Foreign Components and Foreign Affiliations

Foreign Components and Foreign Affiliations
Over the past several months, Congress and federal funding agencies have voiced their concerns about the potential for improper foreign influence in U.S. academic research. On April 18, 2019, Dr. Bruner sent a “Dear Colleague” letter to the Emory research community.

Highlights and Reminders
To ensure complete disclosure, faculty should:

  • Complete forms requesting information on research support, such as the NIH’s Other Support or NSF’s Current and Pending Support, with detailed and comprehensive information that provides details on all forms of research support, including support from foreign sources and gifts, regardless of the sponsoring entity.
  • Disclose all compensated or uncompensated external affiliations, especially affiliations with foreign organizations, in all grant proposals and progress reports. If you have an affiliation that should be disclosed and are unsure where or how to disclose the information, please contact your analyst in the Office of Sponsored Programs for guidance.
  • Correctly identify when an NIH proposal has a foreign component. NIH’s current definition of “foreign component” as the “performance of 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.” The NIH Grants Policy Statement goes on to further clarify that the following activities would meet the definition:
      • the involvement of human subjects or animals;
      • extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities; or
      • any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.
  • Additional activities that may also indicate that a grant has a foreign component include:
      • collaborations with investigators at a foreign site anticipated to result in co-authorship;
      • use of facilities or instrumentation at a foreign site; or
      • receipt of financial support or resources from a foreign entity.

Foreign components require prior approval by the NIH. Additional information on what should be disclosed is available from the Office of Sponsored Programs.

Ensure Compliance with Export Controls Regulations:
Export controls regulations can apply to a wide range of research activities, regardless of the source of funding. Consult the Office of Compliance if you have any export control related questions.

Required Survey for Federally Funded Faculty – Foreign Talent Programs
Federally funded faculty members must complete the Required Survey regarding Foreign Talent Programs by June 14, 2019.

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