Intl Research – https://sites.research.uci.edu

International Research Activities and Engagement

To support UCI’s continued engagement and collaboration in research with the international community while also addressing the federal government’s expressed concerns about undue foreign influence, the Office of Research created this website to provide the essential information and helpful resources.

Update

Click link: New Office of Research Videos for Creating NSF-Compliant Biographical Sketches

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Basics (How to get started)

Details (Intl Research Activities)

How to get started

Disclose accurately, completely, properly, and consistently for the disclosure requirements of domestic and foreign interests related to UCI employment and federal research awards

Recommendation: Maintain a set of up-to-date records of your activities and relationships to refer to when completing these disclosure requests

Maintain an updated CV
Master Log is a tool and example of the types of information you need to maintain and track

Federal agencies are investigating discrepancies and failures to disclose in university grantees, which resulted in some cases, universities terminating researcher’s employment and criminal and civil charges

Who Needs to Disclose	Disclosure Type	When to Disclose	Who to Disclose to	Contact/Resources
UCI Employees	Intellectual Property - Record of Invention	Submitted after invention’s discovery	UCI Beall Applied Innovation Research Translation Group	http://innovation.uci.edu/about/research-translation/
UCI Faculty	Conflict of Commitment: outside professional activities in UC OATS	Annually based on the fiscal calendar, Prior Approval for Category 1 Activities	UCI Academic Personnel	Ilona Pak (ipak@uci.edu) https://ap.uci.edu/directory/
Researchers (varies based on applicable Conflict of Interest policy(ies)- see COI Disclosure Chart)	Conflict of Interest: personal outside financial interests Public Health Service/National Science Foundation: KR COI Annual Disclosure Other policies have different disclosure procedures	With certain research project based transactions (such as proposal, award, continuing award, etc.)	UCI Conflict of Interest	coioc@research.uci.edu Conflict of Interest (Office of Research)
Researchers (varies by federal agency)	Biographical sketches: positions, affiliations, etc.- see Details	In federal grant/contract applications	Federal Agency	International Activities & Relationships Compliance (Office of Research)
Researchers (varies by federal agency)	Other Support/Current & Pending Support: research related resources, collaborations, etc.-see Details	At just-in-time/with application and updated with federal project’s annual progress reports	Federal Agency	International Activities & Relationships Compliance (Office of Research)

Develop your awareness of undue foreign influence risks and implement practices to reduce risk

Training
- Compliance & Conflict of Interest for Researchers Briefing (COIR)- search "COIR"
- Export Control
  - Export Control Videos
  - Export Control Training Modules
Potential Undue Foreign Influence Risks

Federal Sponsored Projects Requirements

Public Health Service (National Institutes of Health)

Biographical Sketches

Timing: Submit with application

Applies to: All Senior/Key Personnel and Other Significant Contributors

What to disclose: Include positions and honors, list any relevant foreign and domestic, paid and unpaid academic and professional appointments, achievements, and honors including voluntary, guest, adjunct, honorary

Resources: https://grants.nih.gov/grants/forms/biosketch.htm

Foreign Component

Timing: Submit with application and requires prior approval when adding a foreign component to the NIH award in Research Performance Progress Report

Applies to: PHS Project- It is the Program Director/Principal Investigator's responsibility to include foreign component information in the application and request prior approval if necessary

What to disclose:

Foreign Component: performance of a significant scientific element of the NIH-supported project outside of the US, whether or not funds are expended

Examples of “significant”:
- Collaborations with investigators at a foreign site anticipated to result in co-authorship
- Use of facilities or instrumentation at a foreign site
- Receipt of financial support or resources from a foreign entity
"Outside of the US" or Foreign: organization located in a country other than the US and its territories that are subject to the laws of that country, regardless of the citizenship of the proposed Program Director/Principal Investigator

Resources:

UCOP Foreign Component Infographic: https://www.ucop.edu/ethics-compliance-audit-services/_files/compliance/research/foreign_component_infographic.pdf
NIH FAQs: https://grants.nih.gov/grants/faq-other-support-foreign-components.htm#
Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interests and Foreign Components: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html

Financial Conflict of Interest

Timing:

KR COI Annual Disclosure required prior to proposal submission and at least annually for the duration of the award
Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award and at least annually for the duration of the award

Applies to: All Investigators are required to disclose their significant financial interests.

"Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS, or proposed for such funding, which may include, for example, collaborators or consultants. For more clarification, please visit Identifying PHS Investigators.

For non-UCI Investigators on the UCI's award/proposal and any subrecipients following UCI's PHS COI Policy, all individuals that meet the definition of an Investigator must submit the Form 800SR.

What to disclose:

"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the Investigator's Institutional Responsibilities includes the following:

Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
Any reimbursed or sponsored travel

The term "Significant Financial Interest" does not include: salary, royalties, or other remuneration paid by the UCI to the Investigator if the Investigator is currently employed or otherwise appointed by the UCI, including intellectual property rights assigned to the UCI and agreements to share in royalties related to such rights; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or income from service on advisory committees or review panels for a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.

Resources:

Other Support

Timing: Submit at Just-in-Time and update in annual progress reports

Applies to: All individuals designated in an application as senior/key personnel except:

Program Directors, training faculty, and other individuals involved in the oversight of training grants
Individuals categorized as Other Significant Contributors

What to disclose:

All foreign and domestic resources made available to a researcher in support of and/or related to ALL of their research endeavors (regardless of whether they have monetary value and whether they are at the institution the researcher identifies for current grant)
Resources includes but not limited to foreign and domestic:
- Current and pending support including support through the applicant organization, through another domestic or foreign organization, or provided directly to an individual that supports the senior/key personnel’s research efforts
- Positions and scientific appointments including paid and unpaid, full-time, part-time, and voluntary (including adjunct, visiting, or honorary) titled academic, professional, or institutional appointments and affiliations with foreign entities or governments
- Financial support for laboratory personnel
- Provision of high-value materials not freely available (e.g., biologics, chemical, model systems, technology, etc.), in-kind support and contributions (e.g. office/laboratory space, equipment, supplies, employees)
- Foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program
- Income, salary, consulting fees, and honoraria in support of an individual’s research endeavors
- Research collaborations that directly benefit the researcher’s research endeavors

Resources:

NIH Recommendation: "In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.”

Purpose: NIH evaluation of Other Support to ensure:

All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
Sufficient levels of effort are committed to the project
There is no scientific, budgetary, or commitment overlap
Only funds necessary to the approved project are included in the award

More Information

UCOP Foreign Influence- National Institutes of Health

National Science Foundation

Biographical Sketches

Timing: Submit with application

For new proposals submitted or due on or after 10/5/20, must be PDFs generated through use of an NSF-approved format, https://www.nsf.gov/bfa/dias/policy/biosketch.jsp

Applies to: All Senior Personnel

What to disclose: Includes education and training, ALL titled foreign or domestic academic, professional, or institutional positions whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary)

Resources:

International Activity

Timing: Submit with application by listing primary countries involved on the coversheet

Applies to: NSF Project

What to disclose: International Activities include:

International Research/Education/Training Activities: research, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the US using virtual technologies.
International Conferences: enter on the Cover Sheet country/countries with which project participants will engage and/or travel to attend international conferences
Work in foreign countries: PI responsible for obtaining required authorizations if necessary to conduct work in foreign countries.

Resources:

NSF International Activities Instructions

Conflict of Interest

Timing:

KR COI Annual Disclosure required prior to proposal submission
Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award- COI Team will send a follow-up NSF question if the Investigator has a positive KR COI Annual Disclosure at award stage to determine if a COIOC review is required
Investigators are required to disclose if they acquire or discover a new significant financial interests during the period of the NSF award

Applies to: All Investigators are required to disclose their significant financial interests.

- For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR

What to disclose:

"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the NSF project includes the following:

Total income or payment of services received over the past 12 months exceeding $10,000
- Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the UC Regents)

Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest.

Resources:

Current & Pending Support

Timing: Submit with application and update in annual progress reports

For new proposals submitted or due on or after 10/5/20, must be PDFs generated through use of an NSF-approved format, https://www.nsf.gov/bfa/dias/policy/cps.jsp
RPPR: On October 5, 2020, NSF will add the following new question to the Edit Participants screen: Has there been a change in the active other support of the PI/PD(s) since the last reporting period? If Principal Investigators (PIs)/Project Directors (PDs) and co-PIs/co-PDs select “Yes,” they will be required to upload their most up-to-date Current and Pending Support document in an NSF-approved format to notify NSF that active other support has changed since the award was made or since the most recent annual report.

Applies to: All Senior Personnel

What to disclose:

Includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value including but not limited to the following:
- In-kind contributions with the expectation of an associated time commitment (such as office/laboratory space, equipment, supplies, employees, students) not intended for use on project/proposal being proposed
  - Notes: In-kind contributions intended for use on the project being proposed to NSF should be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be replicated in the current and pending support submission. Gifts (such as services, lodging, equipment time, etc.) are by definition given without the expectation of anything in return and do not need to be reported.

Resources:

NSF-Approved Formats for Current & Pending Support
UCI Other Support Report Coming Soon
Current and Pending Support Instructions: PAPPG, Chapter II.C.2.h
NSF FAQs on Current & Pending Support

Article 38: Post-award Disclosure of Current Support and In-Kind Contribution Information- Effective 10/5/2020, if an organization discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the Authorized Organizational Representative must submit the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.

More Information

UCOP Foreign Influence- National Science Foundation

Department of Defense

Current & Pending Support

Timing: Submit with application

Applies to: Proposals for all non-procurement research and research-related educational activities (i.e., grants, cooperative agreements, Technology Investment Agreements) should include the below information for all key personnel, whether or not the individuals’ efforts under the project are to be funded by DoD in the Senior Key Person Profile form included in the Notice of Funding Opportunities

What to disclose:

List of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of source
Title and objectives of other research projects
Percentage per year to be devoted to other projects
Total amount of support the individual is receiving in connection to each of the other projects or will receive if other proposals are awarded
Name and address of agencies and/or other parties supporting the other research projects
Period of performance of other research projects

Resources:

Actions for the Protection of lntellectual Property, Controlled Information, Key
Personnel and Critical Technologies

Please note that DOD proposals for other types of awards may have other requirements so please check the program solicitation.

More Information

UCOP Foreign Influence- Department of Defense

Department of Energy

Current & Pending Support

Timing: Submit with application as Appendix 2: Current and Pending Support

Applies to: Principal Investigator and senior/key personnel, including subawardees, regardless of funding source

What to disclose:

A list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; full-time, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. All foreign government-sponsored talent recruitment programs must be identified in current and pending support.

For every activity, list the following items:

The sponsor of the activity or the source of funding
The award or other identifying number
The title of the award or activity
The total cost or value of the award or activity, including direct and indirect costs. For pending proposals, provide the total amount of requested funding.
The award period (start date – end date).
The person-months of effort per year being dedicated to the award or activity
Briefly describe the research being performed and explicitly identify any overlaps or synergies with the proposed research.

Please note that DOE Offices other than the Office of Science may have different requirements; please check the program solicitation

Resources:

Purpose: Current and Pending support is intended to allow the identification of potential duplication, over-commitment, potential conflicts of interest or commitment, and all other sources of support.

More Information

UCOP Foreign Influence- Department of Energy

National Aeronautics and Space Administration

Restriction on Funding Activity with the People's Republic of China

NASA is prohibited form funding a “grant or cooperative agreement of any kind to participate, collaborate or coordinate bilaterally in any way with China or any Chinese-owned company at the prime recipient level or at any subrecipient level...”

Resources:

More Information

UCOP Foreign Influence- National Aeronautics and Space Administration

International Collaborations, Affiliations & Activities

Engaging with Restricted Parties

The US government maintains a number of lists of federally sanctioned, debarred, or restricted persons and organizations. Entities/organizations/persons on one of these lists may require campus approval and/or a license to work with them, which is why these reviews should be done prior to engaging in the work.

To know if an international entity/organization/person is on a restricted entities list, departments and the Export Control team has access to a screening tool called Visual Compliance. Contact the Export Control Team if you have any questions.

In some cases, the proposed work will need to be reviewed by the International Relations Council.

Resources:

Restricted Entities

Hosting International Visitors

International visitors should be screened to confirm there is no affiliation with restricted parties or embargoed organizations. Please contact your department or the Export Control Team for help screening your visitor.

Resources:

Participation in Foreign Government Talent Programs

Participation in Foreign Government Talent Programs is one of the key concerns from the US government. This relationship must be disclosed appropriately as Other Support/Current and Pending Support and possibly financial conflict of interest. Some agencies have additional requirements:

NSF- Personnel Policy on Foreign Government Talent Recruitment Programs
- NSF personnel and IPAs detailed to NSF cannot participate in foreign government talent recruitment programs
DOE- 486.1A Foreign Government Sponsored or Affiliated Activities
- DOE clarifies that of the restrictions contained in the order, only the prohibition on participation in foreign talent programs applies to university research projects when university staff come onto a DOE site to perform R&D work. In these cases, UC must report information required to meet this condition and follow the requirements of the order that pertain to foreign country of risk talent recruitment programs. These requirements also flow down to subcontractor employees.

Shipping Internationally

To help ensure that UC faculty, staff, and students do not experience customs delays, seizure of goods, or inadvertent violation of federal export laws, please visit the following website which describes the basic requirements for international shipping and hand carry of items abroad: https://research.uci.edu/ref/export-controls/exporter/international-shipping.html.

Travelling Internationally

Two important factors to consider while travelling internationally is:

Are there any export control restrictions on the items you plan to bring with you internationally? For more information, visit: International Travel and International Shipping.
Have you taken steps to protect the security of your data and information on your devices? For more information, visit International Travel Security Guidance.

UC Huawei Moratorium

The moratorium restricts any future engagements with Huawei, calls for the cessation of all pending projects, gifts, purchases or other engagements and requires locations to wind down existing agreements and consider risks associated with engagements with Huawei’s U.S. subsidiaries.

Frequently Asked Questions

What is undue foreign influence?

Foreign influence or undue foreign influence are terms used to describe the federal government's concerns over foreign governments and entities' influence in academia which could negatively impact the United State's economic competitiveness and national security. The four main areas of concern are:

Peer review violations
Failure to disclose substantial foreign resources, including but not limited to: foreign employment arrangements, foreign grant support that creates problem with overlap, or over-commitment, foreign talents programs.
Failure to disclose significant foreign financial conflicts of interest
Compliance with regulatory requirements including US Export Control laws and regulations, which establish a set of requirements for the transfer of technology and data to foreign countries and/or foreign nationals in the US and sanctions from the Office of Foreign Assets Control, which restrict interactions with individuals or entities on the sanctions list.

These concerns resulted in new legislation, federal investigations, and updated disclosure requirements, emphasizing the importance for researchers and universities to disclose accurately, properly and consistently and establish practices to reduce the risks.

How do I comply with undue foreign influence requirements?

Please review the Basics section above and continue to monitor our website and campus emails for announcements of changes since this is an evolving compliance area.

If you have specific questions, please contact Nadia Wong at nadiaw@uci.edu.

More FAQs

International Research Activities and Engagement

Update

Tools

Click the button below to switch views

Basics (How to get started)

Details (Intl Research Activities)

How to get started

Disclose accurately, completely, properly, and consistently for the disclosure requirements of domestic and foreign interests related to UCI employment and federal research awards

Develop your awareness of undue foreign influence risks and implement practices to reduce risk

Federal Sponsored Projects Requirements

Public Health Service (National Institutes of Health)

Biographical Sketches

Foreign Component

Financial Conflict of Interest

Other Support

More Information

National Science Foundation

Biographical Sketches

International Activity

Conflict of Interest

Current & Pending Support

More Information

Department of Defense

Current & Pending Support

More Information

Department of Energy

Current & Pending Support

More Information

National Aeronautics and Space Administration

Restriction on Funding Activity with the People's Republic of China

More Information

International Collaborations, Affiliations & Activities

Engaging with Restricted Parties

Hosting International Visitors

Participation in Foreign Government Talent Programs

Shipping Internationally

Travelling Internationally

UC Huawei Moratorium

Frequently Asked Questions

What is undue foreign influence?

How do I comply with undue foreign influence requirements?

Comments

Additional Resources