UF MainSpring Seminar: International Activities – Hot Topics and Best Practices

The expectations related to disclosure and participation in international activities are changing rapidly. In this forum held May 11, speakers discussed all facets of international activities including international collaborations, outside activities, and sponsored research. They provided tips for building and nurturing international collaboration while ensuring compliance with UF and sponsor policies, regulations, and expectations. A summary of the workshop is provided below.

1. International Activities and Collaborations
2. Disclosure of Outside Activities and Conflicts of Interest
3. Federal Sponsor Updates

 

1. International Activities and Collaborations

• Federal agencies have significant concerns about foreign entities’ attempts to improperly influence U.S. researchers, which may lead to:
  • Diversion of intellectual property produced by U.S.-funded research
  • Leaking of confidential research information
  • Failure of U.S.-based researchers to disclose resources they receive from, and relationships they have with, foreign entities

International Risk Assessment

• Inputs
  • UFIRST Agreements
  • UFIC Agreements
  • UFOLIO
• Process
  • Administered by UFRI with input from other core offices as needed
  • Likely invisible to you and other offices
  • Key to an effective and efficient review is complete information
• Considerations
  • Occur in a comprehensively sanctioned country?
  • Occur in a country that has a Department of State Level 4 travel warning?
  • Involve Restricted Parties?
  • Include travel for one or more months/year?
  • Have other high risk factors?

2. Disclosure of Outside Activities and Conflicts of Interest

Conflicts of Interest

• What is a conflict of interest?
  • As defined by Florida law, a conflict of interest is a situation in which regard for a private interest tends to lead to disregard of a public duty or interest.
• What is an outside activity?
  • Those activities that draw upon the knowledge, skills, or abilities employees use to fulfill institutional responsibilities and are performed for outside entities. Examples include consulting, external employment, expert witness services, etc.
• Why does it matter?
  • University of Florida employees are subject to a variety of laws, regulations, and policies which require reporting and management of conflicts of interest and disclosures of outside activities and interests. These include UF Regulation 1.011, UF’s Policy on Conflicts of Commitment and Conflicts of Interest, and the Florida Code of Ethics for Public Officers and Employees, among others.

New Disclosure Process

• UFOLIO replaces outdated procedures and routing processes to save time and provide a more intuitive platform for compliance with federal, state, and university disclosure laws and rules. The UFOLIO system makes reporting easy by identifying if a disclosure is necessary via a survey of 11 questions.
• Disclosures submitted in UFOLIO are approved by the discloser’s supervisor and the UF Conflicts of Interest Program and may be routed to subject matter experts for “ancillary” review as well.
• All other employees are to continue disclosing activities and interests to their supervisors outside of the UFOLIO system and will be notified in the future of any process changes.

What If I Don’t Disclose?

• Under the university’s policy, failure to disclose or failure to truthfully and completely disclose can result in disciplinary action up to and including termination of employment.
• Additionally, in March 2020 Florida lawmakers proposed legislation that is expected to implement severe penalties for failure to disclose certain activities and interests.
• It is important that you protect yourself by disclosing your activities for approval prior to engaging in them.

3. Federal Sponsor Updates

Disclosing to Federal Sponsors

• Current & Pending Support / Other Support Sections Must Include
  • Grants or contracts, whether provided through UF, another institution, or directly to the PI
  • All research resources, even in-kind, including:
    • Foreign financial support
    • Research or lab personnel
    • Lab space, scientific materials and supplies, etc.
    • Travel or living expenses received in connection with travel for research efforts
  • Selection to a foreign talent or similar recruitment program
• Key Personnel must submit complete biosketch/CVs that include
  • All positions and scientific appointments, both domestic and foreign (e.g., titled academic, professional, or institutional appointments)
  • Affiliations with foreign entities or governments
  • The above whether or not remuneration is received and whether full-time, part-time, whether voluntary, adjunct, visiting, or honorary
    

NSF UPDATE: Must use NSF approved form.  See: https://research.ufl.edu/dsp/proposals/nsf-updates.html

• International Activities / Foreign Component
  • Work on this particular grant conducted in a foreign location
  • Can be work done by PI, key personnel, or others, either affiliated with UF or not
  • Does not matter if federal grant money is expended or not
  • Indicators
    • International Collaborators
    • Use of foreign facilities
    • Receipt of financial support or resources from foreign entity