Foreign Financial Interests – Research - ɫ

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Foreign Financial Interests

Reporting Other Support and Foreign Relationships and Activities

Federally funded research requires the reporting of foreign activities that constitute other support, foreign components, and a conflict of interest in addition to the reporting of Significant Financial Conflict of Interests. In order to prevent scientific, budgetary, or commitment overlap, this disclosure requires full transparency of all research activities both domestic and foreign and are instrumental to protect the integrity of research sponsored by the U.S. government. Failure to disclose can invite federal scrutiny, jeopardize funding or career opportunities and may result in legal prosecution.

Therefore, University employees who receive grant funds from the U.S. government are urged, in the strongest terms possible, to disclose information about any and all other support, foreign components, or current and pending support, whether it’s provided through an organization or directly to an individual, and also all projects and activities that require a time commitment.

The form to be used for reporting foreign interests to NIH in new and renewal applications and progress reports can be found .

The form to be used for reporting foreign interests in NSF applications can be found .  Note: The NSF form was expected to change on October 5, 2020. Until the new form is approved by NSF, proposers should continue to prepare the current document in accordance with guidance specified in the PAPPG (NSF 20-1).

National Institutes of Health

On July 10, 2019, the National Institute of Health issued   and it should be referred to assist with reporting obligations.

What to disclose as other support?

NIH defines as all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).
NIH Applicants must:
1. List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

2. Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts.

3. Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.

4. Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.

What to disclose as Foreign Components?

NIH requires recipients to determine whether activities it supports include a foreign component, defined as “the existence of any “significant scientific element or segment of a project” outside of the United States, in other words:

1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or

2. performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.
If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component. To aide with what may be considered significant, go to the .
If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.

When do I disclose?

Foreign influence must be disclosed at the time an application is submitted and prior to award using “Just-in-Time Procedures.” Researchers are also responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award. If other support, as described as above, is obtained after the initial NIH award period, from any source either through the institution or directly to senior/key personnel, the details must be disclosed in the annual research performance progress report. Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”

National Science Foundation

What is Current and Pending Support as defined by NSF?

Current and pending support information must be separately provided for each individual designated as senior personnel on the proposal. Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students. In-kind contributions not intended for use on the project/proposal being proposed also must be reported.

Current and pending support information must be provided for the proposed project, for ongoing projects, and for any proposals currently under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.

The total award amount for the entire award period covered (including indirect costs) must be provided, as well as the number of person-months (or partial person-months) per year to be devoted to the project by the individual.

Links to other Institutions of Higher Education Foreign Influence websites/guidance