Sponsor Requirements: Biosketch, Current & Pending & Other Support
Investigators should familiarize themselves with the information provided by OVPR
as well as specific guidance from their respective funding agency. Ultimately it is
the Investigator's responsibility to appropriately disclose relationships, activities
and components in accordance with internal and external policies.
We strongly encourage investigators to err on the side of transparency when considering
or reporting a foreign activity. At some institutions, failures to disclose foreign
connections or other regulatory violations have resulted in personnel actions and
even indictments by law enforcement. Some federal funding agencies have stated that
investigators who fail to disclose appointments or support from foreign entities may
be ineligible to receive funding.
Definitions of terms may differ by sponsor as the federal agencies have not adopted
standard definitions or reporting requirements. Investigators should read sponsor
guidelines and requirements to ensure that they are disclosing and reporting in accordance
with the specified agency.
Presently, there is no uniform practice among federal funding agencies for disclosing
relationships, activities or components of research activities. There exist multiple
ways in which such disclosures may be included in grant proposals and progress reports,
depending on the funding agency. In addition, funding agencies provide guidelines
for information to be included in publications resulting from grants and contracts.
They also generally require that all publications resulting from sponsored research
must be reported, typically in annual and final progress (or technical) reports.
PROPOSALS AND AWARDS
- Approach the Office of Sponsored Programs (OSP) if your proposal includes foreign
collaborations, foreign components and/or activities in a foreign country. Outreach
early and discuss with your OSP Specialist as they will provide you with current institutional and Sponsor policies/guidelines.
- Read sponsor guidelines, Funding Opportunity Announcements (FOA), and proposal questions
(i.e. NIH Other Project Information Form Question #6 asks "Does this project involve
activities outside of the United States or partnerships with international collaborators?")
carefully to ensure that you and other project personnel are correctly answering the
questions that address foreign engagements, foreign affiliations, and Foreign Components
and collaborations, as required by the sponsor.
- At award stage, review agency definitions to verify that your interpretation of your
sponsor's terms and conditions included in a notice of award and grants policy statements
is correct. The Office of Sponsored Programs and your sponsor's program and grants
management staff can be contacted with questions about definitions.
- Review current projects to ensure that all locations outside the U.S. where significant
scientific activities are performed have been disclosed through progress reports and
final technical reports (as applicable).
- Review each funding application to ensure that all resources available in direct support
of an individual’s research activities (Other Support) is disclosed as required by
the federal sponsor at the time of proposal submission, Just-in-Time/pre-award negotiation
- Identify foreign countries where the research activities are being conducted.
- Obtain Sponsor prior approval through OSP when adding a foreign component to an existing federal award.
- Determine if sponsor approval is required for international collaborations resulting
- Cite in manuscripts only the funding which specifically supports the work in the publication.
- Do not cite unrelated financial support in publications.
- Check the funding agencies guidelines for information to be included in publications
resulting from grants and contracts.
- Carefully review the sponsor's guidelines for reporting publications in reports (i.e.
progress or final) as some sponsors differentiate between publications where funding
specifically supported the work in the publication and all other publications.
FOREIGN TALENT PROGRAMS
- Disclose participation in foreign talent programs to federal sponsors and the university.
Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) on
National Security Strategy for United States Government -Supported Research and Development
Department of Energy definition: Distinguishing features of a foreign government talent recruitment program (covered
by this policy) include:
(a) Compensation provided by the foreign state to the targeted individual in exchange
for the individual transferring knowledge and expertise to the foreign country. The
compensation can take several forms, such as cash, research funding, honorific titles,
career advancement opportunities, promised future compensation, or other types of
remuneration or other consideration.
(b) Recruitment refers to the foreign state sponsor's active engagement in attracting
the targeted individual to join the foreign-sponsored program and transfer their knowledge
and expertise to the foreign state. The targeted individual may be employed and located
in the United States, or in the foreign state.
Note that, generally, an invitation by a foreign state to simply attend or present
work at an international conference would not constitute recruitment.
Contact the Director of Research Security or the Vice-President for Research if you
have not disclosed participation in a foreign talent program to discuss the activity.
The Office of the Vice President for Research (OVPR) continues to monitor new regulations
and guidance provided by funding agencies regarding foreign relationships and activities,
and we will inform the University community of relevant changes. Updates and new information
will also be provided on this page.