International Collaboration

While the University of Cincinnati strongly supports international collaboration and values our partners, it is important that everyone at UC understand the current regulatory landscape and the importance of transparency.

 
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Frequently Asked Questions

UC Specific FAQs

Biosketch

NIH has revised the Biosketch on the most recent forms. The NIH policy states that investigators must report all positions, domestic and foreign, including titled academic, professional, or institutional and regardless of whether full-time, part-time, voluntary, adjunct, visiting, honorary, or if remuneration is received. Any in-kind or other support received in association with these positions must be reported as Other Support. For positions or appointments with foreign entities, researchers will need to provide an English translation of any agreement along with the foreign-language version.

You must disclose all positions, domestic and foreign, including titled academic, professional, or institutional, regardless of whether full-time, part-time, voluntary, adjunct, visiting, honorary, or if remuneration is received.

These appointments need to be disclosed in the Biosketch. If appointments include any support (financial or in-kind) for research activity, you also need to report the appointment and support as Other Support. The appointment also needs to be disclosed to UC (OAR disclosure system).

Collaborators and Foreign Components

Based on NIH policy statements, and FAQ 27, researchers that perform experiments that benefit any of the PI's research (regardless of location) are considered collaborators and must be reported as Other Support.

If the collaborator provides support for an NIH award and the work is being performed outside the US, the collaboration may be considered a "Foreign Component." Foreign Components exist if a significant scientific element or segment of the project (including any experiments) are being performed for the project outside the US, whether or not NIH funds are used to support that work. Foreign Components require prior NIH approval. If you believe you may have a Foreign Component, please contact the Office of Sponsored Research Services (SRS).

If you believe you need to disclose Other Support or a Foreign Component retroactively, please contact the Conflict of Interest (COI) Officer. If you, the COI Officer, and SRS determine that there is something to report, you will work with Office of Research (OoR) to submit the retroactive disclosure to NIH.

Report research collaborations, both foreign and domestic, that benefit your research endeavors as in-kind support.

If the collaborator is providing research support for a specific NIH award and the work is being performed outside the US, the collaboration may be considered a "Foreign Component" (as defined above) for that project, whether or not NIH funds are used to support that work. Foreign Components require prior NIH approval. If you believe you may have a Foreign Component, please contact the please contact the Office of Sponsored Research Services.

If you believe you need to disclose Other Support or a Foreign Component retroactively, please contact the Conflict of Interest (COI) Officer. If you, the COI Officer, and the Office of Research (OoR) determine that there is something to report, you will work with OoR to submit the retroactive disclosure to NIH.

If you wish to accept the invitation, you should talk with your Division/Department Chair or supervisor to decide whether it would be acceptable and receive approval prior to accepting. If you proceed with the engagement, several disclosures may be required to both UC and NIH. Your outside activity report (OAR) will need to be updated within 30 days of change to your professional and/or scholarly activities.

Collaborations, whether foreign or domestic, that result in the availability of resources for your research, as evidenced by the generation of a manuscript, are reportable as Other or In-Kind support. Updates to expired awards are not required. For active NIH awards, if this collaboration was anticipated at the time of proposal, the In-Kind support should have been disclosed during Just in Time, before funding. If the collaboration arose after the start of the award, you should report foreign and domestic collaborators at the next opportunity to report (usually the next annual progress report, RPPR). Starting January 25, 2022, you must disclose foreign and domestic collaborators immediately after discovery if something wasn't reported at the first opportunity to report it (e.g., proposal, JIT, progress report).

Contact the Conflict of Interest (COI) Officer for assistance in reporting items that you believe should have been reported earlier.

As a rule of thumb regarding disclosure of collaborations, look toward publication. If a foreign or domestic collaboration results in a publication where you might acknowledge or confer authorship to your collaborator, it is likely a relationship that rises to the level of other or in-kind support for your research and must be reported to NIH. Foreign collaborators performing experiments in a foreign country on an NIH-funded award may be a Foreign Component that requires prior approval from NIH.

If you have an appointment with the collaborator's institution, you should report that appointment or those activities as a commitment in the outside activity report (OAR). This collaboration should be reported as a foreign collaboration and In-Kind support. If this collaborator contributes directly to an NIH-funded project, it would likely be considered a Foreign Component, which requires prior NIH approval.

In-Kind Contribution

For unique items such as these, you should estimate the value based on the cost of comparable reagents from a supplier. If there is no information available about the cost of similar items, you should state, “No market value available.” Note that if the samples will be used for the project being proposed, they should be listed under Facilities and Other Resources.

If this person will be self-funded, through their home institution or otherwise, you need to disclose them as an “in- kind contribution,” including information about the source(s) of funding that may be supporting this person. As NIH has stated, “since the student or post-doc is performing research activities, the [person’s] work in the lab is a resource available in support of the PD/PI or other senior/key personnel’s research endeavors.”  You must also follow University requirements for visiting scholars (contact your department/college HR and International Office, if applicable).  If the visitor has an affiliation with sensitive, restricted or other high-risk university research at either their home institution or will have access to sensitive/high-risk research at UC, consult with the Director for Export Controls regarding possible additional compliance requirements.

It depends.

  1. If they are working on the project being proposed, they should be disclosed in the Facilities & Other Resources section of the proposal. If they worked on an active NIH-funded project at least one person month during a reporting period, they should be included as “Participants” in section D.1 of the RPPR, regardless of the source of the compensation.
  2. If they are working on other projects in the lab, you should include them in Other Support.
  3. If they are not contributing to your research at all, but they are simply observing, or working solely on their own projects, then you need not disclose them to NIH.

If the collaboration is “directly supporting your research endeavors,” it should be disclosed as “Other Support.” That would be the case if, for example, it results in co-authored publications.

In addition, in some instances, such a collaboration could be considered a “foreign component,” if the collaborator is contributing a significant scientific element to an NIH-supported project from a non-U.S. location (see definition of foreign component). In such cases, prior approval would be required. You should work with your SPA project officer on any prior approval requests.

It depends. If the collaborations will directly support your research endeavors, you should disclose them in Other Support, under In-Kind Contributions. This would be the case if, for example, you would include your collaborator as a co-author on a publication or as an investigator on a sponsored project. Similarly, if the collaboration involves provision of high-value materials, it should be disclosed like any other In-Kind Contribution.

If the collaborations do not directly support your research endeavors, then they do not need to be disclosed in Other Support.

If that student is not part of your group or contributing work to your research at UC, then this would not be considered In-Kind support on your NIH award. However, if you receive an appointment at the other university, this activity should be disclosed on your NIH Biosketch and to UC (OAR).

Omissions

You should contact your SPA project officer as soon as possible. They will work with you to submit updated information to NIH.

Other

Submit all newly required information at the time of proposal, and just in time, for new projects that will be funded. After award, update your Biosketch and Other Support information per the NIH RPPR instructions. See the post-award guidance page for more details. There is no need to update awards that have ended. If you discover that you did not report something from a period year, contact the COI Officer to determine whether a retroactive disclosure will need to be made. If so, the OoR will work with you to submit the disclosure to the agency.

Other Support

NIH Other Support includes all planned, pending, and current project support and in-kind support that is either provided directly to the individual, or through an organization in support of that individual's research endeavors, from whatever source, including but not limited to all sponsored agreements for research or educational activities that take place at UC or elsewhere, and outside consulting activities that involve performing research for other entities. See UC’s Other Support Questionnaire for more details.

Unless you plan to use the compensation to support research, it is not Other Support and need not be reported to NIH. If you are being appointed as an editor, you must include the position on your Biosketch. In any case, you must disclose your time commitment and the income in your OAR disclosure.

NIH states that its scientific program and grants management staff review Other Support information to ensure that:

  1. All resources, domestic or foreign, directly supporting the individual's research endeavors have been reported
  2. Sufficient levels of effort are committed to the project
  3. There is no scientific, budgetary, or commitment overlap
  4. Only funds necessary to the approved project are included in the award
  5. Any foreign resources that meet the definition of a Foreign Component have received appropriate prior approval.
Outside Activities

Service on advisory boards should be included as a “scientific appointment” on the Biosketch. However, it does not need to be disclosed as Other Support unless it involves the conduct of research.

Yes. You should err on the side of transparency and include consulting engagements that are relevant to your professional expertise under Scientific Appointments.

Consulting needs to be included in Other Support only where it “involves the conduct of research.” Consulting or professional service that does not involve the conduct of research does not need to be included in Other Support.

Consulting roles that involve the design, conduct or reporting of research may be considered to involve the “conduct of research.” These would include, for example, consulting roles that warrant co-authorship or result in joint publications. On the other hand, if the engagement is purely advisory, it should not be considered Other Support.

Consulting is typically an outside activity that is not part of an individual’s Total University Effort and does not require an effort commitment. For this reason, in most cases, you may provide an estimate of the number of days spent on consulting activity, with the following text: “This project is professional activity outside of my institution, as defined in the Uniform Guidance, 2 CFR § 200.430(c), and carried out in accordance with institutional policy on outside activities. I spend approximately _____ days per quarter/year on this outside activity.” However, if the consulting engagement includes an explicit commitment of person-months, you must disclose that commitment in person-months in your Other Support.

Projects (Active, Pending, and Completed)

Yes. Internal awards such as pilot grants, seed grants, or other internal awards to fund specific research projects must be included.

Prizes are typically awarded to an individual to recognize their overall accomplishments or achievements, and the funds are completely unrestricted. In contrast, a sponsored project has defined aims and objectives, and the funding must be expended in accordance with the project’s scope. If you have a question about whether a particular item can be excluded as a prize, please contact your SPA project officer.

You should disclose clinical trials in the same way as other projects. See also UC Effort Commitment Policy on Sponsored Projects 2.1.20.

Subawards

The non-U.S. investigators must follow the same rules as U.S. investigators. They do not need to disclose their employment agreements with the subaward recipient institution, but they must disclose any Other Support, including any appointments with additional entities that involve research or access to resources for research endeavors.