Sponsor Requirements: Biosketch, Current & Pending & Other Support 

Investigators should familiarize themselves with the information provided by OVPR as well as specific guidance from their respective funding agency. Ultimately it is the Investigator's responsibility to appropriately disclose relationships, activities and components in accordance with internal and external policies. 

We strongly encourage investigators to err on the side of transparency when considering or reporting a foreign activity.   At some institutions, failures to disclose foreign connections or other regulatory violations have resulted in personnel actions and even indictments by law enforcement. Some federal funding agencies have stated that investigators who fail to disclose appointments or support from foreign entities may be ineligible to receive funding.

Best Practices 

Definitions of terms may differ by sponsor as the federal agencies have not adopted standard definitions or reporting requirements.  Investigators should read sponsor guidelines and requirements to ensure that they are disclosing and reporting in accordance with the specified agency.

Presently, there is no uniform practice among federal funding agencies for disclosing relationships, activities or components of research activities. There exist multiple ways in which such disclosures may be included in grant proposals and progress reports, depending on the funding agency.  In addition, funding  agencies provide guidelines for information to be included in publications resulting from grants and contracts. They also generally require that all publications resulting from sponsored research must be reported, typically in annual and final progress (or technical) reports. 

Update:  The Office of Science and Technology Policy issued a policy that requires federal sponsor agencies create implementation plans to adopt the Common Forms.  (February 14, 2024)

PROPOSALS AND AWARDS

• Approach the Office of Sponsored Programs (OSP) if your proposal includes foreign collaborations, foreign components and/or activities in a foreign country. Outreach early and discuss with your OSP Specialist as they will provide you with current institutional and Sponsor policies/guidelines.
• Read sponsor guidelines, Funding Opportunity Announcements (FOA), and proposal questions  (i.e. NIH Other Project Information Form Question #6 asks "Does this project involve activities outside of the United States or partnerships with international collaborators?") carefully to ensure that you and other project personnel are correctly answering the questions that address foreign engagements, foreign affiliations, and  Foreign Components  and collaborations, as required by the sponsor.
• At award stage, review agency definitions to verify that your interpretation of your sponsor's terms and conditions included in a notice of award and grants policy statements is correct. The  Office of Sponsored Programs  and your sponsor's program and grants management staff can be contacted with questions about definitions.
• Review current projects to ensure that all locations outside the U.S. where significant scientific activities are performed have been disclosed through progress reports and final technical reports (as applicable).
• Review each funding application to ensure that all resources available in direct support of an individual’s research activities (Other Support) is disclosed as required by the federal sponsor at the time of proposal submission, Just-in-Time/pre-award negotiation and post-award
• Identify foreign countries where the research activities are being conducted.
• Obtain Sponsor prior approval through OSP when adding a foreign component to an existing federal award.  
• Determine if sponsor approval is required for international collaborations resulting in co-authorship.

PUBLICATIONS 

• Cite in manuscripts only the funding which specifically supports the work in the publication. 
• Do not cite unrelated financial support in publications. 
• Check the funding agencies  guidelines for information to be included in publications resulting from grants and contracts. 
• Carefully review the sponsor's guidelines for reporting publications in reports (i.e. progress or final) as some sponsors differentiate between publications where funding specifically supported the work in the publication and all other publications.  

FOREIGN TALENT recruitment PROGRAMS

• Disclose participation in foreign talent recruitment programs to federal sponsors and the university.    
• Additional information and guidance on Foreign Recruitment Talent Programs 
• Contact the Director of Research Security or the Vice-President for Research if you have not disclosed participation in a foreign talent recruitment program to discuss the activity.

The Office of the Vice President for Research (OVPR) continues to monitor new regulations and guidance provided by funding agencies regarding foreign relationships and activities, and we will inform the University community of relevant changes. Updates and new information will also be provided on this page.