Disclosing foreign relationships and activities
Requirements vary by agency and funding opportunity. Please check the specific funding opportunity announcement and agency grant policies for individual applications. In the event that other federal funding agencies announce changes to their disclosure and reporting obligations, this page will be updated.
The National Science Foundation (NSF)
The “Current and Pending Support” section of grant proposals must include all proposed and ongoing projects of the Principal Investigator and senior personnel, even if no salary support is received from the project.
“Collaborators and Other Affiliations” (COA) information must be provided for each individual listed as senior project personnel. This information includes all organizational affiliations for the previous 12 months and any co-authors or collaborators in the previous 48 months.
NSF Dear Colleague Letter: Research Protection (July 11, 2019)
The National Institutes of Health (NIH)
The NIH requires reporting of all “other support,” meaning all financial resources, domestic or foreign, available in direct support of an investigator’s research. The NIH provides opportunities to disclose at multiple steps in the application and funding processes:
- On the grant application: Applicants are asked to check a box on the grant application “other information” page if they have international collaborators.
- In the Biosketch: In new and renewal grant applications, all applicants are asked to complete the Research & Related, Senior/Key Person Profile as part of the Biosketch. Each investigator on the grant must upload a document listing other support and relevant affiliations.
- “Just-in-Time application information provides another opportunity to disclose foreign support.
Under the NIH Grants Policy Statement, a “foreign component” is defined as “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.” The definition of “foreign component” may include a large number of collaborative activities, including “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.” Other sponsors have similar requirements to disclose foreign components.
The Department of Defense (DOD)
Beginning in the second quarter of 2019, DOD notices of funding opportunity for research and research training will include a requirement for current support documentation from all key personnel at the proposal stage, whether or not the key personnel on the project are DOD-funded. The requested information will include:
- A list of current projects the individual is working on, as well as any future support applied for regardless of source;
- Titles and objectives of the other projects;
- Percentage per year devoted to the other projects;
- Total amount of support the individual is receiving or will receive;
- Name and address of agencies and/or other parties supporting other projects; and
- Period of performance for the other projects
The Department of Energy (DOE)
Refer to specific DOE Funding Announcement instructions on Current and Pending Support.
1. Disclose all “Other Support” / ”Current and Pending Support” as required by federal sponsors.
Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all other support has been disclosed, which must include any direct research support provided the investigator, even if it is not administered by WSU. If a PI identifies an omission or error in a previously submitted proposal, he or she should contact the Office of Research Support & Operations [email@example.com] to have the error corrected. For key personnel, progress reports should indicate any change in other support that occurred over the last budget year.
Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.
2. Disclose “foreign components” of federally-funded research on proposals, progress reports, and final technical reports.
PIs should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Support & Operations at firstname.lastname@example.org to have the error corrected.
There are multiple ways in which foreign components can be disclosed. For example:
- Identifying a “foreign component” in an NIH grant application;
- Listing a “non-U.S. performance site”;
- Identifying foreign relationships and activities in a biosketch;
- Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
- Financial resources should be disclosed even if they relate to work performed outside of appointment period. For example, if a researcher has a 9-month appointment and conducts research at a university outside of the U.S. under a foreign award during the summer, that activity should be disclosed.
3. Financial Conflict of Interest (FCOI)
Investigators who share responsibility for the design, conduct and reporting of Public Health Service-supported research (which includes NIH) must disclose all personal financial interests related to their institutional responsibilities, through the MyResearch system. Required disclosures include income and reimbursed or sponsored travel. Investigators, including subrecipient investigators, must disclose all financial interests received from a foreign institution of higher education or the government of another country (which includes local, provincial, or equivalent governments of another country).
4. Significant Financial Interest (SFI)
A “Significant Financial Interest” (SFI) is a financial interest of the Investigator (and the Investigator’s spouse and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities and that meets one or more of the following criteria:
- With regard to any publicly traded entity, if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000;
- With regard to any non-publicly traded entity, if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
Investigators must disclose their Significant Financial Interests (SFI’s) at the following times:
- When submitting a proposal related to HHS or PHS FCOI applicable sponsors (direct or flow-through funding) and/or when the COI box is checked yes on the eREX Form;
- When a new SFI is discovered or acquired (e.g., through purchase, marriage, or inheritance);
- Annually, when funded
- When travel is reimbursed or sponsored (i.e., travel expense paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available), related to the Investigator’s WSU Responsibilities, with some exceptions
Disclosures are reviewed by the Conflict of Interest Committee to ensure conflicts are properly managed or eliminated. A financial conflict of interest management plan may be developed in certain cases.
5. External activities
External activities within the scope of a researcher’s university responsibilities must be disclosed through the Conflict of Interest process and through any NIH or NSF required reporting mechanism.
6. Individuals serving on NIH, NSF or other federal agency scientific peer review panels should note and strictly comply with all requirements to maintain the confidentiality of the information in research grant applications.