NIH issued a notification on upcoming changes to the NIH Biographical Sketch and Other Support Format Page, effective May 25, 2021. These changes primarily impact proposal submission, JIT, and RPPR submissions.
In its July 10, 2019 Notice NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies and accompanying FAQs related to Financial Conflicts of Interest and Foreign Components, the National Institutes of Health (NIH) reminded the community (including universities) that applicants and awardees must disclose all forms of research and other support and financial interests, including support coming from foreign governments or-other foreign entities. Support can also include in-kind support such as foreign laboratory facilities (“Shadow Labs”), and other forms of unfunded support.
On July 30, 2021, NIH issued a memo outlining Foreign Interference in NIH funding.
NIH Terms and Guidance
- Used to prevent scientific, budgetary, or commitment overlap
- NIH interprets "financial resources" broadly
Not just salary support from another project but also other forms of support such as carrying out research under an appointment with another institution and that institution provides support in the form of on non-monetary resources
- List all positions and appointments that are relevant to an application whether or not remuneration is received
- Disclose affiliations or appointments that are likely to be cited in NIH-funded publications
- SF424 application asks if the project involves activities outside the U.S. or partnership with International Collaborators
- Any work that will be done in a foreign country should be included in the performance sites section of the application
- All pending support at the time of application submission and prior to award must be reported using JIT procedrues
- Any substantive changes to previously submitted JIT information must be assessed for budgetary or scientific overlap
Research Performance Progress Report (RPPR)
- Any changes to foreign involvement or new foreign involvement should be reported using the RPPR
- If Other Support is obtained after the initial award period, the details must be disclosed in the annual RPPR
- Include visitors who dedicate at least one month of effort to the project in the budget year, whether or not the effort is compensated
- Address any substantive changes by submitting a prior approval request
- For Other Support submissions that include foreign activities and resources, recipients are required to submit copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation. If they are not in English, recipients must provide translated copies. This supporting documentation must be provided as part of the Other Support PDF following the Other Support Format page.
NSF has issued a revised version of the Proposal & Award Policies & Procedures Guide (PAPPG) effective for proposals submitted or due on or after October 4, 2021. A table entitled, NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support identifies where disclosure information must be provided.
On August 18, 2021, NSF issued a memo to the FBI regarding Foreign Interference in NSF Funding.
NSF Terms and Guidance
- Appointments include any titled academic, professional, or institutional position whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary)
- Information must be provided for all current and pending support irrespective of whether such support is provided through the proposing organization or directly to the individual
- All projects and activities that require a time commitment must be reported (no minimum has been established), even if the support received is only in-kind
Facilities, Equipment, and Other Resources
- If in-kind contributions are intended for use on the project being proposed to NSF, the information must be included as part of the Facilities, Equipment, and Other Resources and need not be disclosed in Current and Pending Support
- The NSF proposal application cover sheet asks if there are any international activities and what country/countries are involved
- Support protection of intellectual property, controlled information, key personnel, and information about critical technologies relevant to national security; and
- Limit undue influence, including through foreign talent programs, by countries that seek to exploit United States technology within the Department of Defense research, science and technology, and innovation enterprise
DOD Terms and Guidance
All DoD Notices of Funding Opportunities pertaining to research and research-related educational activities shall require proposers to submit the below information for all key personnel:
- A list of all current projects as well as any future support applied for regardless of source
- Titles and objectives of the other projects
- Percentage of year devoted to the other projects
- Total amount of support
- Name and address of agencies supporting other projects
- Period of performance of other projects
DARPA Countering Foreign Influence Program (CFIP)
On September 17, 2021, DARPA issued guidance that the CFIP team will create risk assessments of all proposed Senior/Key Personnel selected for negotiation of a fundamental research grant or cooperative agreement award. For selected proposals rated as High or Very High risk, the proposer must address the risk during negotiations.
In accordance with Department of Energy (DOE) Directive 486.1A, MSU must disclose Foreign Government Talent Recruitment Program (FGTRP) Participation by any MSU contract participant (funded or unfunded) in a DOE Contract who will access US Government or Government contractor facilities or systems. The following disclosure requirements and restrictions can apply to any DOE-funded contract, subcontract, and federal flow through contract, regardless of where the work is performed.
The directive defines a talent recruitment program as "any foreign-state-sponsored attempt to acquire US scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States."
According to the Contractor Requirements Document, MSU must file reports with DOE on a quarterly basis stating whether or not any of its applicable contract participants are also participants in a FGTRP.
MSU must report to DOE within five (5) business days at any time during the term of the contract, including options and extensions, should any of its applicable contractor participants, applicable subcontractor participants, or joint appointees participating in the contract are or are believed to be participants in a FGTRP.
On identification of an applicable contract participant who is a participant in an FGTRP, MSU will have 30 days to remove the participant, or for the participant to terminate the FGTRP relationship. Failure to remove the participant, or for the participant to terminate the FGTRP relationship may result in DOE/National Security NNSA exercising contractual remedies including contract termination.
Please complete the FGTRP certification and return it to Veronika Jelinkova at email@example.com. Your completed certification will be noted in the ORC&S Training Database and can be verified here. If you have any questions about the directive or Foreign Government Talent Recruitment Programs, please contact Kacey Strickland by email or phone at 5-7474. You need only complete the certification one time even if you are on multiple projects. The certification will not expire so it is important to notify ORC&S if you enroll in a FGTRP in the future.
NASA is prohibited from providing funding to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company - including Chinese Universities and research institutes. This is not a prohibition on the participation of the Chinese nationals. The university must certify compliance with this restriction for each proposal and award.