing controls; and

  2. Enforce a written OS disclosure procedure (this CCHIP) to ensure complete and accurate OS disclosures. 
NIH TRAINING REQUIREMENTS (EXCLUSIVE TO NOT-OD-25-133)

Curriculum & Delivery
Initially, USF will deliver NIH OS training via USF鈥檚 Research Listserv. Thereafter, USF will deliver NIH OS training via CITI (e.g., CITI USF OS integration). The USF OS training module covers:

  • Scope of OS; inclusions/exclusions; examples of in-kind support;
  • Timing (JIT vs. RPPR); documentation standards (agreements, English translations);
  • Immediate-notification scenarios; common pitfalls and remediation. 

Completion & Frequency

  • Complete prior to NIH JIT or any NIH award action that triggers OS checks;
  • Refresh annually (kept current within 12 months) to avoid routing holds.

Tracking

  • Subsequent to USF鈥檚 CITI integration, completion will be tracked in CITI and, where technically feasible, synced to Bulls iResearch for routing checks.
NIH OS DISCLOSURE REQUIREMENTS
  • Disclose all active and pending support, including in-kind contributions (e.g., lab space, personnel, equipment, supplies) and foreign activities/affiliations relevant to research. When in doubt,disclose.

  • Maintain supporting documentation (executed agreements; certified English translations of foreign documents). Provide upon NIH request at JIT or during RPPR.

  • If a previously undisclosed OS is identified after submission, the PD/PI or Senior/Key Person must immediately notify SR so NIH can be promptly informed.
ROLES & RESPONSIBILITIES
  • Institutional Research Effectiveness & Assessment (IREA) 鈥� Performs periodic post-award audits of NIH OS training/compliance (prime and subrecipient); assists or advises on ambiguous or unusual NIH OS situations or cases.
  • Principal Investigators (PI) /Departments 鈥� Ensure all named NIH Senior/Key Personnel, including subrecipients, complete training and provide complete OS.
  • Research Integrity & Compliance (RIC) 鈥� Owns NIH OS training content/delivery; coordinates with eCOI; assists or advises on ambiguous or unusual NIH OS situations or cases.

  • Senior/Key Personnel 鈥� Complete training; prepare accurate OS; maintain documentation; immediately report undisclosed OS.

  • Sponsored Research (SR)鈥� Verifies NIH OS training completion and OS documentation before JIT/award; enforces routing holds if needed; assists or advises on ambiguous or unusual NIH OS situations or cases; serve as AOR/SO;  and, notify sponsors of undisclosed OS.
PROCEDURES 

Access & Tracking 鈥� Training is assigned via CITI (upon implementation); completion status available to SR for routing.

Gatekeeping 鈥� Subsequent to availability of OS training in CITI, NIH proposals/JIT actions will not be routed to AOR until all named NIH Senior/Key Personnel show 鈥淐omplete鈥� for NIH OS training (鈮�12 months).

JIT & RPPR 鈥� Before JIT, SR confirms training and that OS documentation is on file. At RPPR, PIs update OS and confirm training currency.

Immediate Notification 鈥� Report undisclosed OS to SR immediately; SR coordinates NIH notice. 

RECORD KEEPING AND RETENTION

Retain training certificates, OS forms, agreements, translations, JIT/RPPR submissions, and sponsor correspondence for at least three (3) years from the date of submission of the final financial report, or longer if audit/litigation/claims are pending, consistent with 2 CFR 200.334, NIHGPS 搂8.4.2, and CCHIP #007.  

ENFORCEMENT

Non-compliance may trigger sponsor-imposed enforcement (e.g., removing non-compliant personnel from NIH proposals/awards until OS disclosure and/or training requirements are satisfied), imposition of special terms and conditions, result in potential disallowances, or enactment of other measures designed to promote research security. Internally, USF may elect to remove non-compliant personnel from NIH proposals/awards.

EFFECTIVE DATE AND TRANSITION

Effective October 1, 2025 for NIH; USF implementation is immediate to avoid delays for upcoming deadlines.  

CONTACT

Sponsored Research (SR) or Research Integrity & Compliance (RIC) for NIH OS questions/training.
 
ISSUED: October 1, 2025鈥冣�僉AST REVISION: N/A (Initial Release)