July 17, 2019
Foreign Influence on Research: NIH NOTICE on Foreign Interests Released July 10, 2019
UW Research Community:
I am writing to provide an update from the NIH notifying the research community of its obligations in all sources of research support, foreign components, and financial interests and affiliations, foreign and domestic. Clarification is being sought on behalf of research universities, as some of the guidance is unclear and would appear to represent new policy. The summary below is intended to present current, best interpretation of the guidance. Updates will be issued.
Resources and/or financial support from foreign and domestic entities must be reported as Other Support. This includes all resources made available to a researcher in support of, and/or related to, all of their research endeavors. By way of example, NIH emphasizes that all senior/key personnel on an NIH application or award must list:
- Positions and scientific appointments, whether or not remuneration is received. A specific example is an honorary, visiting or adjunct appointment at a foreign university.
- Resources and other support provided directly to the senior/key personnel for their research efforts (whether directly to the individual or through their institution).
- In-kind support, such as lab space, equipment or supplies. It can also take the form of selection to a foreign talent program or similar type program.
- Research collaboration that directly benefits the research endeavors of the senior/key personnel, even if unrelated to the subject NIH grant. One example is a scientist’s (including a visiting postdoc’s) experiments in the senior/key personnel’s lab, funded by another institution.
Other Support requires use of a format that includes the total award amount for, and devotion of person-months to, each form of support. We understand this format is challenging for some of the reportable Other Support listed above. Please estimate to the best of your ability, but in all cases, report it.
Review Other Support Guidance
Any significant scientific element or segment of a project conducted outside of the U.S. is considered a foreign component and requires prior approval. As with any other significant change to a project, please send your request to add a foreign component via OSP as a concurrence request.
This NIH notice also clarifies that activity conducted within the U.S. that involves non-U.S. resource support is not a “foreign component” and does not require prior approval. However, we remind the UW research community:
- Participation on a project in the U.S. is reportable in the research performance progress report (RPPR) in Section D, Participants. If the individual’s primary affiliation is foreign, that is disclosed in the RPPR.
- Foreign support provided to an individual who is participating in a substantive manner on the NIH project should report this as Other Support in the RPPR, Section D.2, Personnel Updates.
Review Foreign Components Guidance
Financial Conflict of Interest
Investigators must disclose significant financial interest (SFI), including that received from a foreign entity, via the UW FIDS system.
Melissa Petersen, Assistant Vice Provost for Research Compliance, will be presenting on the topic of Financial Interest as it pertains to Foreign Interests in an upcoming MRAM meeting.
Review Financial Interest Guidance
Contact by Topic
General Announcements Research home page
General Questions firstname.lastname@example.org
Sponsor Guidance Office of Sponsored Programs
SFI Disclosure and/or Outside Work Melissa Petersen
Web: Foreign Interests in Sponsored Programs