12/2022: Learn more about the Biden Administration’s Research and Development National Security Policy (NSPM-33) in our new guidance for researchers.
Open science and international collaboration are essential to research, scholarship, and discovery. As of 2016, nearly twenty percent of academic papers were authored by teams representing multiple countries. At Boston University, we are actively working to safeguard these partnerships by maintaining the highest standards of transparency and doing everything we can to support and educate our faculty.
In the past year, federal funding agencies have asked researchers to become more vigilant in the disclosure of international research collaborations, affiliations, and activities to protect the integrity of U.S. research and intellectual property. We are closely monitoring guidance coming out from the National Institutes of Health (NIH), the National Science Foundation (NSF), and other agencies. We encourage faculty to stay abreast of current agency regulations and best practices, some of which are outlined below.
- Complete all aspects of federal grants thoroughly, especially items related to foreign components
- Update funding agencies on new foreign engagements
- Complete a Conflict of Interest disclosure whenever required
- Report all intellectual property to the University to ensure it’s protected
- Familiarize yourself with BU policies related to research agreements and export control
All portions of federal grants must be completed thoroughly and with great attention to detail. Even innocuous inconsistencies and errors have the potential to raise flags with federal funding agencies.
As a reminder, all proposals for external research support must be submitted through Sponsored Programs and awards must be made to the “Trustees of Boston University.” Full guidance on submitting proposals can be found here. In September 2019, we updated both the proposal summary form (PSF) and the NIH RPPR summary form (RSF) to include a checklist of considerations as faculty submit federal proposals.
Guidelines from specific agencies related to “foreign influence” are outlined below.
When to disclose
What to disclose
NIH defines “foreign component” as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.
Activities that would meet this definition include, but are not limited to:
- the involvement of human subjects or animals;
- extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities; or
- any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.
Examples of other grant-related activities that may be significant are:
- 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.
Foreign travel for consultation is not considered a foreign component.
Here are examples of what to disclose to NIH about Senior/Key Personnel on applications and awards.
How to disclose
- NIH Application Other Project Information page (Question 6) requires you to indicate if this project involves activities outside of the US or partnerships with foreign collaborators. If you check “Yes” to Question 6, you must upload a “foreign justification” document in Field 12, Other Attachments. On this form, you must describe the special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting.
- NIH RPPR Participants (Section D1) requires you to list who has worked on the project at least one-person month per year and identify if the individuals’ primary affiliation is with a foreign organization.
- NIH RPPR Personnel updates (Section D2) requires you to report if there are will be new/senior key personnel or if there has been a change in other support of senior/key personnel since the last reporting period.
- NIH RPPR Impact (Section E4) requires you to report the dollar amount from the budget that is being spent in foreign countries.
- NIH RPPR Project Performance Site(s) (Section G8) requires you to report changes to the project/performance site(s) including any new sites where either human subjects or vertebrate animals will be involved.
- NIH RPPR Foreign Component (Section G9) requires you to report on Foreign Components (note — Foreign Components require prior approval).
- Biosketch: Investigators should list the foreign affiliations (e.g., positions, honors) they hold in their Biosketches. NIH currently is recommending that any foreign affiliation be disclosed as “relevant” to the proposal.
- Other Support: Other support includes all financial resources, whether Federal, non-Federal, commercial, or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts are not included.
All financial resources, including support from foreign entities and talent programs, must be included in the Current and Pending Support/Other Support section of research proposals. This includes any direct research support provided to you, even if it is not administered by BU.
NSFNational Science Foundation has similar requirements to those of the NIH for reporting “Current and Pending Support.” “Current and Pending Support” is defined by the NSF as the support requested or available from all sources of project funding.
All current and pending support from whatever source (e.g., federal, state, local or foreign government agencies, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects) must be listed. The proposed project and all other projects or activities requiring a portion of time of the PIPrincipal Investigator View Boston University's policy on... and other senior personnel must be included, even if they receive no salary support from the project(s).
Faculty and researchers must adhere to all BU finance-related policies. The more the University understands your international collaborations and relationships, the better we can support your research efforts in the current environment.
Disclosure of Financial Interests
Faculty and researchers must disclose any income or travel reimbursements received from a foreign entity, including governments and academic institutions. Financial disclosures are governed by BU’s Investigator Financial Conflicts of Interest Policy, which states that principal investigators and others who share responsibility for the design, conduct, and reporting of research must disclose all personal financial interests related to the breadth of their institutional responsibilities. Learn more or complete a disclosure
Gifts and Donations
As a reminder, only designated University personnel are authorized to accept gifts from any source. This includes gifts from foreign entities.
- Activity reports: Familiarize yourself with BU’s policy on external activity and complete your annual external activity report thoroughly, including the new sections on international employment, international support, and international patents.
- Research agreements: You may not enter into informal or unofficial agreements to restrict publication or sharing of research results. Publication restrictions in research can only be negotiated by University officials who have delegated authority to accept contracts and grants. Learn more
- Export control: You must comply with U.S. export control regulations when doing any of the following: traveling internationally and attending conferences, participating in international collaborations, using proprietary information, working with international staff and students, hosting international visitors, shipping materials internationally, or engaging in any international transactions. Learn more
- Intellectual property: To ensure that all intellectual property is protected and, when required, appropriately reported to sponsors, all BU employees are expected to promptly disclose intellectual property and any improvements to existing intellectual property to BU Technology Development.
Frequently Asked Questions
We are beginning a compilation of FAQs based on information received to date. Most of the responses below are from NIH senior officials and the Grants Policy office. Responses across NIH divisions may differ. We will continue to add to this list as we receive new details from federal funding agencies.
Which foreign affiliations and support need to be reported to the NIH?
Any foreign affiliation of the PI(s) and key personnel must be reported. Foreign affiliations include paid, unpaid, honorary, and volunteer positions at a foreign institution (e.g., visiting or adjunct professor, board member, consultant) – largely anything that would result in a PI and key personnel on an NIH grant being included on a foreign institution’s official list of faculty, advisors, consultants, etc.
All other support of the PI and key personnel must be reported as well, even if the support is for research unrelated to the NIH grant. This includes foreign funding, research resources, and in-kind support.
Which international collaborations need to be reported to the NIH?
All foreign components of an NIH grant must be reported. If a grantee determines that (1) a portion of the project will be conducted outside of the U.S., regardless of whether NIH funds are expended, the grantee then will need to (2) determine if the activities are considered significant. If both criteria are met, then there is a foreign component.
Please note that foreign components to an active NIH grant require prior approval and the FOA (funding opportunity announcement) to which the grant is linked must allow foreign components.
Collaborations with foreign researchers that do not meet the definition of a foreign component do not have to be reported or receive approval. There is still a bit of policy uncertainty regarding what activities are considered significant or not. PIs should consult with their Program Officer and Grants Management Specialist when establishing a new collaboration with a foreign investigator to get a formal decision from NIH as to whether the activity is considered significant. If NIH staff determine the activity is significant, then prior approval will be required. If you anticipate co-authorship resulting from collaboration with an investigator at a foreign site, that would be considered significant, and may constitute a foreign component.
How do I report on a collaborator's funding?
Agencies recognize the difficulties of reporting funding associated with an international institution or grant, and ask you to comply to the best of your ability. Some basic information to include would be grant/contract project number, the name of the contact PI, source of support, title of project/subproject, dates of approved/proposed project, and person months committed to the project.
NIH is currently updating the instructions for the Other Support Format Page, and these updates will include additional instructions on reporting collaborations and other in-kind sources of support.
Does this affect my Financial Conflict of Interest (fCOI) disclosure?
All investigators that report through the fCOI disclosure process are required to include any external financial interests, as well as those received from foreign entities (including foreign institutes of higher education or the government of another country).
- October 11: Webinar on Managing Compliance Challenges Involving Global Collaborators
- October 10: FBI Academia Summit Summary of Topics & Key Takeaways
- September 27: NIH Reveals its Formula for Tracking Foreign Influences
- September 17: Trump’s Top Scientist Outlines Plan to Reduce Foreign Influence on US Research
- September 16: White House Letter to US Research Community
- July 10: Reminders of NIH Policies
- June 19: NIH Working Group on Foreign Influences on Research Integrity Update
- May 31: Memo to BU Faculty on Foreign Influence in Academic Research
- April 22: Actions Taken by Universities to Address Growing Concerns
Resources from Other Universities
If you have questions, please contact Diane Baldwin, Associate Vice President, Sponsored Programs at firstname.lastname@example.org.