Foreign Influence

Foreign influence is the inappropriate or inadvertent sharing of confidential and/or proprietary information, intellectual property, or data of grant applications, unpublished research or technologies. Recently, the NIH has identified at least 100 instances of foreign influence on extramural research. And, investigators at more than 65 institutions failed to report foreign ties, funding sources, and conflicts of interest.

This is a reminder that disclosing all support - foreign and domestic - is fundamental to transparency in research funding. UTMB policies help to raise awareness of foreign influence and reiterates the regulatory requirements aimed at preventing it.

BIOSKETCH CHECKLIST

CITI COURSE UNDUE FOREIGN INFLUENCE: RISKS & MITIGATION

NIH REQUIREMENTS FOR DISCLOSURE

NIH SUBAWARDS TO FOREIGN ENTITIES

What to Disclose

All faculty funded by or submitting to NIH must disclose all resources or "other support" made available to a researcher regardless of its monetary value and regardless of whether the support is based at the current grantee institution. All investigators are required to disclose the following:

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List all positions and scientific appointments

List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments regardless of compensation or benefit status, including adjunct, visiting, or honorary positions.
Report all resources and other support

Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts.
Report all current projects & activities

Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.
Provide total award amount

Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.
Report all pending support

All pending support at the time of application submission and prior to award must be reported using “Just-in-Time Procedures” by providing all information indicated above. Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award, including “Other Support” changes that must be assessed for budgetary or scientific overlap. Further, if other support, as described as above, is obtained after the initial NIH award period, from any source either through the institution or directly to senior/key personnel, the details must be disclosed in the annual research performance progress report (RPPR). Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”

In addition, NIH grant recipients must identify and disclose whether there are any foreign components in its research projects. Foreign components include:

Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended; and/or
Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether-or-not NIH grant funds are expended.

Research Quick Find Tool

Research Experts

Funding Institutional

❑	Any titled academic, professional or institutional position regardless whether or not remuneration is received
❑	All full-time, part-time or voluntary positions
❑	All adjunct, visiting or honorary appointments
❑	All appointments at foreign institutions – even if labeled as “guest”
❑	Unpaid appointments at foreign institutions
❑	Domestic appointments
❑	Foreign appointments
❑	Affiliations with foreign entities or governments
❑	Affiliations or appointments likely to be cited in sponsor-funded publications
❑	Advisor to foreign institution on their program of research
❑	Ongoing and completed research projects from the past three (3) years that the applicant wishes to highlight

Research Administration

Foreign Influence

What to Disclose