Foreign Influence and Other Support

This month, I will be discussing foreign influence and how this impacts other support (also called current and pending support). First, the University strongly supports all collaborations, including foreign, that further the research and scholarship of our faculty. Federal sponsors also recognize the value of these collaborations. However, to ensure research and scholarship is not inappropriately influenced and that federal funding and the results of that funding are protected, sponsors require transparency and disclosure of relationships with foreign entities. Most of these disclosures are done through the submission of "other support."

While many people are used to the fact that "other support" includes all of your sponsored awards through the University of Miami, it also includes many other types of support such as:

• Sponsored awards through other institutions
• Financial support for laboratory personnel
• High value materials that are not freely available or broadly available as an institutional resource
• Financial support from institutions other than the University of Miami
• Consulting agreements where you will be conducting research
• In-kind contributions (e.g., office/laboratory space, equipment supplies, and employees or students) provided by institutions other than the University of Miami

The penalties for non-disclosure can be significant. They include loss of funding, prevention from applying for or receiving federal funds, and in some cases, criminal charges. Our goal at the University is to make it as easy as possible for faculty to comply with regulations, the interpretation of which are often shifting. To protect faculty, we now require all faculty to disclose foreign engagements through UDisclose. The Office of Research Administration (ORA) now reviews those disclosures to ensure resources for faculty outside of the University are appropriately disclosed.

To help ensure compliance, federal agencies are changing their requirements for biosketches and other support. Most notably:

National Institutes of Health (NIH)

Starting January 25^th, 2022 all proposals and Just In Time (JIT) submissions must use new biosketch and other support templates. The biosketch requires the disclosure of ALL appointments including voluntary, honorary, part-time, and unpaid.

There is also a new template for other support which must be signed by the individual to certify the accuracy and completeness of the other support. Additionally, we must submit all contracts, agreements or other documentation related to foreign support. These documents must also be translated. Therefore, it is vital to identify these types of support as soon as possible to ensure the application is complete. The University will not be able to submit JITs or proposals that include other support if this is missing. Reach out to ORA early with questions!

National Science Foundation (NSF)

Like the NIH, the NSF now requires the disclosure of all appointments in the biosketch. This includes any titled academic, professional, or institutional position, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

Our goal is to protect our faculty and help them to navigate regulations and requirements. Please do not hesitate to reach out to me with questions or concerns on this topic.

Please join me on Tuesday, June 15^th at 12:00pm to discuss this topic further, I would love to hear from you!