Federal sponsors require investigators and key personnel to fully disclose international relationships, foreign appointments, and all sources of research support to protect research integrity and address risks related to foreign influence. This page provides guidance and required resources for complying with NSF, NIH, and Department of Defense disclosure requirements at both the pre-award and post-award stages.
Disclosures of Foreign Ties
NSF requires disclosure of all current and pending support, including foreign support, in the biographical sketch and current and pending support documents.
- NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support
- NSF Current and Pending Support FAQs (January 2022)
- NSF Dear Colleague Letter on Research Protection (July 11, 2019)
NIH policies require investigators to disclose foreign appointments, activities, resources, and financial interests, including in-kind contributions and foreign components of research.
- NIH Notice NOT-OD-19-114 Reminders of NIH policies on Other Support, financial conflicts of interest, and foreign components
- NIH Notice NOT-OD-21-073 Updated requirements for applications due on or after May 25, 2021, including:
- New biographical sketch formats and instructions
- New Other Support format with in-kind contributions listed separately
- Required submission of supporting documentation, including foreign grants and contracts (translated into English)
- Immediate notification of previously undisclosed Other Support
- Electronic certification by PIs and key personnel attesting to the accuracy of disclosures
Required forms:
The DoD has issued guidance to counter unwanted foreign influence in Department-funded research.
- DOD guidance and decision matrix (June 29, 2023) Countering Unwanted Foreign Influence in DoD-Funded Research at Institutions of Higher Education
Why This Matters
Failure to fully and accurately disclose international relationships, foreign support, or affiliations may result in compliance findings, funding delays, or enforcement actions by federal sponsors. Investigators are responsible for ensuring that all required disclosures are complete, current, and accurate throughout the life of an award.
Related Subrecipient Topics
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