On July 10th, the National Institutes of Health (NIH) published a reminder on NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components. This was followed on July 11th by a Dear Colleague Letter on protecting research funded by the National Science Foundation (NSF) from NSF Director, Dr. France Córdova. These notices relate to the ongoing concerns regarding foreign influence in federally funded research.
In response to these publications, the OVPR recommends that any collaborations with foreign entities or individuals, or appointments with foreign entities (including foreign talent or similar programs) be disclosed to the NIH or NSF program officer, your Dean, and the OVPR (contacts and additional information listed below).
The OVPR has posted additional guidance on our site regarding Active and Pending Support and Foreign Collaborations. For any questions or for guidance on this and other related matters, please contact:
- Laura Kozma, Executive Director SPS (firstname.lastname@example.org)
- Paul Hudobenko, Director SPS – UConn Health (email@example.com)
Thank you for your cooperation,
Radenka Maric, PhD
Vice President for Research
Important Information from the NIH and NSF for UConn/UConn Health Investigators
The NSF Letter references the draft NSF Proposal and Award Policies & Procedures Guide published in May 2019. Clarifications in the draft Guide related to current and pending support and biographical sketches include:
- Providing information for all current and pending support irrespective of whether such support is provided through the proposing organization or directly to the individual.
- Expanding examples of current and pending support to include non-profit organizations and consulting agreements.
- Reporting all projects and activities requiring a time commitment (no minimum has been established), even if the support received is only in-kind.
- Appointments should include any titled academic, professional, or institutional position whether or not remuneration is received.
The Dear Colleague Letter also states the NSF will be issuing a policy that NSF personnel and Intergovernmental Personnel Act (IPA) assigned personnel cannot participate in foreign government talent-recruitment programs.
The NIH Notice reminds applicants that in regards to Other Support, they must:
- List all positions and scientific appointments, both domestic and foreign, held by senior/key personnel which are relevant to an application including affiliations with foreign entities or governments such as titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
- Report all resources and other support for all individuals designated in an application as senior/key personnel – including the program director/principal investigator and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. All current support for ongoing projects must be included, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual who supports the senior/key personnel’s research efforts.
- Report all current projects and activities involving senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees), including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support.
- Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel.
The Notice also reminds applicants of the need to determine whether projects include a foreign component, defined as the existence of any “significant scientific element or segment of a project” outside of the United States including:
- Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
- Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.
If a significant portion of a project will be conducted outside the United States, then there is a foreign component and NIH prior approval is required. If all project activity is conducted within the United States, but there is a non-U.S. resource supporting the project, it must be reported as other support.