Guidance on Foreign Relationships/Affiliations

Recent reports and guidance from the federal government have highlighted the importance of disclosing financial interests, affiliations, activities, and relationships with foreign entities. At UCI, international collaboration is very important. However, it is also important to be aware of disclosure requirements and compliance procedures UCI has in place to protect faculty members. To facilitate compliance, this page highlights the different disclosure requirements and resources to contact if you have any questions.

  • Researcher's Outside Financial Interests

      Contact: Nadia Wong ( or COI Team (

      Foreign entities (governmental, nonprofit, forprofit) are not excluded from the following disclosure requirements:

      • PHS/NSF Investigators- KR COI Annual Disclosures
      • IRB Research Personnel- COI disclosures related to IRB protocols

      Foreign governmental entities are excluded from the following disclosure requirement:

      • Principal Investigators/Co-Principal Investigators on research contracts/grants/gifts from non-governmental sponsors
  • Research Grant Applications Current or Pending Research Support

      Contact: Paul Lekutai ( or SPA Team

    • Researchers whose research is supported with federal funding should update and maintain their current and pending support documentation. Make sure to include all sources of support foreign or domestic.

    • Visiting Scholars and Sponsored Programs


      A visiting scholar should submit other support documentation, if he/she will contribute in any way to the research set out in the scope of work. Submit in the format required by the sponsor and at the time the sponsor requires.

      On-going projects:

      You do not need to receive prior approval from NIH for a visiting scholar in your lab to work on a project. However, keep these requirements in mind: Report all participants on a project within your progress report. This section also requests whether the individual’s primary affiliation is with a foreign organization.

      Consider Visiting Scholars working on the project as Key Personnel, thus triggering the need to submit his/her Biosketch and Other Support in the “ Personnel Updates” section of the RPPR, if you haven’t already.

    • National Institutes of Health (NIH)

      Update: On March 12, 2021, the NIH announced the release of updated Biosketch and Other Support format page templates and requirements (NOT-)D-21-073) required for applications, Research Performance Progress Reports (RPPR), and Just-In-Time requests submitted for due dates on or after May 25, 2021. The updates promote transparency and full disclosure of all resources (both foreign and domestic) that directly support an individual’s research endeavors.

      Key changes:

      • Other Support:
        • Signature block added.  The Program Director (PD)/Principal Investigator (PI) and Other Senior/Key Personnel must electronically sign the other support form to certify its accuracy.
        • Supporting documentation. If Other Support includes foreign activities or resources, the PI/PD or Other Senior/Key personnel much attach copies of contracts, grants, or any other agreement specific to their foreign appointments and/or employment with a foreign institution, as well as for all foreign activities and resources reported in Other Support. If these documents are not in English, they must provide translated copies.
        • Immediate notification of undisclosed Other Support.  As soon as it becomes known to UCI that a PI/PD or Other Senior/Key personnel on an active NIH grant failed to disclose Other Support information when submitting the Just-in-Time information or RPPR, as applicable, UCI must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.  Even accidental oversight may have individual and/or institutional reputational consequences.  Therefore, PIs/PDs and Other Senior/Key Personnel should take great care to ensure that Other Support is properly and completely disclosed.
        • Format.  NIH reorganized the Other Support page to separate funded projects from in-kind contributions.

      FAQs -

      • Biosketch:
        • NIH renamed Section B “Positions and Honors” to be “Positions, Scientific Appointments, and Honors” and updated the instructions to read (specific changes are in bold italics):
          • List in reverse chronological order all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). High school students and undergraduates may include any previous positions. For individuals who are not currently located at the applicant organization, include the expected position at the applicant organization and the expected start date.
        • As applicable, all applicants may include details about ongoing and completed research projects from the past three years to which they want to draw attention within the personal statement, Section A (previously known as research support)
        • Removed:
          • Section D for non-Fellowship Biosketch
          • “Research Support” from Section D for Fellowship Biosketch

      FAQs -

      Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.

      This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely avaialble.

      NIH applicants must: 

      1. List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments.
      2. Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation.
      3. Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources must be reported.
      4. Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.

      NIH requires recipients to determine whether activities it supports include a foreign component, defined as: The existence of any “significant scientific element or segment of a project” outside of the United States. In other

      1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
      2. performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

      If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign

      If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it
      must be reported as other support.

    • National Science Foundation (NSF)

      NSF Pre-award and Post-award Disclosure Guidance Relating to Biographical Sketch and Current and Pending Support (June 2021)

      Include all financial resources and commitments of time even if no salary support is received.

      • All current and pending support, including this project, for ongoing projects, and for any proposals currently under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.
      • All projects and activities, current or proposed that require a time commitment from the individual must be reported, even if the support received is only in-kind (such as office/laboratory space, equipment, supplies, employees, students).
      • The total award amount for the entire award period covered (including indirect costs) must be provided, as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior personnel involved.
      • Concurrent submission of a proposal to other organizations will not prejudice its review by NSF, if disclosed.
      • If the project (or any part of the project) now being submitted has been funded previously by a source other than NSF, provide the required information describing the last period of funding. For example, Federal, State, local, foreign, public or private foundations, non-profits, industrial or other commercial organizations, consulting, or internal funds allocated toward specific projects.

    • Department of Defense (DOD)

      Refer to the specific Notice of Funding Opportunity (NFO) for details on requirement for current support documentation from all key personnel at the proposal stage.

      This info will be required for key personnel whether or not their efforts on the project are DOD funded.

    • Department of Energy (DOE)

      Refer to specific DOE Funding Announcement instructions on Current and Pending Support.

  • Relationships/Activities with Restricted Entities

      Contact: Export Control Officer (

      If you are planning an activity or developing a relationship with a foreign entity, please use this Consolidated Screening List tool. If there are any results from your search, please contact Export Control to determine if the result is a match and whether or not any additional steps are required.

  • Faculty Member's Outside Professional Activities (Conflict of Commitment)

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