UF Administrative Memo: Federal Agency Disclosure Requirements for Grant Supported Investigators – Disclosing Financial Support from Foreign Entities

January 3, 2019
FROM: David P. Norton, Vice President for Research
Joseph Glover, Provost and Senior Vice President for Academic Affairs

In recent months, U.S. federal agencies that support university research have emphasized the requirements for disclosure of other research support, specifically highlighting support from foreign entities. In particular, mandatory disclosure of other support, when requested in proposal submission or other agency requirements, must include any support received by the investigator from a foreign government, university, or other legal entity outside the U.S.

This disclosure requirement includes support the investigator receives through UF agreements (contracts or grants) or support provided directly to the individual as a consultant, visiting scholar, lecturer, or similar non-UF appointment. For faculty on nine-month appointments, this requirement includes applicable funds received from a non-UF entity for activities over the summer term.

Whenever engaging in research or scholarly activities, please comply with the following UF regulations and policies:

• When applying for federal awards, appropriately disclose all current and pending support, including U.S. and all foreign sources of funding.

https://grants.nih.gov/grants/forms/othersupport.htm

https://www.nsf.gov/pubs/policydocs/pappg18_1/index.jsp

• All University employees must disclose all outside activities, via the Outside Activities and Financial Interests form. All approval for outside activities must occur in advance of the activity.

http://aa.ufl.edu/media/aaufledu/forms/OAA-GA-L-267-Disclosure-of-Outside-Activities-Out-of-Unit.pdf

• Comply with U.S. export control regulations in all domestic and international activities. Additionally, obtain Division of Research Compliance and Global Support approval prior to hosting visitors, entering into contracts, or engaging in activities with an entity or individual listed on any U.S. government restricted party list.

• Promptly report all inventions and intellectual property to UF Innovate.

• Follow all international travel guidelines, including travel registration with the UF International Center and UF Asset Management approval for foreign travel with UF equipment.

https://internationalcenter.ufl.edu/travel

https://internationalcenter.ufl.edu/travel/online-travel-registration

The University of Florida supports and encourages international research, collaboration, and scholarship.  Our faculty, staff, and graduate students conduct research in over 100 countries, host students and collaborators from all over the globe, and contribute to the research mission of the University of Florida. Such activities enhance the effectiveness and reach of our university, but also come with additional responsibilities.

Thank you for your help in ensuring compliance with all UF and federal policies.

If you have any questions that pertain to sponsored research policy and procedure, please contact Stephanie Gray, Director of Division of Sponsored Programs (slgray@ufl.edu), or Terra DuBois, Director of Research Compliance and Global Support (tdubois@ufl.edu).

If you have questions that are pertinent to the topic but are confined to non-research academic activities, please contact Chris Hass, Associate Provost for Academic and Faculty Affairs (cjhass@aa.ufl.edu).

NOTE: This and other Administrative Memos are maintained at http://administrativememo.ufl.edu