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Disclosing Foreign Support

Complete and accurate reporting of research support from internal and external sources, and the relationship to federal funding, is critical for federal agencies and grantee institutions to assess scientific and budgetary overlap, and availability of time to commit to federally funded projects. To protect yourself, your research and UMMS it is critical that you provide complete and timely disclosure of your professional activities to ensure compliance with all agency policies and regulations. Specifically:

A. Disclosing Other Support

When completing forms requesting information about Other Support (which NSF and others call “Current and Pending Support”) provide detailed and comprehensive information on all forms of research support, including support from foreign sources and gifts, regardless of the sponsoring entity.

Disclose all compensated or uncompensated external affiliations, especially affiliations with foreign organizations, in all grant proposals and progress reports. Such affiliations can be disclosed via your bio sketch or other applicable section of the proposal. If you have an affiliation that should be disclosed and are unsure where or how to disclose the information, please contact your analyst in the Office of Sponsored Programs for guidance. We will work with you to ensure full transparency of this information to the sponsor.

1.  Key Reminders

  • Read sponsor guidelines, Funding Opportunity Announcements (FOAs), proposal questions, and award documents carefully to ensure that you and other project personnel are correctly answering the questions that address foreign engagements, foreign affiliations, and foreign components and collaborations, as required by the sponsor.
  • Review agency definitions to verify that your interpretation of your sponsor's Terms and Definitions is correct. The Office of Sponsored Programs and your sponsor's program and grants management staff can be contacted with questions about definitions.

2.  Reporting Training Awards, Gifts, and Prizes / Institutional Support

  • Key Personnel must disclose start-up packages and support for research from entities other than the applicant institution, even if the research will be carried out at another institution; and institutional grants and awards that are “separately budgeted and accounted for” per the Uniform Guidance.
  • Key Personnel are not responsible for disclosing start-up packages from the applicant institution in any form; gift funds that meet the formal definition of a gift; endowed chair funds and other endowment allocations.

3.  Reporting In-Kind Support

  • Key Personnel must disclose in-kind resources that are uniquely available to key personnel (office/laboratory space, equipment, supplies, employees) including those available outside the applicant institution; details about in-kind personnel who are expected to work directly on a proposed project; report details of in-kind support in the Facilities and Other Resources section or in Other Support section of the application; report details of individuals who have expended at least one month of effort during the year (compensated or uncompensated) in the annual report (no change from prior regulations).
  • Key Personnel are not responsible for disclosing institution-wide resources such as core facilities or shared equipment that are made broadly available.

4.  Reporting of Appointments and Affiliations

  • Key personnel must disclose affiliations or appointments that are likely to be cited in NIH-funded publications in the biosketch section of the application.
  • All appointments must also be disclosed in the Conflict Disclosure System.

B. Disclosing a Foreign Component/Collaboration

Foreign collaborations involving NIH funding have always required prior approval. But in in its Notice Regarding Policies on Other Support and FCOI (NOT-OD-19-114) – July 2019 the NIH clarified that the policy also applies to foreign conduct of any of the work scope regardless of the source of funding.

A foreign component as performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended.

-   Activities that would meet this definition include the following:

o   Research involving human subjects or vertebrate animals at a foreign site

o   Extensive foreign travel by UMMS project staff for the purpose of data collection, surveying, sampling, and similar activities.

o   Any activity of the grantee that may involve the population, environment, resources, or affairs of a foreign country.

-   Examples of other grantā€related activities that may be significant are:

o   Unfunded collaborations with a foreign entity or a foreign person, including visiting scholars, graduate students and fellows funded by their home country,

o   Exchanging material and/or data developed with NIH funding with foreign collaborators

o   Use of facilities or instrumentation at a foreign site; or

o   Receipt of financial support or resources from a foreign entity.

A change in the performance site within a foreign country or the addition of a performance site in a country other than that specified in the approved application also requires NIH prior approval, as does the transfer of work by a domestic grantee to a foreign entity.

Principal Investigators must identify and disclose all Foreign Components through progress reports and final technical reports. While we focus on NIH, sponsors have varying requirements for disclosure of Foreign Components, so it is important to understand each sponsor's proposal instructions before submission. Contact Office of Sponsored Programs with questions.

1.  Areas to Watch For

  • Formal collaborations should be documented via a Memorandum of Understanding and/or a project-specific research collaboration.
  • Informal collaborations with international researchers could meet the NIH definition of a Foreign Component; therefore, it will not always be apparent to the Office of Sponsored Programs when a foreign component arises.
  • A joint publication with a foreign collaborator is not considered a Foreign Component if the research was performed in the US, even if the publication occurs after the international collaborator returns home.
  • An activity that does not rise to the level of a Foreign Component still must be reported as Other Support.

2.  Completing a Foreign Project Registration

The PI for any project with Foreign Component must complete a Foreign Project Registration form upon indication of funding (at Just in Time or at least 60 days prior to any expenditure of funding) to ensure proper compliance and alignment of internal support. FPRs are initially reviewed by the Director of International Support Services and, as necessary, by appropriate members of the International Engagements Working Group.

During the proposal development process you are encouraged to reach out to International Support Services with questions concerning compliance and risk considerations in the locations where research activities are to be conducted.

Refer to the table entitled “Examples of What to Disclose to NIH about Senior/Key Personnel on Applications and Awards” for the most recent guidance. https://grants.nih.gov/policy/protecting-innovation.htm

C. Disclosing Foreign Affiliations & Talent Plan Participation

The U.S. federal government is concerned that foreign affiliations – particularly those that are associated with government-supported foreign talent programs – are being used by foreign governments to acquire, legally and illegally, U.S. government-funded scientific research in order to dominate high technology sectors currently led by U.S. entities.

Even if you are not actively collaborating with a foreign entity, any participation in a talent program (i.e., an active contract) must be disclosed within applications to federal sponsors as Other Support. Faculty with past participation in a Foreign Talent program should proactively reach out OSP to determine if there are any disclosure requirements for federally funded research.

1.  Prior Approval & COI Disclosure for Outside Activities

Faculty are reminded that, per the University on Faculty Consulting and Outside Activities policy, they are required obtain prior approval from their Department Chair for all Outside Activities (i.e., non-academic activities in their area of professional expertise, whether paid or unpaid). This includes, but is not limited to, participation in talent plans, foreign teaching appointments or any contractual relationship with a foreign entity. Any Outside Activity involving a Significant Financial Interests (i.e., exceeding $5000 in income/travel support) must also be reported in the Conflicts Disclosure System. Note that disclosures of foreign-source financial interests below the Significant Financial Interest threshold may not trigger in depth review, but given current scrutiny faculty are encouraged to disclose all foreign financial interests. When in doubt – DISCLOSE.

2. Participation in foreign government-sponsored talent programs

Researchers are reminded that participation in a foreign government sponsored talent program may jeopardize your ability to receive future federal funding for research or your ability to collaborate with U.S. government agencies. Any current participation by faculty members must be disclosed via the Conflict of Interest System, and any prospective participation must be approved by the Provost prior to engaging in such activity.

Please note that federal agencies do not have a unified definition of what constitutes a foreign talent program. As such, you are encouraged to contact the Director of International Support Services (Teresa Zash), to discuss offers for research which will be awarded to you as an individual (not through UMMS) which may require frequent travel to or extended stays in the foreign country from which the offer of research support originated since these are possible indicators that the activity could constitute a government-supported foreign talent program.