Updated guidance from the vice chancellor for research on foreign influence concerns can be found here.
In May, notice was sent from the Office of the Vice Chancellor to the research community regarding the resources available at our University in response to concerns about foreign threats to the integrity of research. One of the major concerns identified in that memo was the failure of researchers to disclose research resources and support provided by other organizations, including foreign entities.
There have been recent changes to the NIH FAQs related to the agency’s Guide Notice on reporting of foreign activities, as they pertain directly to that topic.
It is important to note that the NIH has not substantially changed its expectations of what should be reported, but is working to clarify its guidance to respond to recent cases of undue foreign influence in which activities or resources that should have been reported to NIH and other institutions had not been disclosed.
NIH-funded researchers are encouraged to review the updated FAQs thoroughly.
Examples from the updated NIH FAQ’s on Other Support and Foreign Components with further clarification provided by the Office of Sponsored Research (OSR):
I am key personnel on an NIH grant in the United States. I am collaborating with another scientist, whose research has directly benefited my research. Their research was conducted with funds awarded to their institution. Should this be reported as Other Support?
Yes. Other Support includes research collaborations that directly benefit the researcher’s research endeavors. For example, if materials, results from experiments, or data from another researcher’s project directly benefits your research, then it must be included in Other Support. If a dollar value for that benefit is not known, it should be reported as “in-kind” support.
What are some examples of a “significant element of a project” when making determinations regarding a foreign component?
The recipient institution should evaluate the element of the project that is being conducted outside of the United States within the context of the project, as a whole, when making determinations about significance. If a determination is being made at the proposal stage, OSR and/or Sponsored Programs Office (SPO) should be consulted prior to proposal submission.
If a determination to add a foreign component after an award has been issued is being made, OSR should be consulted before adding the foreign component to the project.
Examples of activities that may be considered a significant element of the project include, but are not limited to:
- collaborations with investigators at foreign institutions anticipated to result in co-authorship on publications
- use of facilities or instrumentation at a foreign site
- receipt of financial support on resources from a foreign entity
I am a PI on an NIH award to a domestic university. I will have a visiting fellow joining my lab whose salary will be supported by a foreign university. Do I need NIH prior approval before the fellow can work on my NIH funded research?
Since specific circumstances may vary, it would be best to alert OSR before bringing on any visiting staff from foreign institutions of any sort. They will then speak with the NIH Grants Management Specialist assigned to your project.
Additional Information on Financial Conflicts of Interests (FCOI):
The PHS/NIH FCOI regulations have not changed. Some quick reminders about COI:
- Any related income (including but not limited to honorarium, reimbursed or supported travel) from any government, university or research center outside of the United States must be reported on your project specific COI disclosure form.
- Any related external role (compensated or uncompensated) with any entity must be reported on your project specific COI disclosure form.
- If not related to a specific project and you are a PHS/NIH funded researcher, travel may otherwise be reported through the general COI Travel Disclosure on the air.unc.edu website. For assistance in deciding whether the travel has to be reported, please use the COI Travel Decision Tree.
The University of North Carolina at Chapel Hill strongly supports and encourages international collaboration and values our partnerships with universities and other organizations worldwide. To support continued collaboration, it is important that all faculty and staff members understand the concerns being raised and how we can partner together to address them.
The UNC National Security Working Group has recently been assembled and will continue to meet regularly to review guidance, polices, and any new regulations that become available. Further communication and guidance will be distributed as the group deems necessary. Although these new clarifications pertain to NIH funding, we do anticipate similar announcements from other federal agencies. We will continue to update you as information becomes available.
If you have questions or concerns, please direct them to The Office of Sponsored Research at ResAdminOSR@unc.edu or The Conflict of Interest Program at firstname.lastname@example.org.