Background
Federal and state agencies have issued statements expressing concerns about threats to the integrity of U.S. biomedical research, specifically:
One issue that has moved to the forefront is the failure of federally-funded researchers at U.S. institutions to disclose their relationships and activities with foreign institutions and funding agencies. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.
Rush encourages international collaborations. However, Rush recognizes that it is important to be transparent about foreign relationships and activities to mitigate risk and prevent undue foreign involvement in research. U.S. government agencies such as the Federal Bureau of Investigation (FBI), federal funding agencies such as the National Institute of Health (NIH), National Science Foundation (NSF) and the Department of Defense (DoD), have issued guidance for the academic and research community to effectively identify, educate, and mitigate the risk of undue interference and influence in all research activities.
Click for more information on Foreign Interference and Influence in Academia and Conflict of Interest Office for when, what and how to disclose possible conflicts. All related COI policies are listed within the Conflict of Interest Office website.
Questions
If you have any questions regarding sponsor requirements for disclosure at the proposal or award stage, reach out to Sponsored Programs Administration.
Foreign Activity Reporting Guidance by Sponsor
According to the NIH Grants Policy Statement, a foreign component is the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to:
Foreign travel for consultation is not considered a foreign component.
In order to comply with Foreign Influence guidance issued in the NIH Notice (NOT-OD-21-073), individuals are required to disclose all foreign research activities on NIH grant applications, at the time of funding, on Research Performance Progress Reports (RPPR) through the lifecycle of the grant and ad-hoc as changes arise.
When and Where to Disclose Foreign Activity
Pre-Award: Grant Application
Research & Related Other Project Information page of the SF424 application
If the applicant organization is a foreign organization OR a foreign component is involved in the project, a foreign justification must be included on this page indicating how it meets the definition of a foreign component.
Biographical Sketch (biosketch)
Just-in-Time (JIT)
Other Support
Post-Award: Research Performance Progress Report (RPPR)
Other Support
The information requested for Other Support as noted under JIT above is also required at the time an interim or final RPPR is due for an active grant from all senior/key personnel if there has been a change in other support. Each activity that changed should be marked and include a short description of the change that occurred.
In the Summer 2020, the NSF released an updated version of its Proposal and Award Policies and Procedures Guide (PAPPG) which provided key reporting updates related to foreign influence. NSF, similar to the NIH, provides guidance on key areas where foreign activity must be reported. These areas are outlined below.
Pre-Award: Grant Application
Biosketch
NSF requires a biosketch for all senior-key personnel listed on an application.
Biosketches for senior personnel must include the following disclosure relating to foreign involvement:
Current and Pending Support
Current and Pending Support by NSF is used to assess the capacity of the individual to carry out the research as proposed, as well as to help assess any potential overlap/duplication/foreign influence with the project being proposed.
Current and Pending Support for senior/key personnel must include the following disclosure relating to foreign involvement:
Gifts do not need to be reported in Current and Pending Support.
Post-Award: Research Performance Progress Report (RPPR)
Current and Pending Support
At the time of technical progress report submission (RPPR), the Principal Investigator (PI) must provide an updated Current and Pending Support file and include the same foreign disclosure information as outlined above if there has been a change in their active other support since the last reporting period.
On 10/5/2020, NSF added the following question related to foreign activity to the RPPR.
What percentage of the award’s budget was spent in a foreign country
The FY2019 National Defense Authorization Act (NDAA), signed into law in August 2018, directs the Secretary of Defense in Section 1286 to establish an initiative to work with academic research institutions on: limiting undue foreign influence (including through talent recruitment programs); supporting the protection of intellectual property and information about national security relevant technologies; and developing domestic talent in relevant scientific and engineering fields. In response to the NDAA, on March 20, 2019, the DoD issued a Memorandum titled “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies.” In this memorandum, DoD outlined disclosure requirements for research and research-related educational activities supported by DoD grants. Subsequently the general application instructions for Congressionally Directed Medical Research Programs were updated with similar instruction to NIH on reporting foreign activity in the biosketch and what they call “Previous/Current/Pending Support.”
When and Where to Disclose Foreign Activity
Pre-Award: Grant Application
Previous/Current/Pending Support
Senior/Key Personnel on DoD Research grants are required to submit the following information as part of Previous/Current/Pending Support in the Senior/Key Person Profile section of the SF424 application, including information on foreign projects or collaborations: For more details see the DoD Congressionally Directed Medical Research Programs General Application Instructions.
Post-Award: Progress Report
Previous/Current/Pending Support
At the time of annual progress report, any updates to Current Support should be submitted to the DoD and ad-hoc as changes arise. The same information as outlined in the pre-award process applies to Previous/Current/Pending Support provided at the time of Progress Report.