NIH policy requires all individuals included in an application as senior/key personnel – including the program director/principal investigator and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way to disclose “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,” and for determination to be made if the project activities include a foreign component, “significant scientific element or segment of a project to be performed outside the United States.”

Foreign engagement and other support should be disclosed in proposals, and in interim and final Research Performance Progress Reports. Specific disclosure of “Foreign Components” is to be disclosed on its Research and Related Other Project Information Form submitted with proposals. This disclosure is in Item 6 of the Research and Related Other Project Information Form

Throughout a project if the need arises to include a foreign component, it requires NIH prior approval and should always be included in the foreign components section of the RPPR Report, Section G.9.

Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.

NIH Resources

• Letter from NIH Director Francis Collins.
• Statement on Protecting the Integrity of U.S. Biomedical Research
• NOT-OD-18-160 Financial Conflict of Interest Disclosures of Foreign Financial Interests
• NIH FAQs on Other Support and Foreign Components.
• NIH Grants Policy Statement, Section 1.2, definition of “other support”.
• Other Support.
• Biosketch Format Pages, Instructions and Samples

NSF policy requires full disclosure of domestic and foreign engagements, regardless if funded or unfunded. Disclosures are to occur in current and pending support; annual reports; final reports and biosketches.

Biosketches – domestic and foreign appointments, funded and unfunded (e.g., scientific advisor, consultant, etc.) are to be included in the “Appointment Section.”  In addition, submission of an update can occur by your SRO through the “Other request” category in the Notification and Request Module in Research.gov

Note: Starting prior to October 5, 2020, if/when ASU discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the PI or co-PI must work with the AOR on submission of the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.

Resource:  October 5, 2020 Significant Change

Additional information and links to the forms are available on the NSF biographical sketch and current and pending support websites, and in the NSF Fillable PDF FAQs

Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.

Resources

• NSF Training Webinar
• NSF PAPPG 2020
• Current and Pending NSF FAQs
• NSF director’s letter on research protection.
• Collaborations and Other Affiliations Information.

DOD policy requires full disclosure for all key personnel, in addition to PI or Co-PI, even if efforts are or are not to be funded by DOD., domestic and foreign engagements/support, regardless if funded or unfunded. Disclosures are to occur in Current and Pending Support as announced in March 20, 2019 memo. This memo applies to new research activities after April 19, 2019 and applies to grants, cooperative agreements, etc. If you have a DOD contract, please review terms and conditions as it may have additional requirements.

DOE policy requires full disclosure, domestic and foreign engagements/support, regardless if funded or unfunded. Disclosures are to occur in Current and Pending Support as announced in DOE FY 2020 Continuation of Solicitation for the Office of Science Financial Assistance Program. Include as an appendix to your project narrative. Do not attach a separate file.

NASA requires full disclosure, domestic and foreign engagements/support, regardless if funded or unfunded. Disclosures are to occur in Current and Pending Support as outlined in NASA Guidebook for Proposers Responding to a NASA Funding Announcement.

If you are a co-investigator and spending more than 10% of your time on an active award or pending proposal, regardless if funded or unfunded, then you do need to disclose on your Current and Pending Support.

As a reminder, the proposal you will be submitting does not need to be included on your Current and Pending Support, unless you have submitted the same proposal to another agency.

If you have a NASA contract, please review terms and conditions as it may have additional requirements.

Resources

NASA grant restrictions and contract restrictions.

Additional federal funding agencies information

• Public Health Service: Promoting Objectivity in Research.
• PHS: Financial Conflict of Interest, Title 42 CFR 50, Subpart F.
• John S. McCain National Defense Authorization Act for Fiscal Year 2019.

• To fully and accurately disclose domestic and foreign engagements to ASU, including equity interests in foreign entities and/or if you need to update your conflict of interest financial disclosure, contact ASU Research Operations at [email protected].
• Obtain restricted party screening of foreign collaborators and including foreign visitors.  Contact [email protected]
• As you are developing your proposal include a clear description of all foreign collaborations
• Review your active awards and pending proposals to ensure all locations outside of the United States have been disclosed to the federal agencies and ASU.
• Ensure that any material transfers, data sharing and confidential information are covered by an agreement. Contact the Office of International Research Collaboration at [email protected] should you need assistance with the development of an agreement.
• Be aware of and follow peer review regulations, including confidentiality provisions related to the content provided during the review.
• Obtain export control review for incoming and outgoing collaborations, including traveling abroad and international rework requests – whether funded or unfunded.  Contact [email protected]

1. If I have been approached by a domestic or foreign entity for an appointment (e.g. visiting, adjunct, honorarium), who should I discuss this with?
   
   Please contact your Research Administrator so they can coordinate and facilitate with your departmental leadership and the Office of Research Integrity and Assurance.
   
   Note: Your Dean’s Office needs to be aware of any proposed arrangement(s) before entering into any of them. 
2. Are there foreign activities, which should be disclosed to ASU and federal sponsors? Yes, those activities may include but are not limited to the following:
   1. Consultancy agreements
   2. Salary, living, lodging, research space or other reimbursements
   3. Travel funds
   4. Ownership in a foreign company
   5. Research collaboration (e.g., funded or unfunded) and/or affiliations 
3. If it has come to your attention that a disclosure needs to be made to ASU  that hasn’t been previously reported, how should I manage disclosure at this time?
   
   Contact [email protected] to discuss how to best work through the best way to correct this omission or error.
4. If it has come to your attention that a disclosure needs to be made to a Sponsor that hasn’t been previously reported, how should I manage disclosure at this time?
   
   Contact [email protected] to discuss how to best work through the best way to correct this omission or error. 
5. I am working and/or collaborating with another institution – domestic or foreign? How do I disclose this to ASU?
   
   This work is considered outside activity. For ASU, it is required to be disclosed through our COI process. Please contact [email protected]
   
   Dependent upon the sponsor, regardless if funded or unfunded should be disclosed in current pending support, biosketches, other support, facilities, equipment and other resources documents, annual reports, final reports, Just-In-Time, etc. Please work with your Research Advancement contact. 
6. Should foreign affiliations be included on my biosketch?
   
   Yes, all affiliations – domestic and foreign –  regardless if funded of unfunded, should be included on your biosketch. 
7. If I am contacted by a sponsor regarding a past or current foreign engagement, how should I respond?
   
   Do not respond directly. These responses need to come from the Institution. Please contact [email protected] and Assistant Vice President, Research Operations [email protected] 
8. A sponsor – domestic or foreign – has requested information outside of what I am required to provide under an agreement; how should I respond?
   
   Please contact your Research Administrator, so they can work with a Contracts Officer within ASU Office for Research and Sponsored Projects Administration.
    
9. If I have/will have foreign visitors (scholars, engineers, scientists, students, etc.) visiting ASU now or in the near future, what actions do I need to take?
   
   Please contact your Research Administrator so they can coordinate and facilitate with your departmental leadership and the Office of Research Integrity and Assurance. 
10. If a Visiting scientist/scholar/student/engineer is visiting a laboratory more than a few days a week in an academic or in research capacity, should it be disclosed?
    
    Yes, if they are using up your potential capacity as the PI/Co-I/researcher
11. Do Material Transfer Agreements (MTAs) need to be disclosed?
    
    They do not need to be disclosed on your current and pending support as they are a tool to perform the activities.  They should be referenced in the “Facilities” section of your proposal.