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Foreign Involvement

"There is a heightened concern that certain foreign entities may be seeking to influence U.S. research at all levels including peer review, diversion of intellectual property, sharing of confidential information and the use of resources originating outside the U.S... Therefore, we must comply with existing and new policies and regulations, including those related to full disclosure of foreign engagements, conflicts of interest, and conflicts of commitment." (Elizabeth H. Simmons, Executive Vice Chancellor, Academics Affairs and Sandra A. Brown, Vice Chancellor, Research, UC San Diego, 1/25/2019)
"Applicants for federal grants must list all foreign affiliations [in their] biosketch and "other support" prior to award and are required to identify any changes in each annual progress report. 
  
According to NIH policy foreign influence includes: 
  • 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."
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UC San Diego is interpreting NIH's definition of foreign involvement as being work performed outside of the U.S. If the work is not done outside of U.S. soil, then it is not considered a foreign component.  For NIH, all foreign affiliations that fit the above interpretation should be disclosed on proposals, progress reports, and final technical reports, be it financial or non-financial in nature.

For New, Renewal, Resubmission, and Supplement Applications in ASSIST, where do you identify foreign involvement?
  • R&R Other Project Information FormItem 6: Does this project involve activities outside of the United States or partnerships with international collaborators? Indicate whether this project involves activities outside of the United States or partnerships with international collaborators. Check "Yes" or "No." If Yes, list the country(ies) as well as you are required to upload a Foreign Justification under Item 12: Other Attachments
    • The Foreign Justification should "[d]escribe special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting. In the body of the text, begin the section with a heading indicating "Foreign Justification" and name the [PDF] file "Foreign Justification."
    • Foreign Justification Example Language to be used when foregin collaborations could result in co-authorship.
  • R&R Other Project Information Form: Item 10: Facilities & Other Resources. Describe any use of facilities or instrumentation at a foreign site.
  • Project/Performance Site Location(s) Form: Project/Performance Site Location 1 or Additional Location(s): enter all applicable non-U.S. performance sites that fit UC San Diego's interpretation of foreign involvement.
    • Note: if the foreign site does not have a DUNS #, then use 000000000 (nine zeros). For the Congressional District, use 00-000 (two zeros dash three zeros). 
  • R&R Senior/Key Person Profile (Expanded) Form: Biosketch: B. Positions and Honors: list all foreign affiliations in this section of the Biosketch as well as list all foreign awards in D. Research Support. 
  • R&R Budget Form: Travel, Foreign: "Identify the total funds requested for foreign travel. Foreign travel includes any destination outside of the U.S., Canada, Mexico, or U.S. possessions. In Section L. Budget Justification, include the purpose, destination, dates of travel (if known), and the number of individuals for each trip. If the dates of travel are not known, specify the estimated length of trip (e.g., 3 days)."
  • For more information, please see the SF424 Guidelines.
For Just-in-Time in eRA Commons, where do you identify a foreign involvement?
For SNAP & Non-SNAP RPPR Progress Reports in eRA Commons, where do you identify a foreign involvement?
  • Section D – Participants: if the individual’s primary affiliation is with a foreign organization, provide the name of the organization and country. 
  • Section E – Impact: E.4: indicate what dollar amount of the award’s budget is being spent in foreign country(ies), and if more than one foreign country identify the distribution between the foreign countries.
  • Section G. Special Reporting Requirements: G.9 Foreign Component: provide the organization name, country, and description of each foreign component. 
  • Template language if you have a Paid Direct Foreign Student or Post Doc: "X were visiting graduate students from X Foreign University. They were financially supported by a scholarship from the foreign government, which covered their living expenses in San Diego, with no fund brought here to support their research work in the lab at UCSD. All the research work and experimental data reported in our most recent paper were done in Dr.’s X UCSD lab."
  • RPPR G.9 FOREIGN COMPONENT Example Language to be used if collaborations resulted in co-authorship.
  • Human Subjects System (HSS): Planned Inclusion Enrollment Report: indicate whether the IDR involves participants from a non-US site (i.e., foreign) or a US site (i.e., domestic).
  • For more information, please see the RPPR Instruction Guide.
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