Published June 13, 2019
With the June and July NIH proposal submission deadlines near, the Office on Sponsored Research Services (OSRS) would like to remind principal investigators and research administrators about the responsibilities for disclosing certain foreign collaborations at the time of application submission. While NIH is still revising its written guidelines, the following include its current requirements and best practices. Foreign collaboration disclosure includes the proactive identification of:
- Any foreign components participating in the research,
- Investigator affiliations with foreign institutions and organizations, and
- Other support received from foreign sources.
The information provided below is similar to the notice issued by Dr. Lodge – Vice Chancellor for Research in January 2019.
1. Disclosing Foreign Collaborations in Proposals
Criteria for Disclosure
The NIH requires investigators to disclose whenever a significant part of their proposed research will be performed outside of the U.S. – regardless of who will be performing the research or funding the research.
When performed outside of the U.S., the following activities would constitute a foreign collaboration that must be disclosed as a foreign component:
- 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;
- Any activity that may impact U.S. foreign policy through involvement in the affairs or environment of a foreign country.
How to Disclose
To disclose a foreign collaboration in a proposal, on the R&R Other Project Information form (G.220) in the NIH application package:
- 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.
2. Disclosing Foreign Affiliations in Proposals
In their Biosketch, investigators should list the foreign affiliations (e.g., positions, honors) they hold. NIH currently is recommending that any foreign affiliation be disclosed as “relevant” to the proposal.
3. Disclosing Foreign Sources of Other Support
If the NIH requests additional “Just-In-Time” information about an investigator’s overall funding/resources prior to issuing an award, list any support received from foreign entities (e.g., federal contracts, non-federal research grants, cooperative agreements, institutional awards, talent program payments, etc.) in Other Support documentation.
Contact Teri Medley (314-747-4444 / firstname.lastname@example.org) or Joe Gindhart (314-747-5385 / email@example.com) in OSRS if you have any questions about this issue.