April 23, 2019
Disclosing Foreign Interests in Sponsored Programs
Update 6.06.19: Review compliance guidance on Foreign Interests in Sponsored Programs
UW researchers whose research is supported with federal funding should update and maintain their current and pending support documentation. Make sure to include all sources of support foreign or domestic
Visiting Scholars and Sponsored Programs:
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.
You do not need to receive prior approval from NIH for a visiting scholar in your lab to work on a project. However, keep these requirements in mind:
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.
Follow sponsor directions for content and format.
National Institutes of Health (NIH) – Other Support
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
NIH: Other Support
National Science Foundation (NSF)
Current and Pending Support – Include all financial resources and commitments of time even if no salary support is received.
Department of Defense (DOD)
- Refer to the specific Notice of Funding Opportunity (NFO) for details on requirement for current support documentation from all key personnel at the proposal stage.
- This info will be required for key personnel whether or not their efforts on the project are DOD funded.
- See UW announcement on DOD Current and Pending Support Information in Proposals.
Department of Energy (DOE)
Refer to specific DOE Funding Announcement instructions on Current and Pending Support
Financial Interests Received from Foreign Institutions:
NIH has reminded the research community that Investigators must disclose all financial interests received from a foreign institution of higher education or the government of another country NOT-OD-18-160:
- Significant Financial interest is defined in GIM 10. It is broad, and includes forms of compensation, equity, sponsored/reimbursed travel, or Intellectual Property.
- Disclose in FIDS, along with any other significant financial interests.
Foreign Talent Programs:
A researcher who is 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
Other Notes on Biosketches, Progress Reports, and Significant Financial Interests (SFI)
- Biosketches should be current and thorough.
- Progress reports for key personnel should indicate any change in support that occurred over the last budget year.
- SFI disclosures need to occur before an application is submitted, annually thereafter, and whenever SFI changes.
Outside Professional Work for Compensation
Approval for outside work relationships with external entities, including foreign entities and governments must be requested in advance as described in
- Executive Order 57: Outside Professional Work Policy and
- Administrative Policy Statement 47.3 : Outside Consulting Activities and Part-Time Employment by Professional or Classified Staff Employees.
Intellectual Property and Inventions
Inventions must be promptly reported:
- To CoMotion, the University’s technology transfer office.
- To federal research sponsors as part of progress reporting.
Researchers must take reasonable efforts to protect the University’s interest (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their UW research.
Intellectual property developed under a sponsored research agreement is subject to the University’s policy on UW IP Disposition in Sponsored Program Agreements.
Individuals serving on NIH, NSF or other federal agency scientific peer review panels should note and comply with all requirements to maintain the confidentiality of the information in research grant applications.
Guidance and Resources
We expect further guidance from sponsors, in the meantime, please review relevant sponsor and UW policies and guidance:
UW Policies and Guidance
UW: Foreign Influence on Federally Sponsored Research
UW: DOD Current and Pending Support in Proposals
GIM 10: Financial Conflict of Interest Policy
GIM 40: UW Intellectual Property Disposition in Sponsored Program Agreements
Executive Order 36: Patent, Invention and Copyright Policy
Executive Order 57: Outside Professional Work for Compensation
NIH: Other Support
NIH: Biosketch Format, Instructions and Samples
NIH: NOT-OD-18-160 – SFI Reminder
PHS: Promoting Objectivity in Research
NSF: Current and Pending Support
NSF: Biographical Sketch(es) – Synergistic Activities
NSF: Collaborations and Other Affiliations
Other federal agency sponsors may have different requirements. Please check the specific funding opportunity announcement and relevant agency grant policies for individual applications.