Recently, federal agencies and Congress have raised concerns about threats posed by foreign influence in academic research conducted in the U.S. Their concerns relate to issues such as the integrity of the peer review process, loss of intellectual property and failure to disclose conflicts of interest.
NIH has issued specific clarifications on what constitutes a foreign component in NIH activities as well as what information should be included in the Other Support lists submitted in proposals, Just-in-Time submissions and RPPRs. NSF similarly has updated their guidelines of what to include in the Current and Pending Support and Facilities, Equipment, and Other Resources proposal components. To help you navigate this process, the University’s Office of Sponsored Programs has created a website with links and guidance on how to comply with NIH’s newly clarified policies. Since the NIH is only one of a broad range of sponsors that fund research in the Dietrich School, we supplement their guidance with best practices relating to the issue of foreign influence in all externally sponsored research.
Read on for more detailed information to determine if foreign influence may be a concern in your proposal, and don’t hesitate to reach out to our office with any additional questions.
Bio Sketches and Other Support/Current and Pending Support
Almost all federal sponsors require a bio sketch/CV and a list of current and pending support for PIs, Co-PIs, and other Senior Personnel, either as part of the initial proposal, or at some other time prior to issuing an award. When preparing these documents, you should keep in mind the following considerations in order to ascertain if there may be foreign influence you need to disclose.
NIH Other Support and NSF Current and Pending Support must include all resources that are available to you, regardless of whether they have a monetary value, and regardless of whether they are located at your home institution. This can include start-up funds at institutions other than Pitt, externally funded visitors to your lab, in-kind lab space, externally provided materials and supplies, appointments at other institutions even if no compensation is involved and all other resources available to you as PI.
The Bio Sketch format for most sponsors includes details on your appointments, affiliations and other activities, both foreign and domestic. You should review your bio sketches and make sure that all applicable and relevant information is in accordance with the sponsor’s guidelines. If you are uncertain about the requirements of an individual sponsor, contact your pre-award administrator.
- Foreign Components
In addition to the attention to paid to any potential foreign influence, most federal sponsors also require that proposals disclose any parts of the proposed work that will take place at a foreign location.
- NIH defines a foreign component as “the existence of any significant scientific element or segment of a project outside of the United States.” This can include work performed by a Pitt employee at a foreign location, whether or not NIH funds are expended, as well as work performed by an employee of a foreign organization at a foreign location, whether or not NIH funds are expended.
- All foreign components in NIH-funded projects should be disclosed at the proposal stage. If a PI fails to disclose a foreign component in a proposal, it should be included in the Just-in-Time submission. And if a foreign component that was not anticipated at the proposal stage arises after an award has been issued, it should be disclosed in the next year’s RPPR.
- NSF requires that any proposed International Activities be disclosed at the proposal stage. International Activity is defined by NSF as “research, training and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies.” Any applicable countries must be listed on the Cover Page in the International Activities box, and the activities themselves should be described in the relevant portions of the proposal. (For example, proposed foreign travel could be addressed in the budget justification, and planned international training and research activities could be described in the project description.)
- Complying with Regulations
Take a few moments to review the following checklist, which will help you ensure compliance with foreign influence regulations:
- Review your other support/current and pending support list to ensure that all relevant sources of support, including non-monetary and in-kind support, foreign and domestic, are listed.
- Review your bio sketch to ensure that all academic and professional appointments and affiliations, foreign and domestic, are included, even if no salary support is provided.
- Complete your Financial Conflict of Interest disclosure, and review and update it throughout the year if there are any changes to your financial interests or additional items to disclose.
- Disclose any foreign components on NIH projects that have not previously been disclosed. For pending proposals, this can be done via a Just-in-Time submission, while for active awards, foreign components should be disclosed in your next RPPR.