The Sponsored Projects Office has compiled the following information to assist campus researchers and department contracts and grants liaisons with understanding the foreign disclosure requirements that federal agencies have enacted at the various stages of the proposal and award process.

For information on the background of these foreign disclosure requirements, please review the discussion found on the Office of Research's Research Integrity International Engagement webpage. https://www.research.ucsb.edu/research-integrity/international-engagement

Please note that these requirements are constantly evolving and that this website will likely be updated regularly.  Sponsored Projects recommends referring to these resources often.

For federal agencies not listed below, please refer to the specific instructions found in the solicitation, along with any other applicable proposal preparation guidance that the agency has issued. 

National Science Foundation (NSF)

This guidance is current as of 1/30/2023.

NEW (as of 1/30/23): Please refer to this table for helpful NSF reference information regarding pre-award and post-award disclosure information in the biographical sketch and current and pending support proposal sections. The table identifies where these disclosures must be provided in proposals as well as in project reports.

Download NSF Disclosure of Foreign Involvement Certification

 

 

WHERE TO REPORT:

WHAT TO REPORT:

Biosketch

All academic, professional, or institutional affiliations, positions and appointments, regardless of whether they are:

  • domestic or foreign 
  • paid or unpaid 
  • full-time, part-time, or voluntary (including adjunct, visiting, or honorary)
  • provided through the proposing organization or provided directly to the individual 

 

New required NSF-Approved formats for biographical sketch (per PAPPG, effective October 5, 2020):

"The requirement to use an NSF-approved format for preparation of the biographical sketch will go into effect for new proposals submitted or due on or after October 5, 2020. In the interim, proposers must continue to prepare this document in accordance with the guidance specified in the PAPPG (NSF 20-1). NSF, however, encourages the community to use the NSF-approved formats and provide valuable feedback as we enhance them for the October implementation."

 

Sources:

PAPPG II.C.2.f - Biographical Sketch(es)

Approved Formats for the Biographical Sketch 

 

Current & Pending

All planned, pending and current project support and in-kind support that is either provided directly to the individual, or to the individual through their organization in support of that individual’s research endeavors, from whatever source, including, but not limited to:

  • federal, state, local, or foreign agencies or entities
  • public or private foundations; non-profit organizations
  • industrial or other commercial organizations
  • internal funds allocated toward specific projects
  • consulting agreements
 

This includes, but not limited to:

  • In-kind resources from other institutions or external sources, e.g., office or lab space, equipment, supplies, employees, and students. 
    • Employees include postdocs and visiting scholars receiving support from external sources of funding. If the funding is provided directly to the postdoc or visiting scholar personally, it is not considered an in-kind resource but may be reportable in the Facilities, Equipment and Other Resources section of the proposal. For more information about the Facilities, Equipment and Other Resources document see below under “Other.”
  • Mentoring activities that support undergraduate or graduate students, where the PI/senior personnel receive in-kind support from an external source, either directly or through their organization
  • Grants to the investigators from foreign sources
  • Start-up packages from sources other than the proposing organization
  • Other external sources of support, regardless of whether they are provided to UCSB 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 or otherwise does not have monetary value. (See directly above, regarding in-kind resources.)

 

Regarding “Gifts” -

  • An item or service does not need to be reported on Current & Pending if it is determined to be a "gift", which, by definition, is given without expectation of anything in return.  NSF's definition of "gift" includes "any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, license, special access, equipment time, samples, research data, or other item having monetary value." The definition of "gift" also includes "services as well as gifts of training, transportation, local travel, lodging, meals, research hours, whether provided in-kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has occurred".
    • However, if the item or service is given with the expectation of an associated time commitment, it does not meet NSF’s definition of a “gift” and should be reported as an in-kind contribution.  
  • In-kind contributions that are not intended to be used on the project/proposal being proposed to NSF must be reported in the Current & Pending section. In-kind contributions that are intended to be used on the project/proposal being proposed to NSF must be included as part of the Facilities, Equipment and Other Resources section.

 

 New required NSF-Approved formats for Current & Pending Support (per PAPPG, effective October 5, 2020):

"The requirement to use an NSF-approved format for preparation of current and pending support will go into effect for new proposals submitted or due on or after October 5, 2020. In the interim, proposers must continue to prepare this document in accordance with the guidance specified in the PAPPG (NSF 20-1). NSF, however, encourages the community to use the NSF-approved formats and provide valuable feedback as we enhance them for the October implementation."

 

New clarification regarding on reporting “person months committed to the project” (updated 2/24/2021)

NSF recently updated their Frequently Asked Questions on Current and Pending Support, to provide clarified information on reporting “person months committed to the project” when the individual does not have effort in a given year.  (See updated Questions 3 and 4.)

According to NSF: "It is important to note that NSF is not asking for how much time is budgeted for a particular individual(s), but rather how much time the individual(s) is/are planning to spend to complete the scope of work on the proposed project and/or award. If the individual(s) will be spending time on the proposed project or award, then that time must be reported."

 

Sources:

PAPPG II.C.2.h - Current & Pending Support 

PAPPG II.C.2.i - Facilities, Equipment and Other Resources 

Significant Changes and Clarifications to the PAPPG    

Frequently Asked Questions on Current and Pending Support (Updated April 20th 2022)  


 

Other

Facilities, Equipment and Other Resources  -

  • In-kind contributions intended for use on the project/proposal being proposed to NSF (these do not need to be replicated in the Current & Pending section).
    • As noted above in the NSF Current & Pending section, in-kind support includes office or lab space, equipment, supplies, employees, and students.   Employees include postdocs and visiting scholars receiving support from external sources of funding.
    • If the funding is provided directly to the postdoc or visiting scholar personally, but will benefit the project, it is reportable in the Facilities, Equipment and Other Resources section of the proposal.
  • All substantial unfunded foreign collaborations (also include letter of collaboration).
  • PI/senior personnel effort when no salary is being requested

Sources:

PAPPG II.C.2.h - Current & Pending Support  

PAPPG II.C.2.i - Facilities, Equipment and Other Resources   

Frequently Asked Questions on Current and Pending Support (Updated April 20th 2022) 

 

Cover Sheet and Project Description - 

  • All research, training, and/or education which involves international counterparts, whether in-person or virtually 
  • All subawards, consulting agreements or other forms of funding to foreign entities or individuals

Sources:

PAPPG II.C.2.a(i) - Cover Sheet - Other Information   

PAPPG II.C.2.d - Project Description   

 

Collaborators and Other Affiliations -

  • All affiliations, both foreign and domestic, that are listed for PIs and senior project personnel  must be complete and accurate.

Sources:

PAPPG II.C.1.e - Collaborators and Other Affiliations    

 

WHERE TO REPORT:

WHAT TO REPORT:

Proposal Update

If the Proposal Update seeks information regarding the Biosketch, Current & Pending, or other items listed above, ensure that all new or previously unreported information addressed in the categories listed in the Proposal Submission Stage section is included.

 

For details on what specific information is required to be reported in Current & Pending, please see the Current & Pending section above under "Proposal Submission Stage". 

 

WHERE TO REPORT:

WHAT TO REPORT:

(If Applicable)

Other Request - Research.gov 

NSF’s award terms and conditions require UCSB to identify undisclosed current support or in-kind contributions that were active as of the date the proposal was submitted to NSF. If undisclosed information is discovered, UCSB has 30 calendar days to submit a Post-Award Disclosure of Project Support Information and/or Post-award Disclosure of In-Kind Contribution Information report in NSF’s Research.gov system. 

 

If undisclosed information that was active as of the date the proposal was submitted to NSF is identified, please contact the Sponsored Projects team immediately for further guidance. UCSB is required to report undisclosed information within 30 calendar days of discovery. (This 30-day reporting requirement remains in effect during the entire life of the award.)

 

For details on what specific information is required to be reported in Current & Pending, please see the Current & Pending section above under "Proposal Submission Stage". 

 
 

WHERE TO REPORT:

WHAT TO REPORT:

Post-Award Reports (RPPR)

Generally speaking, all new or previously unreported information in the categories listed in the Proposal Submission Stage section, above. The RPPR calls for detailed information with respect to PIs, co-PIs, senior personnel, and others working on the project, including information regarding both domestic and foreign sources of funding that supported their participation on the project.  The RPPR also requires disclosure of domestic and foreign collaborations and partnering organizations that have been involved with the project.  See additional, newly added requirements, below.

 

*New Question for Project Reports with Active Other Support Changes, effective October 5, 2020*
Effective October 5, 2020, PIs and co-PIs must include an NSF-approved format for Current and Pending Support when notifying NSF that active other support has changed since the award was made, or since the most recent annual report. 

  • On October 5, 2020, NSF added the following new question to the Edit Participants screen: Has there been a change in the active other support of the PI/PD(s) since the last reporting period? 
  • If Principal Investigators (PIs)/Project Directors (PDs) and co-PIs/co-PDs select “Yes,” they will be required to upload their most up-to-date Current and Pending Support document in an NSF-approved format to notify NSF that active other support has changed since the award was made or since the most recent annual report.
  • Current and Pending Support documents not in an NSF-approved format will trigger a compliance error preventing document upload and submission of the annual or final project report.
  • The NSF-approved formats for Current and Pending Support are SciENcv: Science Experts Network Curriculum Vitae <https://www.ncbi.nlm.nih.gov/sciencv/> and an NSF fillable PDF <https://www.nsf.gov/bfa/dias/policy/nsfapprovedformats/cps.pdf>.
  • The NSF Current and Pending Support <https://www.nsf.gov/bfa/dias/policy/cps.jsp> website includes additional information as well as links to system-related Frequently Asked Questions (FAQs) for both NSF-approved formats. A set of policy-related FAQs related to current and pending support <https://www.nsf.gov/bfa/dias/policy/papp/pappg20_1/faqs_cps20_1.pdf> is also available.
  • The complete lists of FastLane and Research.gov automated proposal compliance checks effective October 5, 2020, are available on the Automated Compliance Checking of NSF Proposals website <https://www.nsf.gov/bfa/dias/policy/autocompliance.jsp>.

 

This new requirement serves as NSF’s implementation of the revised RPPR, a uniform format for reporting performance progress on Federally-funded research projects and research-related activities.  All of the terms and conditions have been updated to include a new article which establishes a post-award disclosure requirement for undisclosed current support and in-kind contribution information.  Each set of terms and conditions is accompanied by a summary of changes made to that document.  The revised terms and conditions will apply to all new NSF awards and funding amendments to existing NSF awards made on or after October 5, 2020, except for the SBIR/STTR-I and SBIR/STTR-II CA-FATC which became effective July 6, 2020.

 

*Additional New Questions from the Revised RPPR, effective October 5th, 2020*
Beginning October 5, 2020, NSF will also add the following three questions to the "Impact" and "Changes/Problems" tabs:

  • What was the impact on teaching and educational experiences? (Impact tab);
  • What percentage of the award’s budget was spent in a foreign country? (Impact tab); and
  • Has there been a change in primary performance site location from that originally proposed? (Changes/Problems tab)

 

For details on what specific information is required to be reported in Current & Pending, please see the Current & Pending section above under "Proposal Submission Stage". 

 

New clarification regarding on reporting “person months committed to the project” (updated 2/24/2021)

According to NSF: "It is important to note that NSF is not asking for how much time is budgeted for a particular individual(s), but rather how much time the individual(s) is/are planning to spend to complete the scope of work on the proposed project and/or award. If the individual(s) will be spending time on the proposed project or award, then that time must be reported."

 

Sources:

NSF Research Performance Progress Report (RPPR) Screenshots and Instructions (note: This page may take a minute or two to load)

Research.gov - About Project Reports

Frequently Asked Questions on Current and Pending Support (Updated April 20, 2022)  

 
 

(If Applicable)

Other Request - Research.gov 

NSF’s award terms and conditions require UCSB to identify undisclosed current support or in-kind contributions that were active as of the date the proposal was submitted to NSF. If undisclosed information is discovered, UCSB has 30 calendar days to submit a Post-Award Disclosure of Project Support Information and/or Post-award Disclosure of In-Kind Contribution Information report in NSF’s Research.gov system. 

 

If undisclosed information that was active as of the date the proposal was submitted to NSF is identified, please contact the Sponsored Projects team immediately for further guidance. UCSB is required to report undisclosed information within 30 calendar days of discovery. (This 30-day reporting requirement remains in effect during the entire life of the award.)

 

For details on what specific information is required to be reported in Current & Pending, please see the Current & Pending section above under "Proposal Submission Stage". 

 

WHERE TO REPORT:

WHAT TO REPORT:

As applicable:

NSF annual disclosure in the Office of Research Conflict of Interest (ORCOI) system

The NSF requires that outside activities/interests that would reasonably appear to affect your funded or proposed research and educational activities be disclosed at the time of proposal and within 30 days of acquiring any new disclosable activity/interest. Examples of disclosable outside activities/interests include but are not limited to the following:

  • Compensation related to an academic or research appointment at a foreign institution of higher education (e.g. visiting professor, guest lecturer, or participation in a talent program) exceeding $10,000.
  • Intellectual property assigned to, or licensed to, a party other than the UC Regents.
  • Publicly or non-publicly traded investments the value of which exceeds $10,000 or represents more than 5% ownership,
  • Any personal gifts or loans from organizations or entities.

 

Additional details related to conflict of interest disclosures may be found on this website at the "COI For Researchers" page, or by contacting the COI administrator at coi@research.ucsb.edu.

 

National Institutes of Health (NIH)

This guidance is current as of 6/8/2022.

Download NIH Disclosure of Foreign Involvement Certification 

IMPORTANT: New Updates to NIH Disclosure Table (updated June 8, 2022). Please review the table and contact your SPO Team with any questions.

 

WHERE TO REPORT:

WHAT TO REPORT:

Biosketch

All domestic and foreign positions, appointments and affiliations (regardless of whether they are paid, unpaid, volunteer, guest, adjunct, honorary) that are relevant to the application.

ATTENTION: NEW CHANGES TO BIOSKETCH, EFFECTIVE MAY 25, 2021 AND ENFORCED JANUARY 25, 2022 (see NIH Notice No. NOT-OD-21-073, issued March 12, 2021 and NIH Notice No. NOT-OD-21-110, issued April 28, 2021)

Section A

  • Section A ("Personal Statement") adds language specifying that this section should be used for "including details on ongoing and completed research projects from the past three years that the researcher want to draw attention to (previously known as research support)".

Section B

  • Section B, "Positions and Honors" has been renamed "Positions, Scientific Appointments, and Honors".
  • Changes order of listing from "chronological order" to "reverse chronological order"
  • Revised to include the following specific language: "List in reverse chronological order all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes 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)."

Section D

  • Non-Fellowship Biosketches - Section D ("Scholastic Performance") has been removed.
  • Fellowship Biosketches - Section D ("Scholastic Performance") has been updated to remove "Research Support".

Updated SciENcv Template

  • NIH anticipates that the updated SciENcv Biosketch template will be available March 2021. Those with existing biosketches in SciENcv should be able to transfer their current biosketch information to the new format.

 

Sources:

Biosketch Format Pages, Instructions and Samples (updated March 2021)

Frequently Asked Questions (FAQs) - Biosketches (updated August 2021)

NIH Disclosure Table (updated June 2022)

Instructions for a Biographical Sketch

Protecting U.S. Biomedical Intellectual Innovation

 

Foreign Component


Must be reported, even if activities are not supported by NIH funds.

Performance of any significant part of an NIH project outside of the U.S., including, but not limited to:

  • international collaborations involving activities outside of the U.S.
  • other research activities related to the grant, performed at a foreign location

 

Sources:

Protecting U.S. Biomedical Intellectual Innovation

Frequently Asked Questions (FAQs) - Other Support and Foreign Components

 

WHERE TO REPORT:

WHAT TO REPORT:
 

Other Support

ATTENTION: NEW CHANGES TO OTHER SUPPORT, EFFECTIVE MAY 25, 2021 AND ENFORCED JANUARY 25, 2022 (see NIH Notice No. NOT-OD-21-073, issued March 12, 2021 and NIH Notice No. NOT-OD-21-110, issued April 28, 2021)

Re-Organization of Form

  • The format page has been restructured, separating funded projects from in-kind contributions.

Signature Block Added

  • All PD/PIs and other senior/key personnel must electronically sign the Other Support form, prior to submission to NIH, certifying that the information is accurate and complete. Other Support forms must be submitted as a flattened PDF, after all signatures are obtained. Original electronic signatures must be maintained and make it available upon request

Supporting Documentation Relating to Foreign Activities or Resources

  • If the Other Support submission includes foreign activities or resources, copies of contracts, grants or any other agreements specific to the PD/PI or other senior/key-personnel's foreign appointments, affiliations, and/or employment with a foreign institution must be included with the Other Support submission. These documents must be translated into English if they are in a foreign language. Please contact your SPO team immediately if NIH has requested supporting documentation (contracts, agreements, etc.) relating to foreign activities and resources that are reported in Other Support, or if a PI is planning to provide such documents to NIH.

Immediate Notification of Undisclosed Other Support

  • If an organization discovers that a PD/PI or other senior/key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or RPPR submissions, the institution must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

Formatting & Future Transition to SciENcv

  • NIH anticipates that the SciENcv template for Other Support will be available beginning in FY 2022. Until then, the MS Word version of the Other Support form should be used. (It must be converted to PDF and electronically signed prior to submission.)

 

In addition to the above new requirements (which go into effect May 25, 2021), Other Support submissions must report the following, based on current, established NIH requirements:

All resources that have been made available in support of the research endeavors of all principal investigators and persons designated as senior/key personnel1,  regardless of whether such resources:

  • are Federal or non-Federal
  • are commercial or institutional
  • are domestic or foreign
  • have monetary value or are in-kind
  • involve work is performed inside or outside of a researcher's appointment period
  • are awarded through UCSB, through another institution, or provided directly to the researcher

 

This includes research grants, cooperative agreements, contracts, and/or institutional awards3, along with in-kind resources, such as:

  • financial support for laboratory personnel
  • lab or office space
  • equipment
  • research materials
  • staff (including post-docs and visiting scholars, including those supported by a foreign institution)
  • high-value materials that are not freely available (such as  biologics, chemical, model systems, technology, etc.).
  • income, salary, consulting fees, and honoraria in support of an individual's research endeavors

 

All positions and scientific appointments that are relevant to an application, including:

  • academic, professional, and institutional appointments, regardless of whether they are:
    • domestic or foreign
    • paid or unpaid
    • full-time or part-time
    • voluntary, adjunct, visiting, or honorary
  • affiliations with foreign entities or governments
  • foreign ‘talents’ or similar-type programs 

 

All domestic and foreign research collaborations that directly benefit the researcher’s research endeavors.  

1Senior/key personnel is defined as “other contributors to the project’s scientific development or execution when their involvement is substantive and measurable, whether or not salaries or compensation is requested.”

2Training awards, prizes, or gifts do not need to be included. Currently, it is not required to report support for attendance or hosting conferences, or travel expenses to give a talk, if they are unrelated to research activities.   

 

Please note that, according to NIH, applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award. 

 

Sources:

Other Support Instructions (updated March 2021)

Frequently Asked Questions (FAQs) - Other Support and Foreign Components  (updated August 2021)

Protecting U.S. Biomedical Intellectual Innovation

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components

COGR - Commentary on Disclosing Other Support and Other Resources in Research Funded by the National Institute of Health

NIH Disclosure Table (updated June 2022)

 

WHERE TO REPORT:

WHAT TO REPORT:


Post-Award Reports (RPPR)

NIH has added the following question to the RPPR:  "D.2.c Changes in Other Support - Has there been a change in the active other support of senior/key personnel since the last reporting period?"

If the answer is "yes" to this question, an Other Support form must be submitted with the RPPR.  See guidelines below, which address what must be reported.

Further, if Other Support is obtained after the initial NIH award period, from any source either through the institution or directly to senior/key personnel, the details must be disclosed in the annual research performance progress report (RPPR). See below for details. Note, however, that a new requirement for immediate reporting (before the RPPR period) will take effect May 25th, 2021.

 

ATTENTION: NEW CHANGES TO OTHER SUPPORT, EFFECTIVE MAY 25, 2021 AND ENFORCED JANUARY 25, 2022 (see NIH Notice No. NOT-OD-21-073, issued March 12, 2021 and NIH Notice No. NOT-OD-21-110, issued April 28, 2021)

Re-Organization of Form

  • The format page has been restructured, separating funded projects from in-kind contributions.

Signature Block Added

  • All PD/PIs and other senior/key personnel must electronically sign the Other Support form, prior to submission to NIH, certifying that the information is accurate and complete. Other Support forms must be submitted as a flattened PDF, after all signatures are obtained. Original electronic signatures must be maintained and make it available upon request

Supporting Documentation Relating to Foreign Activities or Resources

  • If the Other Support submission includes foreign activities or resources, copies of contracts, grants or any other agreements specific to the PD/PI or other senior/key-personnel's foreign appointments, affiliations, and/or employment with a foreign institution must be included with the Other Support submission. These documents must be translated into English if they are in a foreign language. Please contact your SPO team immediately if NIH has requested supporting documentation (contracts, agreements, etc.) relating to foreign activities and resources that are reported in Other Support, or if a PI is planning to provide such documents to NIH.

Immediate Notification of Undisclosed Other Support

  • If an organization discovers that a PD/PI or other senior/key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or RPPR submissions, the institution must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

Formatting & Future Transition to SciENcv

  • NIH anticipates that the SciENcv template for Other Support will be available beginning in FY 2022. Until then, the MS Word version of the Other Support form should be used. (It must be converted to PDF and electronically signed prior to submission.)

 

In addition to the above new requirements (which go into effect May 25, 2021 and enforced January 25, 2022), current, established NIH policies require that the following items must be reported as Other Support on the RPPR:

 

New or previously unreported resources that have been made available in support of the research endeavors of all principal investigators and persons designated as senior/key personnel1,  regardless of whether such resources:

  • are Federal or non-Federal
  • are commercial or institutional
  • are domestic or foreign
  • have monetary value or are in-kind
  • involve work is performed inside or outside of a researcher's appointment period
  • are awarded through UCSB, through another institution, or provided directly to the researcher

 

This includes research grants, cooperative agreements, contracts, and/or institutional awards2, along with in-kind resources, such as:

  • financial support for laboratory personnel
  • lab or office space
  • equipment
  • research materials
  • staff (including post-docs and visiting scholars, including those supported by a foreign institution)
  • high-value materials that are not freely available (such as  biologics, chemical, model systems, technology, etc.).
  • income, salary, consulting fees, and honoraria in support of an individual's research endeavors

 

New or previously unreported positions and scientific appointments that are relevant to an application, including:

  • academic, professional, and institutional appointments, regardless of whether they are:
    • domestic or foreign
    • paid or unpaid
    • full-time or part-time
    • voluntary, adjunct, visiting, or honorary
  • affiliations with foreign entities or governments
  • foreign ‘talents’ or similar-type programs 

 

New or previously unreported domestic and foreign research collaborations that directly benefit the researcher’s research endeavors.  

1Senior/key personnel is defined as “other contributors to the project’s scientific development or execution when their involvement is substantive and measurable, whether or not salaries or compensation is requested.”

2 Training awards, prizes, or gifts do not need to be included. Currently, it is not required to report support for attendance or hosting conferences, or travel expenses to give a talk, if they are unrelated to research activities.   

 

Sources:

Other Support Instructions (updated March 2021)

Frequently Asked Questions (FAQs) - Other Support and Foreign Components (updated August 2021)

NIH Disclosure Table (updated June 2022)

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components

COGR - Commentary on Disclosing Other Support and Other Resources in Research Funded by the National Institute of Health

 

Prior Approval Request for Foreign Component6

6 Must be reported and approved, even if activities are not supported by NIH funds. Please contact NIH with questions as to the permissibility of new outside appointments or sources of support.

 

Performance of new or previously unreported activities involving any significant part of an NIH project outside of the U.S., including, but not limited to:

  • international collaborations involving activities outside of the U.S.
  • other research activities related to the grant, performed at a foreign location

 

 

WHERE TO REPORT:

WHAT TO REPORT:

As applicable:

PHS annual disclosure in the Office of Research Conflict of Interest (ORCOI) system

 

The NIH requires that outside activities/interests related to your Institutional Responsibilities be disclosed at the time of proposal and within 30 days of acquiring any new disclosable activity/interest. Examples of disclosable activities/interests include but are not limited to the following:

  • Compensation related to an academic or research appointment at a foreign institution of higher education (e.g. visiting professor, guest lecturer, or participation in a talent program) exceeding $5,000.
  • Intellectual property assigned to, or licensed to, a party other than the UC Regents.
  • Publicly or non-publicly traded investments the value of which exceeds $5,000 or or any investments in non-publicly traded companies.
  • Any personal gifts or loans from organizations or entities.
  • Any reimbursed travel from organizations or entities exceeding $5,000.

 

Additional details related to conflict of interest disclosures may be found on this website at the "COI For Researchers" page, or by contacting the COI administrator at coi@research.ucsb.edu.

 

National Aeronautics and Space Administration (NASA)

This guidance is current as of 08/26/2020.

 

WHERE TO REPORT:

WHAT TO REPORT:

Biosketch

The biographical sketch must include professional experiences and positions, along with a bibliography of publications, especially those relevant to the proposed investigation.  A description of scientific, technical and management performance on relevant prior research efforts must also be included.

 

Please refer to the  NASA Guidebook for Proposers Responding to a NASA Funding Announcement for further details regarding biosketch requirements.

 

Also be sure to check solicitation for any program-specific requirements.

 

Current & Pending

PIs and Co-PIs must provide full disclosure of  all ongoing and pending projects and proposals, both domestic and foreign, regardless of whether salary support is received, and in which they are performing or will perform any part of the work.  Co-Is proposing to spend 10% or more of their time to the proposed effort must disclose ongoing and pending projects and proposals that require greater than 10% of their time.

 

Current and pending support is not required for Co-Is at non-U.S. institutions, and is usually not required for students (although it may be requested).

 

Please refer to the  NASA Guidebook for Proposers Responding to a NASA Funding Announcement for further details regarding current and pending support.

 

Also be sure to check solicitation for any program-specific requirements.

 

Other - NASA China Certifications and Questionnaire

According to the Grant Information Circular 12-01 Class Deviation Implementing NASA Restrictions On Funding Activities With The People's Republic Of China (Prc) Effective April 25, 2011

 

“NASA is restricted by specific applications of Section 1340(a) of The Department of Defense and Full-Year Appropriations Act, Public Law 112-10 (NASA's 2011 continuing resolution), and Section 539 of the Consolidated and Further Continuing Appropriation Act of 2012, Public Law 112-55 (NASA's FY 2012 appropriation) from using funding appropriated in the Acts to enter into or fund any grant or cooperative agreement of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.”

 

In order to ensure compliance with the above, the Sponsored Projects Office requires Principal Investigators to submit certain  signed documents at proposal stage:

 

A.  NASA GRANTS AND COOPERATIVE AGREEMENTS

 

(1) NASA Certification for Grants and Cooperative Agreements - 

 

(The Certification Form can be found here.)

 

For grants and cooperative agreements, NASA is forbidden by law from having the following take place as part of the NASA scope of work for grants, cooperative agreements, and contracts awarded to UCSB, regardless of whether such arrangements are funded by the NASA award:

  • Bilateral participation, collaboration, or coordination with The People's Republic of China (PRC),
  • Bilateral participation, collaboration, or coordination with any company owned by the People's Republic of China
  • Bilateral participation, collaboration, or coordination with any company (including a Chinese university) incorporated under the laws of the People's Republic of China (including Hong Kong and Macau, but not Taiwan). 

 

Principal Investigators must certify that they will not enter or cause The Regents of the University of California to enter into a bilateral subaward, memorandum of understanding, collaboration agreement, or any other type of written bilateral agreement with the PRC as defined above.  (Vendor agreements for acquisition of commercial and non-developmental items are excluded from this certification.)

 

When submitting proposals and accepting NASA grants or cooperative agreements, the Principal Investigator is required to sign the certification and submit it to the Sponsored Projects Office as a condition of proposal submission.

 

(2) NASA China Questionnaire for Grants and Cooperative Agreements - 

 

(The Questionnaire can be found here.)

 

For all grant and cooperative agreement proposals, the lead Principal Investigator must complete and return the following questionnaire to the Sponsored Projects Office, on their own behalf and on behalf of all persons performing any part of the Scope of Work on a NASA grant or cooperative agreement (“Participants”), whether this performance is funded or unfunded, on-campus or remote.  Should PI not know the answers for any Participant, the PI must obtain the necessary information from these Participants. 

 

This questionnaire must be completed, signed and submitted to Sponsored Projects as a condition of proposal submission. The PI is required to update this questionnaire as needed during the life of the project.

The questionnaire asks the following:

  • Is any Participant employed by the Chinese government or a Chinese owned company or university?
  • Does any non-student Participant receive salary support from the Chinese government or a Chinese owned company or university?
  • Does any non-student Participant receive any incidental financial compensation, such as housing or transportation, from the Chinese government or a Chinese owned company or university?
  • Does any Participant have a written agreement to become (or to return as) an employee of the Chinese government or a Chinese owned company or university?
  • Is any Participant enrolled at a Chinese university or does any Participant have a written agreement to become (or to return as) as a student of a Chinese university?
  • If a Participant is a student, does such Participant receive any type of financial support (other than a scholarship) from the Chinese government or a Chinese owned company or university?
  • Does any Participant receive research materials or any other type of goods from China or a Chinese owned company or university? (Do not include the purchase of commercial supplies needed to perform the NASA award scope of work.)
  • Is any Participant co-authoring a paper with a person from China or a Chinese owned company or university that is the result of activity funded by NASA after April 2011?

 

B.  NASA CONTRACTS - 

 

NASA Certification for Contracts - 

 

(The Certification can be found here.)

 

For contracts, NASA is forbidden by law from from contracting to participate, collaborate, coordinate bilaterally in any way with China or a Chinese-owned company* using funds appropriated on or after April 25, 2011. These restrictions apply regardless of whether they occur at the prime recipient level or at any subrecipient level, and whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement

 

(Contracts for commercial and non developmental items are exempted from the prohibition because they constitute purchase of goods or services that would not involve participation, collaboration, or coordination between the parties.)

 

UCSB must not contract with China or Chinese-owned companies for any effort related to the contract, except for acquisition of commercial and non-developmental items. If an award to China or Chinese-owned companies is anticipated, UCSB must contact the contracting officer to determine if funding on the contract can be used for that purpose.

 

These restrictions must be flowed down to any subcontracts involved in the project.

 

Principal Investigators must certify that they will not enter or cause The Regents of the University of California to enter into a bilateral contract or subcontract with The People's Republic of China (PRC), any company owned by the People's Republic of China or any company (including a Chinese university) incorporated under the laws of the People's Republic of China (including Hong Kong and Macau, but not Taiwan) to perform the scope of work of the NASA prime contract, whether or not such contracts or subcontracts are funded by the NASA prime contract.  (Vendor agreements for acquisition of commercial and non-developmental items are excluded from this certification.)

 

* “China” or “Chinese-owned company” is defined as the People’s Republic of China, any company owned by the People’s Republic of China or any company incorporated under the laws of the People’s Republic of China.

 

References:

Grant Information Circular 12-01 Class Deviation Implementing NASA Restrictions On Funding Activities With The People's Republic Of China (Prc) Effective April 25, 2011

 

RPAC Memorandum on NASA Restriction on Funding Activity with the People’s Republic of China (PRC)

 

WHERE TO REPORT:

WHAT TO REPORT:

Proposal Update

If the Proposal Update seeks information regarding the biosketch or current and pending support, ensure that any new or previously unreported required information is included.

 

Also, principal investigators must contact the Sponsored Projects Office if any of the responses on the China Questionnaire have changed.

 

WHERE TO REPORT:

WHAT TO REPORT:

Post-Award Reports (RPPR)

All new or previously unreported information in required categories listed in biosketch or current and pending support sections, above.

 

Principal Investigators must also contact the Sponsored Projects Office if any of the responses on the China Questionnaire have changed.

 

 

Department of Defense (DOD)

This guidance is current as of 08/26/2020.

 

WHERE TO REPORT:

WHAT TO REPORT:

Biosketch

Full disclosure of academic/professional affiliations, positions and appointments, including both domestic and foreign positions is required.

 

Refer to program solicitation instructions for further detail and/or additional requirements.

 

Also be sure to check solicitation for any program-specific requirements.

 

Current & Pending

On March 20, 2019, the Department of Defense issued a memorandum that established new current and pending support requirements for Notices of Funding Opportunities for research and research-related educational activities. These requirements were implemented for the following purposes:

  1. To support protection of intellectual property, controlled information, key personnel, and information about critical technologies relevant to national security; and
  2. To limit undue influence, including through foreign talent programs, by countries to exploit United States technology within the Department of Defense research, science and technology, and innovation enterprise.

 

As of April 20, 2019, all key personnel must submit current and pending support documentation that includes the following:

  • A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
  • Title and objectives of the other research projects.
  • The percentage per year to be devoted to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

 

This information is required for all key personnel, regardless of whether their their efforts under the project are to be funded by the DOD.

 

Failure to submit this information may cause a proposal to be returned without further review.  Additionally, the DOD has stated that it reserves the right to request further details from a proposer before making a final determination on funding the effort.

 

Note that a particular program solicitation may include additional or differing requirements for current support documentation, and should be reviewed closely.

 

Sources:

DOD March 20, 2019 Memo

 

WHERE TO REPORT:

WHAT TO REPORT:

Proposal Update

If the Proposal Update seeks information regarding the biosketch or current and pending support, ensure that any new or previously unreported required information is included.

 

WHERE TO REPORT:

WHAT TO REPORT:

Post-Award Reports (Technical Report)

Information regarding all participants on the project (including those who were not paid) must be reported, and countries of foreign participants must be identified.

 

Refer to Technical Report instructions for further details. 

 

Department of Energy (DOE)

This guidance is current as of 12/16/2022.

 

WHERE TO REPORT:

WHAT TO REPORT:

Biosketch

Full disclosure of academic/professional affiliations, positions and appointments, including both domestic and foreign positions is required.

 

Also be sure to check solicitation for any program-specific requirements.

 

Current & Pending

Full disclosure of current and pending support is required, including both domestic and foreign sources is required.

 

Also be sure to check solicitation for any program-specific requirements.

 

Other

On June 7, 2019, DOE issued Order No. 486.1, which requires that, in many cases, contractors who perform work within the scope of a DOE contract or subcontract must fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs. Talent recruitment programs are defined to include “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”.

 

In conjunction with this foreign talent program prohibition for DOE contractors, new quarterly reporting relating to senior or key personnel have been imposed. (See post-award reporting, below.)

 

Although this directive currently applies to DOE contracts, it is expected that the ban on participating in foreign talent recruitment programs may be extended to cooperative agreements and grants at some point in the future.

 

Sources:

DOE Order No. 486.1 re: Foreign Government Talent Recruitment Programs, dated June 7m 2019 -

 

DOE bars its researchers from participating in rival nations’ talent programs. Physics Today, June 20, 2019 -

 

WHERE TO REPORT:

WHAT TO REPORT:

Proposal Update

If the Proposal Update seeks information regarding the biosketch or  current & pending, ensure that all new or previously unreported information is included.

 

WHERE TO REPORT:

WHAT TO REPORT:

Post-Award Reports (RPPR)

In connection with its ban on contractors participating in foreign talent recruitment programs (see above), DOE has implemented quarterly reporting requirements that seek certain information for senior or key personnel:

 

“With respect to the work being performed under this contract, the contractor must utilize due diligence to ensure that neither it nor any of its employees, applicable subcontractor employees or joint appointees, working at any level, participate in a foreign government talent recruitment program of a foreign country of risk while performing work within the scope of the DOE contract. The contractor must file reports with DOE on a quarterly basis stating whether it or any such employees or joint appointees are participants in a foreign government talent recruitment program of a foreign country of risk, or whether the contractor has a reasonable basis to report such employees or joint appointees as a participant in a foreign government talent recruitment program of a foreign country of risk”

 

Additionally, if it becomes known that someone working on the DOE contract has been involved in a foreign government talent recruitment program, the contractor have five days to notify the DOE.

 

“The contractor must notify the Office of Intelligence and Counterintelligence within 5 business days upon, at any time during the term of the contract, including options and extensions, learning that it or any of its employees, applicable subcontractor employees, or joint appointees are or are believed to be participants in a foreign government talent recruitment program of a foreign country of risk.”

 

Sources:

DOE Order DOE O 486.1 -  Department of Energy Foreign Government Talent Recruitment Programs 

 
WHERE TO REPORT: WHAT TO REPORT:

As applicable:

DOE annual disclosure in the Office of Research Conflict of Interest (ORCOI) system

The DOE requires that outside activities/interests related to your Institutional Responsibilities be disclosed at the time of proposal and within 30 days of acquiring any new disclosable activity/interest. Examples of disclosable activities/interests include but are not limited to the following:

  • Compensation related to an academic or research appointment at a foreign institution of higher education (e.g., visiting professor, guest lecturer, or participation in a talent program) exceeding $5,000.
  • Intellectual property assigned to, or licensed to, a party other than the UC Regents.
  • Publicly or non-publicly traded investments the value of which exceeds $5,000 or or any investments in non-publicly traded companies.
  • Any personal gifts or loans from organizations or entities.
  • Any reimbursed travel from organizations or entities of any value.

 

Additional details related to conflict of interest disclosures may be found on this website at the "COI For Researchers" page, or by contacting the COI administrator at coi@research.ucsb.edu.