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Research collaborations are among the most common form of international partnerships for Rutgers faculty, students, and staff. New and exciting discoveries constantly are being made throughout the world, and it is critical that we promote an environment that allows the best scholars everywhere to work together to solve our most challenging problems. Research activity must be reliable, credible, and reproducible in order to enable subsequent research to build on earlier work. However, when we learn of undisclosed relationships, whether foreign or domestic, that appear to be related to research activities, the credibility of that research is undermined. Rutgers’ research administration support processes and resources as described below have been designed to help protect our researchers.
Funding Proposals & Awards
Research activities may include the effort of or resources from a foreign individual or entity. The National Institutes of Health (NIH) defines a foreign component as, “the performance of any significant scientific element or segment of a project outside of the U.S. either by the NIH award recipient or by a foreign organization, whether or not grant funds are expended.”
Foreign components must be identified in research proposals, progress reports, and final technical reports, and require prior approval from the NIH. Foreign components may include activities such as:
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 in connection with performance that occurs at a foreign site;
Research at a foreign site involving human subjects or animals;
Extensive foreign travel for the purpose of data collection, surveying, sampling, and similar activities; and
Activities that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country (e.g., through an impact on another country’s wildlife, population, or environment).
In NIH grant application forms, a foreign component may be identified by:
Indicating “yes” to the “activities outside the US/partnerships with international collaborators” checkbox on the Research & Related Other Project Information form;
Listing a non-US project/performance site location;
Identifying foreign relationships/activities in the biosketch; and
Identifying foreign financial support in the Other Support documentation.
Visit NIH R&R Other Project Information Form for details on how to complete the form with respect to foreign components.
It is also important in NIH and National Science Foundation (NSF) proposals to report all resources for research, including those from foreign entities, in the “Current and Pending Support/Other Support” documentation. This includes any research support you receive. Examples include, but are not limited to:
Financial support from a foreign award for work conducted outside the U.S. and/or outside the investigator’s Rutgers University appointment, whether received by an investigator or another organization;
Equipment or research material provided by a foreign organization;
Consulting relationships relating to your expertise;
Work with visiting personnel who are supported by a foreign organization; or
Funds received from a foreign recruitment program (e.g., China’s Thousand Talents Program or other “Talents Programs”).
The NIH further notes that “Other Support” includes all foreign and domestic resources made available to a researcher in support of or related to their research, regardless of whether or not the resources have monetary value. Examples of other support include Rutgers University internal funding and consulting. Other support is reported to NIH prior to the award activation as part of the “just-in-time” process, as well as in progress reports submitted to NIH. Pending applications for support should be reported as part of the “just-in-time” process, but such support does not need to be identified in progress reports until it is committed by the sponsor.
NIH specifically excludes start-up funding, training awards, prizes, and gifts from its definition of Other Support. For helpful information regarding the types of activities and how and when they should be reported to the NIH, please visit https://grants.nih.gov/policy/protecting-innovation.htm. For additional information, please review the NIH Grant Policy Statement or contact Rutgers’ Research and Sponsored Programs at firstname.lastname@example.org.
For NSF awards, financial and non-financial resources made available for research should be reported. Per the NSF, “Current and Pending Support” includes “all current project support from whatever source” and “all other projects or activities requiring a portion of time [i.e., commitment] of the principal investigator (PI) and other senior personnel must be included, even if they receive no salary support from the project(s).” (NSF Grant Proposal Guide, Chapter II). The NSF has helpful FAQ’s that address specific situations and how and when they should be disclosed.
NOTE: Include all foreign affiliations and partnerships in your Biosketch and Other Support documents. This includes relevant positions such as appointments and/or visiting scholar affiliations held at foreign institutions. Currently, Rutgers is advising that any foreign affiliation should be disclosed as “relevant.” In addition, foreign activities should be disclosed in your Rutgers eCOI updates and Ethics Armor disclosures.
For more information about disclosure of Other Support, please visit the ORED Research and Sponsored Programs.
For Existing Awards
The NIH requires that Rutgers obtain prior approval whenever a significant part of a project will be performed outside of the United States, regardless of who is doing the work or whether or not the work is funded. To add or amend a foreign component on an existing NIH award, notify your Grant Specialist in the ORED Office of Research and Sponsored Programs to assist with the acquisition of prior approval from the sponsor. If the NIH approves the foreign component, include the Foreign Justification document in the annual (or final) Research Performance Progress Report (RPPR).
The NSF has added questions to its RPPR’s relating to any changes in active other support since the previous RPPR and its impact on the project. NSF has also instituted a process for post-award disclosure of undisclosed current support and in-kind contributions that must be submitted by an authorized official (from ORED’s Research and Sponsored Programs) within 30 days of discovery of the undisclosed information.
FAILURE to disclose appropriately can have serious consequences to the research project in question, the investigator and even Rutgers.
Federal oversight agencies and the US Congress have highlighted recent concerns about the theft of intellectual property from US universities by foreign individuals and entities. In some cases, individuals have been able to divert this intellectual property by failing to disclose new inventions and discoveries in accordance with institutional policy and federal law. All employees have an obligation to report intellectual property and any improvements to existing intellectual property promptly to theRutgers University Office of Research Commercialization via an invention disclosure.
ORC’s Notice of Invention forms and Patent Policy documents can be found on theForms, Policies and Guides page.