Overview
In light of the continued concerns regarding undue foreign influence on federally funded research, all UCSF researchers should familiarize themselves with disclosure requirements to avoid exposing their projects, themselves, and UCSF to risk.
What do I need to disclose?
- Disclose all sources of support: All current and pending support of your research endeavors, regardless of whether this effort is through UCSF, through an outside entity, or a personal venture, must be disclosed to external research sponsors as required by their guidelines and regulations. This includes both foreign and domestic sources of support and also includes travel, housing, gifts, or other types of compensation received from any foreign entities.
- Disclose all appointments and affiliations: All academic professional or institutional appointments held by investigators must be disclosed in applications for external funding. This includes those that are domestic or foreign, paid or unpaid, or full/part-time/voluntary (including adjunct, visiting or honorary).
- Disclose foreign consulting activity: All time spent working for or consulting with foreign entities or institutions must be reported to the university (i) in your Financial Conflict of Interest disclosure in Research Gateway, regardless of whether such activity is conducted in your professional or personal capacity, and (ii) potentially as an outside professional activity in OATS, and whether such effort is paid or unpaid. See Conflict of Interest and Conflict of Commitment. If this activity is in support of and/or related to your research efforts, it must also be disclosed under your current and pending support in your proposals to federal agencies.
- Disclose foreign collaborations in sponsored projects: Collaboration with a foreign entity (e.g. subawards, consultants, funded or unfunded collaborations with investigators located at a foreign site, etc.) in a project must be disclosed in funding applications and project reports. Additionally, adding a foreign collaboration to an existing award may require prior approval from the sponsor.
- Report foreign gifts and private grants: UCSF is committed to complying with reporting requirements for foreign gifts, as outlined in Section 117 of the Higher Education Act of 1965 and UCSF Policy 450-12.
It is highly recommended that you sign up for and use ORCiD.
Contact the Office of Sponsored Research for more information on any of the above.
NIH Decision Matrix for Assessing Foreign Influence
The National Institutes of Health (NIH) recently issued their decision matrix for assessing potential foreign influence. The matrix notes that "undisclosed or incompletely disclosed" affiliations and activities may require mitigation measures.