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Disclosing International Research Activities

Vanderbilt is driven by its academic vision to lead through education and research, and supports international exchange of ideas. See below for information on investigator’s responsibility to disclose to specific federal agencies, as well as to Vanderbilt, to protect intellectual property and comply with federal guidelines. These guidelines intend to promote transparency, so that collaboration can thrive.

Current Guidelines for Disclosing to Federal Agencies

NIH created a table outlining what needs to be disclosed and how is continuing to updating an FAQ to address specific details. 

  • In the biosketch, key personnel must disclose scientific affiliations or appointments 
  • In Other Support, disclose all sources of support for all research activities.
    • Remember to including in-kind resources that are uniquely available to key personnel (office/laboratory space, equipment, supplies, and employees) including those available outside the applicant institution.
    • Include funds outside of appointment period, such as summer research funding.
    • Report all current and pending support at the time of applicant submission, in progress reports, and other times, if there are substantive changes.
  • Disclose Foreign Components on proposals, progress reports and final technical reports.
    • Check yes to a question such as “Does this project involve activities outside of USA” on the cover page.
    • Identify and list non-US performance sites for the project.
    • Identify international collaborators and their roles.
    • Review all pending & active awards and contact Sponsored Programs Administration to correct errors if any.

NSF has worked in close collaboration with the NIH on Research Security, including efforts to harmonize their practices and in the creation of a similar table outlining Pre-award and Post-award Disclosures and a FAQ on Current and Pending Support

DoD requirements will be listed in the each Notice of Funding Opportunity and will include informaition to be included in biosketches and other support disclosures. 

  • In the biosketch, all key personnel, should include all positions, including unpaid positions, honorary titles, affiliated and joint positions, and participation in Talents Programs.
  • All key personnel need to disclose other support, including
    • list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source
    • Title and objectives of the other research projects
    • The percentage per year to be devoted to the other projects
    • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded
    • Name and address of the agencies and/or other parties supporting the other research projects
    • Period of performance for the other research project
  • The DoD released a policy for Risk-Based Security Reviews of Fundamental Research. DoD will use a decision matrix for reviewing potential conflicts due to foreign influence. These security reviews will be distinct from technical reviews, and mitigation is the preferred method for addressing identified risks.
  • Per a December 2023 memorandum, DARPA has adopted the above DOD Risk-Based Security Reviews policy. This policy replaces the previously established Countering Foreign Influence Program (CFIP) policy, DARPA Risk Rubric, and FAQs.
  • The US Army has not yet adopted the DOD Risk-Based Security Reviews policy and continues to use the Army Research Risk Assessment Program (ARRP) matrix for Senior/Key Personnel. ARRP helps identify and mitigate existing or potential risk associated with Conflict of Commitment and/or Conflict of Interest (CoC/CoI) in Army research grants and cooperative agreements. ARRP information for proposers is included in the Army's Research Laboratory Broad Agency Announcement (BAA) instructions. For more information, please see the FAQs and the official website detailing the program.

Funding opportunity announcements (FOA) will require that

  • applicants include current and pending support disclosures for all PIs and other senior/key personnel named in the application.
  • after selection and during the life of the award, if there are changes to or additions of PIs or other senior/key personnel, such person(s) must also submit current and pending support disclosures within 30 days of joining the project team, or on a timeline consistent with the program office instructions.
  • for all PIs and other senior/key personnel, if there are changes to the previously submitted current and pending support disclosures, the individuals must update their disclosures within 30 days of the change, or on a timeline consistent with the program office instructions.

NASA recently revised its Grant and Cooprtative Agreement Manual (GCAM) with a new conflict of interest (COI) and conflict of commitment (COC) disclosure policy and an associated term and condition. This change is effective December 2023.

Disclosing to Vanderbilt