Frequently Asked Questions (FAQs) on International Research and Engagement
Last Updated: September 12, 2024 1:29:18 PM PDT
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Expand section ANIMAL RESEARCH
What is required if I want to use funding administered by UC San Diego to perform research involving live vertebrate animals at a foreign institution?
The Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals (Policy) requires that institutions have an OLAW-approved Animal Welfare Assurance before carrying out any activities involving live vertebrate animals. Institutions outside the United States (U.S.) that receive PHS funds directly through a grant or contract award are to use the Animal Welfare Assurance for Foreign Institutions (Foreign Assurance). The Foreign Assurance also applies to institutions outside the U.S. that receive PHS funds indirectly (as a performance site through a primary institution). The UCSD Institutional Animal Care and Use Committee (IACUC) also requires that the Principal Investigator provide the IACUC Office with a copy of the foreign IACUC (or IACUC-equivalent) approval letter in original language and English translation. Finally, the foreign institution must be AAALAC-accredited. If not AAALAC-accredited, the physical ownership of animals must be ceded to the foreign institution.
If you need assistance or additional information, please contact the UC San Diego IACUC at iacuc@ucsd.edu or (858) 534-6069.
Expand section CONFLICT OF INTEREST
Do I need to disclose the following as a potential conflict of interest or outside interest?
- UC San Diego will receive a subaward from a foreign university or company. Work performed as part of your job at UC San Diego does not constitute a conflict of interest.
- A foreign university will reimburse my travel costs or pay an honorarium to participate in a conference or deliver a lecture. If you are conducting or proposing PHS-funded research (i.e., NIH and those agencies that have adopted the PHS FCOI regulations) and the payments are from a foreign university, foreign organization or foreign government (counting travel reimbursement, honoraria and any other payment combined) total $5,000 or more in any 12 month period, you must disclose this on your annual PHS financial disclosure in Kuali COI (PHS does not require disclosure of these types of payments from domestic universities or domestic government entities). You may need to disclose for Non-PHS federal sponsors (i.e., NSF, CIRM and UC programs) if the activity is related and the interest(s) is greater than $10,000 (or greater than 5% equity) to your research project(s) at UC San Diego.
- An unpaid research collaboration with a foreign university. When you are not compensated and do not receive anything of monetary value (besides your UC San Diego salary) no conflict of interest disclosure is required.
- A university will pay me directly to participate on a research project, as a consultant, peer review journal, hiring committee, or advisory board. If you are conducting or proposing PHS-funded research (i.e., NIH and those that have adopted the PHS FCOI regulations) and the payments are from a foreign university, foreign organization or foreign government total $5,000 or more in any 12 month period, you must disclose this on your annual PHS financial disclosure in Kuali COI. You must disclose a financial interest that appears to be in the same field as your expertise and meets the monetary thresholds. The COI office is responsible per the regulation to determine relatedness.
Please note there may be other types of disclosures and approvals that may be required, depending on the situation. Please contact the Research Compliance and Integrity Office at rci@ucsd.edu for assistance.
How do I disclose my outside financial interests and activities?
For sponsored research and other related activities, conflict of interest (COI) disclosures are required. Whether foreign or domestic, non-profit, or commercial, outside financial interests are disclosed in Kuali COI. This is the only acceptable method for UC San Diego faculty, staff, or students to fulfill disclosure requirements on outside financial interests. More information the various COI disclosure requirements can be found at: https://blink.ucsd.edu/sponsor/coi/disclosing/index.html.
UC San Diego Faculty must also disclose their outside activities whether compensated or uncompensated under the applicable conflict of commitment (COC) policies in UC OATS.
For general campus and SIO faculty, APM 025 Policy is available at: https://www.ucop.edu/academic-personnel-programs/_files/apm/apm-025.pdf. For Health Sciences faculty, APM 671 Policy is available at: http://ucop.edu/academic-personnel-programs/_files/apm/apm-671.pdf.
The Kuali COI system is used to submit your interests with outside entities based on disclosure requirements of your extramurally funded research or other activity (i.e., gifts or service agreements, etc.) project. The UC OATS system is used to advise academic personnel about your time commitment (and income for Health Sciences faculty) related to outside professional activities.
I am a consultant to a foreign company or other entity. Do I disclose this relationship differently from domestic companies?
No. The financial relationship must be disclosed in Kuali COI. PHS-funded investigators must include the relationship in their annual disclosure if it relates in any way to their professional responsibilities at UC San Diego (i.e., income or equity from a publicly held entity is $5,000 or more in any 12-month period OR any equity from a privately held company). PHS funded researchers must disclose the relationship if it presents a potential conflict of interest in research (such as a management role or equity interest in a research-related startup or consulting to a company that will benefit from your research, paid in excess of $5,000 per year); or a medical doctor consulting for a pharmaceutical company (even without a research relationship). You may need to disclose for Non-PHS federal sponsors (i.e., NSF, CIRM and UC programs) if the activity is related and the interest(s) is greater than $10,000 (or greater than 5% equity) to your research project(s) at UC San Diego.
I forgot to disclose a conflict of interest. Should I disclose now?
Yes, if the interest remains active in the last 12 months. While failure to disclose and gain approval is a policy violation, the consequences are likely to be greater should a policy violation be discovered via an audit rather than a self-disclosure by you. Please keep in mind that NIH may require a retrospective review of your research if your outside activity was not properly disclosed.
When in doubt, you should always disclose an outside interest.
Expand section EXPORT CONTROL
What is Restricted Party Screening (RPS)?
The UC System uses a service called Visual Compliance to perform Restricted Party Screenings (RPS) to ensure we are not interacting with restricted entities, weapons proliferators, terrorist organizations, export control violators, and drug traffickers in violation of United States Law. Without proper authorization such as an export license, the government prohibits U.S. individuals and organizations from collaborating with or providing materials, services, and financial support to these restricted or denied parties.
UCSD faculty and staff can sign up for a Visual Compliance account to run their own RPS prior to engagements with foreign entities. There is no cost to utilize Visual Compliance if you sign up for an account using your @ucsd.edu email address. If you have further questions regarding RPS, please contact the UCSD Export Control Office at export@ucsd.edu.
Please note that central campus offices run RPS before facilitating transactions such as research agreements, payments, shipments, and appointments for visiting scholars, visiting graduate students, and postdoctoral scholars. If you engage with volunteers, payments, or shipments that do not use UCSD's central offices, you must run RPS before engaging in the activity.
I have been invited to present at an international conference in a country that is on the U.S. sanctions list. Can I do this?
Presenting at an international conference in a country sanctioned by the United States may be viewed as providing a prohibited in violation of U.S. sanctions regulations. Before agreeing to participate, consult with the Export Control Office, export@ucsd.edu, to determine if this is permissible and/or if a license is required.
I am collaborating with a colleague abroad and would like to send some data to my collaborator. What should I do?
Depending on the nature of the data and the related technology, the exchange of data with foreign collaborators may require a license. Consult with the Export Control Office, export@ucsd.edu, to determine whether there are any restrictions or if a license is required. A Data Use Agreement or other type of agreement may also be needed to facilitate the transfer of data to a collaborator. Please see the Office of Contracts and Grants (OCGA) Ancillary Agreements webpage for more information.
Can I collaborate with an individual or entity (e.g., university or company) included on the Specially Designated National (SDN) list?
It depends on the nature of the collaboration and the underlying activities. Specific authorization in the form of a license from the U.S. government may be required. It may be possible to secure a license to allow for such a collaboration in certain limited circumstances (e.g., when the reason for the individual or entity inclusion on the list is unrelated to the proposed collaboration). However, the license must be secured before any such collaboration is initiated and any restrictions outlined in the license must be strictly followed. Contact the Export Control Office, export@ucsd.edu for assistance.
How do I transfer equipment out of the United States?
An export license may be required to ship or hand-carry items or equipment outside the U.S. The need for a license is dependent upon the nature of the equipment, its end-use, the recipient(s), and destination country. Additionally, even temporary exports of equipment to some locations may incur costly import duties. Due to the complex requirements surrounding the export control regulations and international trade requirements, consult the UCSD Export Control Office, export@ucsd.edu, for assistance regarding shipping, traveling with, or transferring equipment or technical information to international locations or persons.
Expand section FOREIGN TALENT RECRUITMENT PROGRAM (FTRP)
What are Foreign Talent Recruitment Programs (FRTP) and where do I obtain prior approval at UC San Diego?
The White House Office of Science and Technology Policy (OSTP) was required, in coordination with an interagency working group, to publish a uniform set of guidelines for Federal research funding agencies regarding Foreign Talent Recruitment Programs. OSTP’s guidelines were issued on February 14, 2024, and include the following definitions:
“A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.”
Additional guidance on How to Identify a Non – U.S. Talent Recruitment Program
When will UC San Diego be required to report Foreign Talent Programs?
Academic Personnel Services will require prior approval to engage in foreign talent programs under the revised Academic Personnel Policies 025 and 671 starting July 1, 2024. As the landscape of international research collaboration evolves, understanding and navigating the complexities of foreign talent recruitment programs and how to identify which programs may be malign are critical to safeguarding intellectual property and ensuring the ethical conduct of research activities. Disclosure is the first step, whether in UC OATS, Kuali COI, BioSketch, Other Support and/or annual reports.
Expand section MALIGN FOREIGN TALENT RECRUITMENT PROGRAM
What are Malign Foreign Talent Recruitment Programs (MFRTP)?
Malign Foreign Talent Recruitment Programs are initiatives, roles, or activities promising various forms of reward—including cash, travel, titles, career opportunities, or other valuable considerations—provided by foreign entities in exchange for the unauthorized transfer of intellectual property or sensitive data, among other compromising activities. These programs may bind participants to conditions that contradict U.S. federal research standards, such as recruitment obligations, establishment of foreign operations, or nondisclosure of involvement, potentially leading to conflicts of interest or commitment. Conducting restricted party screening may help identify known Malign programs; however, Researchers must evaluate the criteria of opportunities which may shift. Some of the malign criteria are unauthorized transfer of intellectual property, required recruitment of trainees, establishing a laboratory at a foreign entity, and required applications for direct research funding from a foreign entity to conduct research that is also federally funded, prohibiting disclosure of the foreign program, etc. All covered individuals (i.e., Senior Key Personnel) listed on a federal research project will have to certify that they are not participating in a Malign Foreign Talent Recruitment Program. The Department of Energy (DOE) and Department of Defense (DOD) have already begun integrating this required certification. The National Science Foundation will begin the certification process in May of 2024. All other federal agencies will follow.
(As defined by Section 10638(4) of the Act)
“A malign foreign talent recruitment program is:
(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—
- engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;
- being required to recruit trainees or researchers to enroll in such program, position, or activity;
- establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
- being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
- through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;
- being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;
- being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;
- being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
- having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and
(B) a program that is sponsored by—
(i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern;
(ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232); or
(iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232).”
What is the UC policy on the prohibition of Malign Foreign Talent Recruitment Programs?
Regarding UC policy for the prohibition on Malign Foreign Talent Recruitment Program (MFTRP), as required by the Chips & Science Act of 2022 ("CHIPS Act") (Section 10631), our UC policy is located in the University of California Contracts & Grant Manual (Section 2-553), which states:
The Chips & Science Act of 2022 ("CHIPS Act") (Section 10631) prohibits participation in a Malign Foreign Talent Recruitment Program (MFTRP) by Covered Individuals involved with research and development awards from federal research agencies. (See definitions below.) In addition to pre-existing required reporting of participation in Foreign Talent Recruiting Programs on biosketches and current and pending/other support forms, federal research agencies are implementing policies prohibiting participation in MFTRPs to comply with the CHIPS Act.
In addition, Section 10632 of the CHIPS Act requires that every federal research agency establish a policy requiring that each institution or organization applying for research and development awards certify that each Covered Individual employed by such institution or organization has been made aware of, and complied with, the requirement to certify that they are not a party to a malign foreign talent recruitment program in proposal submissions and annually thereafter for the duration of the award.
The University of California will comply with all applicable federal agency policies. To date, only the Department of Defense and the National Science Foundation have issued policies. As other agencies issues policies they will be listed here.
Expand section GENERAL QUESTIONS
Are the disclosure requirements related to International Research and Engagement specific to only National Institutes of Health (NIH) grants?
No. The Department of Defense (DOD), the National Science Foundation (NSF), and the Department of Energy (DOE) have also issued statements regarding foreign engagement. Given the current U.S. Government focus on this topic, we anticipate similar guidance, statements, or requirements will be forthcoming from other funding agencies. For additional information, please see the Federal Guidance section of the UCSD International Research and Engagement webpage.
Have all federal agencies defined foreign components?
No, the concept of Foreign Component is specific to National Institutes of Health (NIH). See the NIH section.
As part of a collaboration effort with a colleague at a foreign institution, we are submitting a joint application for funding to a foreign entity. Does this need to be disclosed in my federal grant applications?
You must disclose all such applications in your Current and Pending and/or Other Support page.
May I send tangible research materials or animals to foreign collaborators?
Such material transfers to any recipient (foreign or otherwise) must be accompanied by a material transfer agreement (MTA), or another type of institutional agreement containing provisions similar to those of an MTA, executed by UCSD. Materials requiring an MTA or MTA-like agreement include mice, plasmids, reagents, human materials (blood, tissue, etc.), cell lines and vectors, regardless of fundamental research or intellectual property status.
For further details, please consult the UCSD Material Transfer Agreements (MTA) webpage. Approval of an MTA request for transfer to a foreign recipient involves screening and consultation with the Export Control Office prior to MTA execution and shipping to ensure export regulations and trade compliance requirements are met.
Do I need to make disclosures related to the work of my graduate students if they are foreign nationals? Does this affect postdoctoral scholars?
In most cases, there is no reason to disclose participation of foreign students or postdoctoral scholars on sponsored research, especially if all such work will be performed in the U.S. The University of California's Nondiscrimination and Affirmative Action Policy states that the University does not discriminate on the basis of citizenship UCSD, therefore, generally does not accept public and private sponsors’ restrictions of research based on citizenship.
However, there may be cases where working with a foreign student or postdoctoral scholar might be considered a “foreign component”, e.g., if that foreign student, postdoctoral scholar or collaborator is performing effort in a foreign country. The National Institutes of Health (NIH) defines a foreign component as, “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."
When referencing a paid direct foreign student or postdoctoral scholar, please see the Health Sciences Sponsored Project Pre-Award Office website and see the section on Paid Direct foreign Post Docs & Students language.
Expand section NATIONAL INSTITUTES OF HEALTH (NIH)
What is the National Institutes of Health (NIH) definition of a foreign institution?
National Institutes of Health (NIH) defines a foreign institution as an organization located in a country other than the United States and its territories that is subject to the laws of that country, regardless of the citizenship of the proposed Program Director/Principal Investigator.
What is National Institutes of Health (NIH) definition of a foreign component?
A foreign component is the performance of a significant scientific element of the National Institutes of Health (NIH) supported project outside of the United States. Once a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component.
What are some examples of a “significant element of a project” when making determinations regarding a foreign component?
When making determinations about significance, the element of the project that is being conducted outside of the United States should be evaluated within the context of the project as a whole. Some examples of activities that may be considered a significant element of the project include, but are not limited to:
- Collaborations with investigators at a foreign site anticipated to result in co-authorship
- Use of facilities or instrumentation at a foreign site
- Receipt of financial support or resources from a foreign entity
Can I add foreign component disclosures to current projects or proposals?
Yes, contact the applicable Sponsored Projects Office (SPO) to have your application updated. Find the applicable SPO website below and search for your department to find the specific SPO contact.
Health Sciences Sponsored Project Pre-Award Office (HSSPPO)
Office of Contract and Grant Administration (OCGA)
Office of Contract and Grant Administration (OCGA) Scripps Institution of Oceanography (SIO)
I have a collaborator from another country who will work in my National Institutes of Health (NIH) funded laboratory on my NIH project but receive no salary from my NIH grant. Is this considered a foreign component?
No, a “Foreign Component” exists only if the research activities occur outside of the United States. However, this should be reported as “Other Support.” All in-kind resources, which includes visitors or employees who are paid directly by outside resources, should be disclosed as “Other Support.” For suggested language on what to include regarding paid direct foreign post-doctoral scholars and students please visit the HSSPPO website.
I am the Principal Investigator (PI) on a National Institutes of Health (NIH) grant to a domestic university. I have a visiting post-doctoral fellow in my lab, who works on my NIH grant and does all his/her work in the United States. The fellow’s salary is paid by a foreign government. Is this a foreign component?
In general, no. The first step in determining whether research constitutes a foreign component is to evaluate whether a portion of the research is being conducted outside of the United States. In this case, since all the work is being conducted in the U.S., there would be no foreign component.
However, this should be reported as “Other Support.” All in-kind resources, which includes visitors or employees who are paid directly by outside resources, should be disclosed as “Other Support.” For suggested language on what to include regarding paid direct foreign post-doctoral scholars and students please visit the HSSPPO website.
I am a Principal Investigator on a National Institutes of Health (NIH) grant and have an appointment and a lab at a foreign university. The research being done at the foreign lab is unrelated to my NIH project. What do I need to do?
Since resources are made available to you in support of your research, this must be reported as Other Support, however, this would not qualify as a foreign component of the National Institutes of Health (NIH) research, as the foreign work is not part of the NIH-funded project.
I am a Research Scientist and am not covered by APM 025 or 671, but participate on National Institutes of Health (NIH) grants (one as a Principal Investigator (PI) through a PI exception and the other as senior/key personnel). I work half the time at a foreign research institution. Does this need to be reported on the NIH grant?
Yes, this appointment must be reported as Other Support. The National Institutes of Health (NIH), National Science Foundation (NSF), and Department of Defense (DoD) require applicants to list all positions and scientific appointments, both domestic and foreign, that are held by senior/key personnel. This includes affiliations with foreign entities or governments, such as titled academic, professional, or institutional appointments, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
If you have any questions on what to include on your ‘Other Support’ contact the applicable Sponsored Projects Office (SPO) to have your application updated. Find the applicable SPO website below and search for your department to find the specific SPO contact.
Health Sciences Sponsored Project Pre-Award Office (HSSPPO)
Office of Contract and Grant Administration (OCGA)
Office of Contract and Grant Administration (OCGA) Scripps Institution of Oceanography (SIO)
It is important that you also remember that you may have additional reporting requirements to other institutional offices such as the Conflict of Interest Office, Export Controls and Research Compliance and Integrity (if you are conducting research outside of the University, i.e. on a proposal, grant application and/or award and there is no agreement between the University and the outside entity).
How will National Institutes of Health (NIH) review foreign contracts, grants or any other agreements that are provided?
National Institutes of Health (NIH) requires the submission of foreign contracts, grants or any other agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution, as supporting documentation to the Other Support submission. NIH will review contracts, grants or any other agreements to confirm that all information provided in the Other Support submission is accurate and complete.
Are machine-read translations of foreign contracts, grants or any other agreements acceptable for Other Support submissions?
Yes. National Institutes of Health (NIH) will accept machine-read translations.
Are the costs of translating foreign contracts allowable on National Institutes of Health (NIH) grants as a direct cost?
The costs associated with translations of foreign contracts for inclusion in Other Support submissions are not typically allocable to a specific National Institutes of Health (NIH) grant project and are therefore not allowable as a direct cost. NIH recommends that institutions consider including such costs in their negotiations for indirect cost reimbursement.
Expand section OTHER SUPPORT AND BIOSKETCH
For ongoing National Institutes of Health (NIH) grants, do recipient institutions need to provide copies of translated foreign contracts for any current foreign appointments and/or employment with a foreign institution?
Yes, effective January 25, 2022, the NIH requires institutions to provide foreign contracts, grants or any other agreements relevant to Other Support information. In the Research Performance Progress Report (RPPR) for ongoing grants, recipients must provide copies of foreign contracts, grants or any other agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. The foreign contracts and grants must be translated into English.
What is the effective date of the new Other Support format page?
Use of the new Other Support format page is preferred immediately and required for due dates and submissions on or after January 25, 2022 (NOT-OD-21-110). Failure to follow the appropriate formats on or after January 25, 2022, may cause National Institutes of Health (NIH) to withdraw applications from or delay consideration of funding.
Applicants and recipients remain responsible for disclosing all research endeavors regardless of the version of the forms used, including:
- If asked by NIH staff, supporting documentation, which includes copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts, grants or other agreements are not in English, recipients must provide translated copies.
- Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.
If an institution identifies a resource that was not reported in Just-in-Time or at the time of the Research Performance Progress Report (RPPR), how should the institution notify National Institutes of Health (NIH)?
If an organization discovers that a Principal Investigator (PI) or other Senior/Key personnel on an active National Institutes of Health (NIH) grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the institution must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.
Do outside consulting activities have to be reported in Other Support?
Consulting or professional service arrangements that do not involve research do not need to be reported, as the type of work conducted is not typically considered to be a resource available in support of an individual’s research endeavors. When the researcher will be conducting research as part of the consulting activities, they must report it as Other Support.
If a Program Director (PD)/Principal Investigator (PI) or other senior/key personnel is mentoring post-doc or graduate students who are individually funded through an outside institution) e.g. foundation or home university), does that need to be disclosed as an in-kind resource in Other Support?
If the post-doc or graduate student is performing research activities in support of the Program Director (PD)/Principal Investigator (PI) or other senior/key personnel’s research endeavors, then their support must be reported as an in-kind resource. If the relationship is solely a mentor/mentee arrangement, with no research activities, then it is not a resource, and does not need to be reported.
I am a Principal Investigator (PI) on a federal award to a domestic university and have an unpaid appointment at a foreign university. At the foreign site, I have access to lab space, research materials, and staff. Should I report this as Other Support and/or my Biosketch?
Yes, this appointment must be reported as Other Support as well as be included on your Biosketch. While monetary compensation is not received, the lab space, materials, and staff are resources provided in support of and/or related to the research efforts. Other payments such as travel or living expenses must also be reported.
National Institutes of Health (NIH), National Science Foundation (NSF), and Department of Defense (DoD) require applicants to list all positions and scientific appointments, both domestic and foreign, including affiliations with foreign entities or governments (that are held by senior/key personnel). This includes titled academic, professional, or institutional appointments, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
If you have any questions on what to include on your “Other Support” or Biosketch, contact the applicable Sponsored Projects Office (SPO) to have your application updated. Find the applicable SPO website below and search for your department to find the specific SPO contact.
Health Sciences Sponsored Project Pre-Award Office (HSSPPO)
Office of Contract and Grant Administration (OCGA)
Office of Contract and Grant Administration (OCGA) Scripps Institution of Oceanography (SIO)
What should I include in my ‘Other Support’ and ‘Biosketch’ about my outside research activity?
Visit the Biosketch, ORCHID, Other Support, SciENcv training resources page for National Institutes of Health (NIH) and National Science Foundation (NSF) Biosketch, Other Support, and Current and Pending Resources.
What should I do if I am not sure if something needs to be included as ‘Other Support’?
Err on the side of disclosure. Federal agencies require complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic. If you have any questions about whether something should be reported, find the applicable Sponsored Project Office (SPO) website below and search for your department to find the specific SPO contact.
Health Sciences Sponsored Project Pre-Award Office (HSSPPO)
Office of Contract and Grant Administration (OCGA)
Office of Contract and Grant Administration (OCGA) Scripps Institution of Oceanography (SIO)
What if National Institutes of Health (NIH) determines that an institution is not complying with NIH policies for transparency and disclosure of all “Other Support”?
National Institutes of Health (NIH) takes the issue of protecting the integrity of U.S. biomedical research seriously. If noncompliance is identified, potential action by NIH may include withdrawing approval of the Principal Investigator or other researchers contributing to the NIH award, imposing specific award conditions, disallowing costs, withholding future awards including the possibility of suspending or terminating the award, per NIH Grants Policy Statement, Section 8.5.
What is an example of an activity that is not a foreign component, but would meet the definition of Other Support? What is the difference?
This is unique to each situation and depends upon specific details surrounding a particular activity. For instance, one model could be that a Principal Investigator (PI) on a National Institutes of Health (NIH) grant may have an appointment and a lab at a foreign university. The research being done at the foreign lab is unrelated to the PI’s NIH project. This would not qualify as a foreign component of the NIH research, as the foreign work is not part of the NIH-funded project. However, it is a resource made available to the researcher in support of their research. Therefore, it must be reported as Other Support.
Expand section OUTSIDE PROFESSIONAL ACTIVITIES OR COMMITMENTS
May I be appointed as an Adjunct Professor, Research Professor or Honorary Professor at another university or institution?
For faculty, category I activities are outside professional activities that require prior approval by the Chancellor and require disclosure in annual reporting. Faculty members report outside activities including Category I requests on the UC Outside Activity Tracking System (UCOATS). Category I activities include, but are not limited to:
- Teaching, research, or administration of a grant at an educational institution, trust, organization, government agency, foundation, or other entity outside of the University;
- Employment outside of the University;
- Assuming a founding or a co-founding role of a company;
- Assuming an executive or managerial position outside of the University
Category I activities also include holding an academic title (whatever the title and whether compensated or un-compensated), at other institutions, whether the institution is foreign or domestic.
Please see APM 025, the University of California policy on Conflict of Commitment and Outside Activities of Faculty Members for general campus faculty and APM 671 for Conflict of Commitment and Outside Activities of Health Sciences Compensation Plan Participants for faculty participating in the Health Sciences Compensation Plan. Please contact Academic Personnel for any questions about category I requests.
Please note, if you are included on a proposal, grant application or award outside of the University and there is no agreement with the University (even if you are not compensated), you are required to obtain an exception to conduct research outside of the University under UC Policy, “Requirement to Submit Proposals and to Receive Awards for Grants and Contracts through the University”, http://policy.ucop.edu/doc/2500500/ReqSubmitProp-Awar. Please visit the UCSD Exception webpage and Frequently Asked Questions (FAQs).
I have been approached by a foreign university/entity to participate in a “talents” program (e.g., 1000 Talents, New Century Talents Project, etc.), what should I do?
UCSD supports outside activities as long as they are disclosed and approved in accordance with UC Policy and the applicable federal agency. Please be aware that some Federal agencies prohibit the participation in talents programs. Please see the UCSD Foreign Government Sponsored Talent Recruitment Program section of the International Research and Engagement webpage.
I am a faculty member with a 9-month appointment. I spend two months at a University outside of the United States during the summer conducting research under a foreign award. What do I need to do?
If the faculty member is covered under APM 025 or APM 671, this should be disclosed as a Category 1 activity through UCOATS. It should also be reported as “Other Support.” Available resources in support of and/or related to an investigator’s research endeavors should be disclosed, even if they relate to work that is performed outside of a researcher’s appointment period.
In addition, if you are included on a proposal, grant application or award outside of the University and there is no agreement with the University (even if you are not compensated), you are required to obtain an exception to conduct research outside of the University under UC Policy, “Requirement to Submit Proposals and to Receive Awards for Grants and Contracts through the University”, http://policy.ucop.edu/doc/2500500/ReqSubmitProp-Awar. Please visit the UCSD Exception webpage and Frequently Asked Questions (FAQs).
For questions, contact the Research Compliance and Integrity Office at rci@ucsd.edu or (858) 822-4939.