Follow Up – Disclosing Foreign Interests in Sponsored Programs

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Submitted by stonewil on

Following our April 2019 MRAM presentations on Foreign Influence:  Increased Scrutiny of Foreign Interests and Sponsor Response to Foreign Influence Concerns, we have more guidance and resources to share. 

This information is also published on the Research website along with other relevant guidance previously communicated. See Disclosing Foreign Interests and Sponsored Programs.

We anticipate more to come from sponsors and will keep you posted as we have other information. 

Visiting Scholars and Sponsored Programs

Proposals:

A visiting scholar should submit other support documentation, if he/she will contribute in any way to the research set out in the scope of work. Submit in the format required by the sponsor and at the time the sponsor requires.

On-going projects:

You do not need to receive prior approval from NIH for a visiting scholar in your lab to work on a project. However, keep in mind these requirements:

  • Report all participants on a project within your progress report. This section also requests whether the individual’s primary affiliation is with a foreign organization.
  • Consider Visiting Scholars working on the project as Key Personnel, thus triggering the need to submit his/her Biosketch and Other Support in the “ Personnel Updates” section of the RPPR, if you haven’t already.

NIH: Other Support

Follow sponsor’s directions for content and format. Interpret “financial resources” broadly. It is not just salary support an individual receives from another project, but other forms of support of the individual’s research, e.g.:

  • Individual named on another project, but not receiving salary support
  • Individual carries out research efforts under an appointment or affiliation with a foreign institution or entity and that institution provides support in the form of non-monetary resources

NSF: Current and Pending Support

NSF Current and Pending Support guidance -  Include all financial resources and commitments of time.

Financial Interests Received from Foreign Institutions:

A researcher participating in a foreign talent program may not at the same time receive support from a DOE grant or contract. A researcher wishing to seek DOE funding who is in such a talent program must remove his/her association with the talent program before receiving DOE funding.
Please see:

  • DOE current requirements on this ban
  • Specific DOE Funding Opportunity Announcement (FOA) for current and pending support requirements

Related Guidance and Resources

UW Guidance and Resources

Sponsor Guidance

Other federal agency sponsors may have different requirements. Please check the specific funding opportunity announcement and relevant agency grant policies for individual applications.