Disclosing Support to Federal Agencies for International Partners
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Description
Information to Disclose
Generally, the following information should be disclosed to federal research Sponsors:
At the time of proposal/Just in Time
- All Outside Appointments, including paid and unpaid, as well as honorary
- External sources of support
- Externally provided in kind resources
At the time of progress reporting:
- New outside appointments
- New sources of support
- New externally provided in kind resources
- New collaborators who are significant contributors
- Effort expended by visiting researchers and student volunteers if 1 calendar month or more of effort is expended
If there are any questions as to if a new outside appointment or external source of support is permissible under the terms of the award, it is appropriate to discuss the proposed activity with the Sponsor’s Program Office.
It is currently not necessary to report:
- Support not related to research activities.
Foreign Components
Foreign components need prior approval on NIH grants. They should be called out in proposals if known, and should be reported prior to engaging in the research activity if added after the start of the award. Foreign Components include:
- Performance of work related to the grant at a foreign location
- Collaboration related to the funded research with a foreign researcher who will perform work at his/her home institution.
Note: the foreign component needs to be reported and approved by NIH even if NIH funds are not being used to support the activity even if the foreign activity is due to the PI or other key personnel working on the project from outside the U.S. for a sabbatical.
Agency Guidance
Current agency guidance for other support follows.
National Institutes of Health (NIH)
| What to Disclose | Where to Disclose | When to Disclose |
|---|---|---|
| Outside Appointments, both paid and unpaid | Biosketch | Proposal, RPPR |
| International Collaborations with activities outside of the U.S. related to the project | Foreign Component | Proposal or requires Prior approval |
| Related sources of support including post-docs and visiting scholars funded by foreign sources, in kind resources provided by other institutions, and foreign grants the investigators | Other Support | Proposal, RPPR |
| International Collaborators in your lab (not key personnel) | Personnel report in RPPR | RPPR only if effort exceeds month |
For more detailed guidance on how to report specific types of activities, reference the following chart:
The NIH announcement on foreign interference has additional information.
National Science Foundation (NSF)
| What to Disclose | Where to Disclose | When to Disclose |
|---|---|---|
| Outside Appointments, both paid and unpaid | Biosketch | Proposal, RPPR |
| Research, training and or education carried out with international counterparts either overseas or using virtual technologies | Cover sheet (list countries), Project narrative | Proposal |
| Funding of a foreign organization including subaward or consultant arrangements as part of award | Cover Sheet | Proposal or Requires Prior approval |
| Unfunded substantial international collaborations | Facilities, Equipment and Other Resources and letter of collaboration Organizations that have been involved as partners and full details of organizations involved as partners | Proposal, RPPR |
| Other sources of support for research including support to Penn and support directly to the individual (office/laboratory space, equipment, supplies, employees, students) | Current and Pending Support | Proposal, RPPR |
| International Collaborators in your lab (not key personnel) | Personnel report in RPPR | RPPR only if effort exceeds month |
Department of Defense (DoD)
| What to Disclose | Where to Disclose | When to Disclose |
|---|---|---|
| Outside Appointments, both paid and unpaid | Biosketch | Proposal |
| Related sources of support | Other Support | Proposal |