MU supports and encourages most international collaborations but also recognizes that Federal sponsors have legitimate concerns about protecting U.S. government (taxpayer funded) research and development activities such as those performed at MU.
The items below contain guidance regarding the types of relationships and activities that researchers are expected to disclose to their sponsors and/or to the University. Additional information about relevant University of Missouri policies and NIH and NSF requirements is provided in the Resources section. Other federal agencies may have other, specific reporting requirements.
Disclosures to Federal Sponsors
In addition, NSF requires the disclosure of Collaborators and Other Affiliations (COA) in order to collect information about certain types of relationships and collaborations for each individual in a proposal identified by name as “senior project personnel.” The information required in the COA tables includes organizational affiliations for the previous 12 months and all co-authors and research collaborators for the previous 48 months.
- Faculty submitting proposals for or performing federally funded research that involves a “foreign component” (NIH), an “international activity” (NSF), or any other similar work must state that in proposals, progress reports, and final technical reports.
The NIH defines a “foreign component” as “any significant scientific element or segment of a project outside of the United States…whether or not grant funds are expended”. The NIH also provides examples of collaborative activities that it considers to be a foreign component, including “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.”
Similar to the NIH, proposals to NSF require disclosure of any “international activity,” which NSF defines as “research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies.” This could include international travel to attend conferences, or funding a foreign entity through a subaward or consulting agreement.
Other sponsors may have similar requirements to disclose foreign components.
There are multiple ways in which foreign components can be disclosed, e.g.,
- Identifying a “foreign component” in an NIH grant application
- Listing a “non-U.S. performance site”
- Identifying foreign relationships and activities in a biosketch
- Checking “yes” to the question on the Research & Related Other Project Information Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
- Indicating that a proposal involves “international activities” on the Cover Sheet for Proposal to the National Science Foundation
- Providing letters of commitment or letters of support from foreign collaborators
- MU researchers should ensure they disclose all applicable “Other Support” (NIH), “Current and Pending Support” (NSF, DoD), or as otherwise required by federal sponsors.
- “Other Support” ” includes all resources available in support of--or related to--a researcher’s research endeavors. The resources to be disclosed as “Other Support” might not always have a monetary value and may include resources that support a researcher’s activities at an institution other than the University of Missouri. Such support should be disclosed on an “Other Support” form in response to a Just-in-Time (JIT) request or as a part of an annual or final Research Performance Progress Report (RPPR). If “Other Support” includes foreign sources of support, copies of the governing contracts or awards—or translated copies, if not in English—must be submitted to the NIH. Effective May 2021, all project personnel must electronically sign their “Other Support” form to certify the accuracy of the information they are submitting.
- “Current and Pending Support” includes all resources, regardless of monetary value, that support or relate to any senior personnel’s research efforts. NSF requires information on “current and pending support” for all research projects, regardless of the funding source and regardless of whether the support is received via the University of Missouri, another institution, or is made directly to the researcher.
- Consulting or other professional service activities are typically not required to be reported as a source of support to federal sponsors. However, if that consultation includes the conduct of research, then the consulting activity should be disclosed as a source of support.
- Financial resources originating from a foreign entity, government, or institution should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a nine-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed. In addition, start-up packages or funds from institutions other than the University of Missouri must be reported.
- Research awards made with internal/university funds for which the researcher must maintain separate budget and accounting constitute support that should be disclosed to sponsors.
- Researchers must also disclose “in-kind” and other non-financial resources such as office/laboratory space, equipment, supplies, and/or personnel.
- In kind contributions intended for use in or to support the research being proposed can be included as a part of the ‘Facilities, Equipment and Other Resources’ statement (NSF) and need not also be entered as “current and pending support.”
- If the in-kind contribution is not intended for use in the proposed project, but does have an associated time commitment or level of effort, the contribution should be disclosed as “other” or “current and pending” support.
- Visiting scholars, postdocs, or students compensated through other sources (i.e., personal funds, their home university/institution, or their home government) who work directly on project should be included in the ‘Facilities’ document if not already included as ‘Other’ or ‘Current & Pending’ Support.
- NSF requires additional documentation of the contributions made by persons not in the budget in the form of a “Letter of Collaboration.”
- NIH rules state that researchers disclose when anyone, including visitors, who dedicates at least one month of effort to a project —paid or unpaid—in the annual report (RPPR).
- Biosketches and the NSF “Collaborators and Other Affiliations” (COA) documents should be current and thorough. This would include disclosure of joint appointments or employment at other institutions, foreign or domestic. The NIH and NSF require that all “academic, professional, or institutional appointments” be included in the Biosketch, regardless of the time commitment, compensation received, or if the appointment is voluntary or honorary.
Most federal sponsors will have their own guidance on how to complete their forms. It is ultimately the responsibility of the individual researcher to ensure that all proposal forms, progress reports, and other documents submitted to a sponsor are complete and accurate to the best of his or her knowledge.
Those researchers who submit grant proposals to--or receive research or other sponsored funding from—federal agencies such as the NIH and NSF should review and update their relevant documents and disclosures as needed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Sponsored Programs Administration (firstname.lastname@example.org) to have the error corrected. The addition of a foreign component to an existing grant award should be reported to the Office of Sponsored Programs Administration to obtain the federal agency prior approval. The PI should submit their request for prior approval to the Office of Sponsored Programs Administration (email@example.com) to obtain agency approval prior to the engagement of the new entity.
Disclosures to the University
If you are unsure whether an external activity constitutes an outside interest that meets the threshold for required disclosure, please contact the Conflict of Interest Office at firstname.lastname@example.org. Disclosures of outside interests can be made by logging into the eCompliance system.
- External activities related to work within the scope of a researcher’s University responsibilities (“outside interests”) must be disclosed through the MU Conflict of Interest (COI)/Conflict of Commitment (COC) process and through any NIH or NSF required reporting mechanism. Conflicts of commitment occur when a researcher is dedicating time or effort to outside interests that detract from his or her primary responsibilities as a University employee. The definition of “outside interest” is included in UM CRR 330.015, which requires disclosure of all activities, regardless of whether those activities occur within the state of Missouri, inside the U.S., or internationally, when those activities include:
- Grants and contracts involving an employee financial interest
- Overlapping business activities
- Full-time employment — faculty and exempt personnel
- Faculty-authored textbooks and other educational materials
- Contact the Information Security & Access Management (ISAM) team regarding any compromised accounts or other IT threats at email@example.com or by calling the appropriate help desk below:
- MU/UM employees should call Tech Support at 573-882-5000
- UMHC employees should call the ITS help desk at 573-884-4357
- Inventions must be disclosed to the Technology Advancement office. The University of Missouri requires (CRR 100.20) that the rights to any Invention made by an employee in the “general scope of his/her duties as an employee of the University” must be assigned to the Curators of the University of Missouri. This disclosure obligation can extend to an invention that was developed outside of the University if it was “in a substantial degree made or developed through the use of University facilities or financing, or on University time, or through the aid of University information not available to the public.” Questions about invention disclosures and other intellectual property concerns can be directed to firstname.lastname@example.org.
Foreign Talent Programs
An area of increased concern is participation in foreign talent programs1. Talent programs can expose our faculty, their work and the University to significant risk, including in the areas of export controls, grant compliance and intellectual property ownership. We recommend that our faculty and staff exercise caution in deciding whether to participate in a talent program. For those who are participating in or considering a talent program, please engage promptly with the Office of Research so we can assess and advise on any risks. Participation in a talent program is a type of outside interest that should be disclosed to a research sponsor and through MU’s COI/COC process as described above.
1 In general, a talent program is “any foreign state sponsored attempt to acquire U.S.-funded scientific research through recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.” Many countries use talent programs as a mechanism to attract U.S. researchers, but the use of talent programs is generally associated with China.