a. Examples
The examples below illustrate activities one would disclose to Boise State University. Note that the below list is not exhaustive, but represents the types of engagements that must be disclosed.
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- 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, visiting, or voluntary.
- Any agreement with a foreign university for which the Boise State University researcher directs non-University students, postdocs, or other personnel affiliated with that university.
- Any foreign affiliation that is included in any publication by the faculty member.
- Any contractual agreement with a foreign institution, company, or government agency.
- Any non-Boise State University agreement in which foreign funds or other resources are provided to the faculty for activities either at Boise State University 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 Boise State University researcher or family member receives payments for salary, stipends, or living expenses.
- Receiving travel, living or lodging funds or reimbursements from a foreign entity.
- Receiving an honorarium from a foreign entity.
- 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.
- Having significant ownership interest in a foreign company related to your Boise State University role/responsibility.
If you are participating in any of these activities, it is important that you fully and accurately disclose them to federal Sponsors and the University.
b. Federal Disclosures Requirements in Sponsored Project Applications
Many sponsors request that applicants provide summaries of their current and anticipated grant and contract funding, as well as other resources that may be available for the individual’s research. Terminology varies by sponsor but usually is referred to as “Other Support” or “Current and Pending Support.” Additional disclosures are required in biosketches and other support. Currently there are not consistent requirements across federal agencies. The following disclosure matrix has been prepared to guide researchers on how and where to disclose support received in sponsored projects applications.
| Types of Support | Proposal Location: Other Support/Current and Pending | Proposal Location: Biosketch | Proposal Location: Facilities & Other Support | Proposal Location: Disclosure Not Required |
| Grants, Cooperative Agreements, and Contracts awarded to Boise State University | NIH, NSF, DOD, DOE | | | |
| Grants, Cooperative Agreements, and Contracts awarded to the Investigator Directly | NIH, NSF, DOD, DOE | | | |
| Consulting agreements relating to the Investigator's research endeavors | NIH, NSF, DOD | | | |
| All academic and professional appointments and affiliations whether domestic or foreign and whether paid or unpaid | | NIH, NSF, DOD | | |
| Foreign Government Talent Recruitment Programs must be specifically identified | NIH, NSF, DOD, DOE | | | |
| In-Kind Support or Other Resources1 Intended for use on the proposed project | | | NIH, NSF, DOD | |
| In-Kind Support or Other Support* NOT intended for use of the proposed project | NSF | | NIH, DOD | |
| Prizes | | | | NIH, NSF, DOD |
Gifts
| | | | NIH, NSF, DOD |
| Start-up Funds provided by Boise State University | | | | NIH, NSF, DOD, DOE |
| Start-up Funds provided by another Entity | NIH, NSF, DOD, DOE | | | |
| Boise State Internal Awards | NIH, NSF, DOD, DOE | | | |
*In-Kind Support or Other Resources may include: Office/Laboratory space; Equipment; Supplies; Employees, paid or unpaid; Visiting researchers paid by outside sources, including visiting students and fellows; In-Kind Support with direct time commitments should go in NSF Current & Pending document (if there is no time commitment, it should be listed in the Facilities and Other support).
(1) National Institutes of Health (NIH)
Disclosing Foreign Components
Foreign components should be disclosed on proposals, progress reports, and final technical reports. Under NIH’s Grants Policy Statement, a foreign component is defined as “any significant scientific element or segment of a project outside of the United States” whether or not NIH grant funds are expended, either by “a researcher or recipient in a foreign location or by a researcher in a foreign location employed or paid by a foreign organization.” Refer to NIH issued guidance: NOT-OD-19-114 for additional details. Other sponsors may have similar requirements to disclose foreign components. Under NIH’s Grants Policy Statement, a foreign component is defined as “any significant scientific element or segment of a project outside of the United States” whether or not NIH grant funds are expended, either by “a researcher or recipient in a foreign location or by a researcher in a foreign location employed or paid by a foreign organization.” Refer to NIH issued guidance: NOT-OD-19-114 for additional details. Other sponsors may have similar requirements to disclose foreign components.
For NIH funded research, when a segment of the research is performed outside of the U.S., the following activities would constitute a foreign collaboration that must be disclosed as a foreign component:
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- Research involving human subjects or animals;
- Extensive travel for the purpose of data collection, surveying, sampling, and similar activities (excluding foreign travel for consulting);
- Collaborations with investigators anticipated to result in co-authorship;
Use of facilities or instrumentation;
- Receipt of financial support or resources from a foreign entity.
Examples of ways to disclose a foreign component in a funding application:
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- Identifying a foreign component in an NIH grant application on the R&R Other Project Information Form (G.220):
- Check “Yes” to Question 6, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
- Upload a “foreign justification” document in Field 12, Other Attachments. This attachment should describe the resources or characteristics of the foreign research component (e.g., human subjects, equipment, research techniques, etc.) including reasons why the use of foreign facilities or other aspects of the project are appropriate for an international setting.
- Listing a “non-U.S. performance site”
- Reporting an Annual Research Performance Progress Report (RPPR)
- Special Reporting Requirements – Section G
- G.9 Foreign component. Provide the name, country, and description of each foreign component.
Other Support
Other Support reporting should include all your ongoing or proposed research activities. This includes any foreign sources of funding/in kind support, including equipment, supplies, lab resources and visitors to your lab supported by a foreign entity. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Most federal sponsors have guidance, for example:
NIH issued guidance: NOT-OD-19-114 clarifying “Just-In-Time” reporting for Other Support requires information about an investigator’s overall funding/resources prior to issuing an award. Reporting for senior/key personnel must include “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. 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.).” Examples include:
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- Federal contracts, non-federal research grants, cooperative agreements, institutional awards, talent program payments, in-kind support, etc.
- Non-U.S. resource that supports the research of an investigator and/or researcher, but does not meet the definition of a foreign component because the work is being performed in the U.S.
NIH has also issued guidance that addresses different examples and the reporting requirements.
(2) National Science Foundation (NSF)
The National Science Foundation (NSF) has created a table for Pre-award and Post-award Disclosure requirements. This table identifies what pre- and post-award activities, such as academic training, appointments, current and pending support, in-kind contributions, consulting, travel, and honoraria, must be disclosed to NSF and details where to disclose if disclosure is required.
c. Conflict of Interest and Conflict of Commitment Disclosures
Coming soon…