Disclosing International Relationships and Activities to UF and Federal Sponsors

The University of Florida values and encourages international research, collaboration, and scholarship. It is through our scholarly relationships—both domestic and international—that our faculty, staff, and students continue to generate innovations and discoveries that leave lasting impacts across the globe. The University is equally committed to adhering to regulatory requirements and being a good steward of state and federal resources in executing UF’s mission.

There is growing concern regarding certain agreements and activities between university faculty members and various foreign universities and institutions, the existence of which may have a negative impact on federal funding decisions for individual researchers. Of particular concern are the cases where researchers are not disclosing these relationships and activities to their university or to U.S. federal sponsors of their work.

The recent message from the funding agencies is clear: investigators and their universities must completely disclose all foreign activities to their sponsors.

What International Relationships and Activities Must Be Disclosed?

Disclosures to UF

All UF employees are required to report any outside activity related to their University expertise, whether domestic or foreign, and coinciding with the term of their UF appointment, for review and approval via the UF outside activity disclosure process. For more information about what and how to disclose to UF, please visit the COI program website at https://coi.ufl.edu/.

Disclosures to Sponsors

Federal sponsors generally require broader disclosure than UF. Outside and inside activities must be reported to federal sponsors. All federally sponsored investigators and key personnel must report any activity that supports their research endeavors to sponsors, regardless of: (1) whether it is an activity conducted within the scope of their UF job (i.e., an “inside activity”) or conducted in their private capacity (i.e., an “outside activity”); and (2) whether it coincides or not with the term of their UF appointment.

Foreign Government Talent Recruitment Programs

As part of the national discussion of inappropriate foreign influence on U.S. research, many federal sponsors, including NIH and NSF, have cited foreign talent recruitment programs as posing a particular threat to the U.S. research community. Participation in foreign government talent recruitment programs (FGTRP) often involves academic or research affiliations with foreign institutions, financial or other in-kind support for a U.S. researcher’s program, and commitments of time and resources from the U.S. researcher.

Both UF and federal sponsors require disclosure of participation in FGTRP. Additionally, activities similar to those described above but not labeled as a foreign talent recruitment program must be disclosed (i.e., affiliations or appointments at another institution, whether or not remuneration is received, and whether full-time, part-time, or voluntary—including adjunct, visiting, or honorary). Additional information about these programs can be found at _FBI PSA 20200716-2_.

Other Foreign Engagement Examples

Within the context of foreign engagements, the examples below illustrate activities one would disclose to UF and federal sponsors if performed in a private capacity. If performed within the scope of one’s UF job, these activities would need to be reported to federal sponsors only. Note that the below list is not exhaustive, but represents the types of engagements that must be disclosed.

  • Academic, research, or administrative appointments at a foreign institution, even if the appointment is uncompensated. This includes appointments that are full-time, part-time, honorary, adjunct, or voluntary.
  • Any agreement with a foreign university for which the UF faculty member directs non-UF students, postdocs, or other personnel affiliated with that university.
  • Any foreign affiliation that is included in any publication by the UF faculty member.
  • Any contractual agreement with a foreign institution, company, or government agency.
  • Any non-UF agreement in which foreign funds or other resources are provided to the faculty for activities either at UF or at a foreign institution.
  • Any agreement or relationship that assigns intellectual property (IP) rights to the foreign institution.
  • Any agreement or relationship with a foreign entity in which the UF faculty member receives payments for salary, stipends, or living expenses.
  • Any consulting agreements with a foreign entity.
  • Holding a position such as founder, partner, employee, or board member at a company, non-profit, governmental agency, or other foreign entity.
  • Receiving living/lodging funds or reimbursements.
  • Having significant ownership interest in a foreign company related to your UF role/responsibility.
  • Financial interests in a foreign entity that does business with or competes with UF (including seeking research funding).
  • Receiving travel funds or reimbursements from a foreign entity.
  • Receiving an honorarium from a foreign entity.

Disclosing Foreign Activities to NIH

For NIH, the disclosure of foreign activities should be included in Other Support, Foreign Component, Facilities and Resources, and/or Biosketch. All communications with NIH must be routed through DSP prior to submission to NIH.

Disclosing Foreign Activities to NIH as Other Support

NIH Definition of Other Support – NIH requires senior/key personnel to disclose all resources made available to them in support of or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of the performance site of the research. Even if the researcher performs the activity outside of the researcher’s UF appointment period (e.g., a nine-month faculty member conducts the activity during the summer months) or at a location other than UF, the researcher must disclose the activity.

Examples of Other Support include, but are not limited to, the following when they are in support of an investigator’s research endeavors:

  • Domestic and foreign grants and contracts, whether provided through UF, another institution, or to the researcher directly;
  • Financial support for laboratory personnel (e.g., students, postdocs, or scholars working in a researcher’s lab at UF and who are supported by a foreign entity either through salary, stipend, or receipt of living or travel expenses);
  • Provision of lab space at another institution, foreign or domestic;
  • Provision of scientific materials that are not freely available for use at UF or another institution where the faculty is working (e.g., biologics, chemical, model systems, technology, equipment, etc.);
  • Travel expenses directly paid or reimbursed by an outside entity;
  • Living expenses directly paid or reimbursed by an outside entity; and
  • Other funding (e.g., salary, stipend, honoraria, etc.) paid to a UF researcher by an outside entity.

NIH requires Other Support to be submitted as part of the Just-in-Time procedures. All other support indicated above must be included in that process. Researchers are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award. Submission of JIT or any changes must be routed through UF’s DSP.

See Protecting U.S. Biomedical Intellectual Innovation for additional information on Other Support.

After the initial NIH award, researchers must disclose changes in other support in the annual research performance progress report (RPPR). Additionally, for post-award disclosures of other support, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”

Disclosing Foreign Activities to NIH as Foreign Component

NIH defines “foreign component” as the performance of any significant scientific element or segment of a project outside of the U.S., either by the recipient (including any UF employee), by a subrecipient or by a researcher employed by a foreign entity, whether or not grant funds are expended. There is a 2-part test for determining whether an activity meets the definition of foreign component: (1) whether a portion of the project will be conducted outside of the U.S. and (2) whether that portion of the project is significant. Some examples of activities that may be considered a significant element of the project include, but are not limited to:

  • Collaborations with investigators at a foreign site anticipated to result in co-authorship;
  • Use of facilities or instrumentation at a foreign site; or
  • Receipt of financial support or resources from a foreign entity.

At the time of application submission, if there is an anticipated foreign component, researchers must check yes to question 6 on the “R&R Other Project Information” form “Does this project involve activities outside of the United States or partnerships with international collaborators?” and include a “Foreign Justification” attachment in Field 12 “Other Attachments.” The Foreign Justification should describe the special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting.  This information must match the information provided in the UFIRST Proposal on page 3.0.

If researchers want to add a foreign component to an ongoing NIH award, UF must receive prior approval before adding the foreign component. To seek prior approval, researchers must submit their request through UFIRST as an Award Modification and must include information to allow DSP to support the process identified in NIHGPS Section 8.1.2.

Disclosing Foreign Activities to NSF, DOE, DOD, and Most Other Federal Agencies

For NSF, DOE, DOD, and other non-NIH agencies, the disclosure of foreign activities should be done within Current and Pending Support and/or the Biosketch.

Disclosing Foreign Activities as Current and Pending Support

For many agencies, the term “current and pending support” refers to the types of “other support” described above for NIH. NSF has developed an electronic format and fillable PDF for the disclosure of current and pending support information effective October 5, 2020. These approved formats must be used by PIs and Co-PIs in proposals. NSF has also established a new requirement for the post-award disclosure of current support and in-kind contribution information, effective October 5, 2020. If a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the university must submit the information to NSF within 30 calendar days of the identification of the undisclosed support. NSF will determine the impact of the information and any appropriate action, if necessary. See UF’s guidance for this on the NSF Updates page.

Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value. Current and pending support also includes in-kind contributions (such as office or laboratory space, equipment, supplies, employees, or students). See also the NSF FAQs related to reporting Current and Pending support.

For other agencies, including DOE and DOD, investigators should list foreign engagement activities with the “current and pending support” construct.

Disclosing Foreign Affiliations in Biosketch

Researchers should include all affiliations on their Biosketch. This includes any titled academic, professional, or institutional position, foreign or domestic, whether full time, part time, or voluntary, and whether or not compensation is received (including adjunct, visiting, or honorary). For NSF, these affiliations must be listed under the Appointments section in one of the approved formats effective October 5, 2020. Additionally, some affiliations or participation in foreign talent recruitment programs may also meet the definition of other support. If so, researchers should disclose the activity as described in the “current and pending” section above as well.

Prior to accepting any affiliation with another institution that requires a commitment of time or resources, and irrespective of whether the affiliation is compensated or not, UF faculty need to disclose the activity to the University and receive approval. This includes participation in foreign talent recruitment programs or other affiliations/appointments at another institution. Disclosure to UF requires that UF faculty use UF’s electronic system for disclosures, UFOLIO. Additional information on UF’s disclosure of outside activities process is within UF’s “Policy on Conflicts of Commitment and Conflicts of Interest.”

Frequently Asked Questions

In light of these issues, should UF researchers continue international collaborations?

Yes! International collaboration is a cornerstone of academia and is a critically important aspect of faculty and student life at UF. There are many options to pursue international collaborations at UF via university-to-university agreements, research sponsorship agreements, visitor and student exchange, etc. If you would like more information about how UF | Research can support your international collaborations, please visit our Global Support page.

Should UF faculty reduce the amount of international travel on UF business for themselves and their students?

No. For many years, the University—through the UF International Center and Global Support – has provided country-specific guidance for UF persons traveling abroad, focused on concerns regarding safety, security, and compliance obligations. The guidance has changed little with the recent concerns discussed above.

What are Federal Agencies Saying?

The University will continue to post updates and clarifications as we receive them from our sponsors. We encourage UF researchers to review federal, sponsor and UF policies and procedures, and to thoroughly disclose relationships and activities to federal sponsors UF as required by applicable policies and regulations.

What do I do if I now see something I need to disclose to UF or a sponsor that I have never previously reported?

Whether you need to correct an omission or error in a previously submitted proposal or progress report, or you have a new activity to report, please contact the Division of Sponsored Programs at ufproposals@ufl.edu.

How do I disclose my foreign outside activities to UF?

Please visit https://coi.ufl.edu/ for instructions how to disclose outside activities to UF.

I am receiving in-kind support, such as an unpaid researcher or student working in my lab, material, reagents, direct-paid travel, or other items of value. How should I disclose this?

Scholars, researchers and students working in your lab with direct support from any organization other than UF (including those who identify as “self-funded”) must be listed on your Other Support or Current & Pending Support Documents (the label differs between sponsors).

Any other resources (including cash gifts, materials, reagents, equipment, direct paid travel, or items of value such as free sequencing, data access, tissues, etc.) that support your research program should be listed as Other Support.  More information about disclosing these types of support to sponsors can be found at:

I have an affiliation (paid or unpaid) at another institution. How should I disclose it?

Any affiliations or appointments (foreign or domestic) require prior approval through the University’s Outside Activities reporting process at https://coi.ufl.edu/.  Further, for the purposes of completing sponsored program applications, such affiliations should be reported in the positions and honors section of your Biosketch.

I have work that is funded through another institution. How do I disclose it?

If you receive funding for performance of work at another institution, that work is considered an outside activity and must be disclosed to UF in accordance with the UF outside activity policy. Additionally, the research funding must also be disclosed in the Other Support or Current and Pending section of proposals and annual reports.

I have received startup funds from the University of Florida in support of my research program. Do I need to disclose that resource to federal sponsors?

No. Internal UF startup funds do not need to be disclosed as other support or current and pending support. However, startup funds or other funds received from entities outside of UF must be disclosed as an Outside Activity to UF and as other/current & pending support to your sponsors.

Need Help?

For assistance with reporting international relationships to sponsors during the proposal stage, including the Just-in-Time, in the biosketch, or within the other support document, contact the Division of Sponsored Programs (DSP) Unit team at ufproposals@ufl.edu.

For assistance with reporting international relationships or activities after a project is funded, including within the RPPR, or progress report, or by way of a prior approval request, contact the DSP Award team at ufawards@ufl.edu.

For assistance with the issue of undue foreign influence in general or to discuss any specific foreign affiliations or activities, contact Cassandra Farley, Associate Director of Research Integrity at 352-392-9174 or cfarley@ufl.edu.

For assistance with UF’s outside activities disclosure requirements, contact Gary Wimsett, Jr., Assistant Vice President for Conflicts of Interest, at 352-273-9272 or gwimsett@ufl.edu.