IMPORTANT Update to Foreign Disclosure Requirements

Over the spring and summer, we have been communicating regarding the U.S. government’s recent focus on faculty compliance with disclosure requirements, including disclosure of foreign engagements related to federally-funded research.

In addition to the guidance issued by our University General Counsel we’d like to call your attention to some other helpful resources:

  1. NIH Frequently Asked Questions about Other Support and Foreign Components – updated 8/6/2019
  2. NIH Notice of Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
  3. NSF Dear Colleague Letter on Research Protection
  4. AAU/APLU “institutional best practices” PDF document dated 4/22/2019
  5. Penn State website
  6. UMass contacts who can assist

Best practices for faculty engaging in international activities and collaborations include:

  1. Properly securing prior approval for all outside activities in accordance with university policy; ensuring any outside activity that includes an effort commitment does not overlap/conflict with Federal or university effort obligations.
  2. Fully and completely disclosing in your proposal any foreign collaboration or engagement overlapping with or contributing to a federally-funded research project, whether you expect to use Federal funds to support it or not; for NIH, checking “yes” to foreign component question on forms.
  3. Ensuring disclosure of any and all financial resources (e.g., cash, in-kind, foreign research support to collaborators, fellowship funds) related to a proposed scope of work submitted to a Federal sponsor; using “Other Support,” “Equipment, Facilities & Other Resources,” or “Current & Pending Support” sections to fulsomely describe the foreign resources.
  4. Including any and all foreign faculty appointments, employment or consulting on a public-facing version of your curriculum vitae.
  5. Ensuring up-to-date financial conflict of interest (COI) disclosures are submitted in the Kuali COI module, including for reimbursed travel, honorarium payments, speaking fees, etc.
  6. Fully disclosing all activities, affiliations, and relationships in accordance with the policies of outside organizations such as scientific journals and professional societies when speaking, publishing, or teaching.

For any questions, please contact the Office of Research Compliance (413-545-5283, or the appropriate contact identified in the contacts list linked above.

Posted: 9/11/19