Disclosure of Foreign Research Support and Collaborations
Texas Tech encourages international collaborations – and it is important for Texas Tech investigators to be transparent about their relationships and activities. It is also important for all investigators to be aware of what must be included in proposals and progress reports for extramural support.
Here are some of key policy reminders:
On 10 July 2019, the National Institutes of Health issued a Notice (NOT-OD-19-114) reminding investigators that anyone who applies for or receives NIH support must disclose all resources, positions, and scientific appointments. The Notice contains the full guidance. On 11 July 2019, the NIH blog Open Mike provided the synopsis (emphasis added):
On 11 July 2019, the National Science Foundation issued a Dear Colleague Letter on "Research Protection", emphasizing that maintenance of a diverse research community and robust international collaborations requires "[a] renewed effort ... to ensure that existing requirements to disclose current and pending support information are known, understood, and followed."
On 07 June 7 2019, the Department of Energy issued a Directive mandating that federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.
On 20 March 2019, Michael D. Griffin, Under Secretary of Defense (Memo on Actions protecting Intellectual Property, Controlled information, Key Personnel, and Critical Technologies) directed changes in DoD Notices of Funding Opportunities, to take effect in 30 business days from the date the memo was issued. Funding Opportunities supported by grants, cooperative agreements, Technology Investment Agreements, and other non-procurement transactions will require submission of information for all key personnel working on an activity, regardless of whether the individual's efforts are funded by the DoD. The information required is outlined in the memo and mirrors that required by NIH and DOE.
Key points for PIs and key personnel:
- Disclose all of your professional appointments, whether compensated or uncompensated,
in the biographical sketch, including (but not limited to) appointments that you hold
at other institutions (e.g., visiting scientist, professor, adjunct) – with dates
- Disclose any planned collaborations – official or unofficial – with foreign or domestic
organizations in your proposals, including dates. Collaborations include, but are
not limited to, exchanges of data, materials, personnel, or confidential information.
- Disclose all of your sponsored programs in your Current and Pending Support pages
for federal proposals and progress reports, per agency instructions. This includes
programs sponsored by foreign governments at foreign institutions.
- When an agency asks about "other funding" for a project (Note – for NSF and many other federal agencies, you answer this question in the proposal;
for NIH, you answer when asked for Just-In-Time information), disclose all key personnel's
other projects and funding so that the agency can evaluate potential scientific, commitment,
or budgetary overlap. That means, respectively:
- You have identified whether any other organization, US or non-US, is supporting the
research outlined in your proposal. If you are named as key personnel in a funding
award from a foreign sponsor made to a foreign institution, such an award must be
- You have included all resources made available to your research team in support of
and/or related to all of their research endeavors, regardless of whether or not the
resources have monetary value and regardless of whether they are based at TTU. This
includes resource and/or financial support from all foreign and domestic entities,
including but not limited to, financial support for laboratory personnel, and provision
of high-value materials that are not freely available (e.g., biologics, chemical,
model systems, technology, etc.). See NOT-OD-19-114 for more information about necessary details.
- You have identified all time commitments. Federal agencies do not recognize a difference
between your primary appointments held at a U.S. university and other appointments
held at foreign institutions. They want information about all of your formal professional
commitments. The total commitment of your time, or of the time of project-supported
personnel, cannot exceed 100 percent.
- You have not requested funding for items already paid for by any other source, including items paid for in a foreign country by a foreign sponsor.
- You have identified whether any other organization, US or non-US, is supporting the research outlined in your proposal. If you are named as key personnel in a funding award from a foreign sponsor made to a foreign institution, such an award must be disclosed.
We urge you to apply these principles to all your funding proposals.
Assistance with Organizing Proposals and Collaborations Involving Foreign Institutions
We urge the TTU community to continue research that involves participation by foreign nationals and institutions in accordance with the guidelines of the sponsoring agency. The Office of Research and Innovation will provide assistance to faculty and staff researchers with questions about organizing and managing such relationships.