Agency Comparison Chart

The chart below is a summary comparing agency-specific guidance related to foreign influence and reporting obligations for key agencies that fund research activities at UC Berkeley.


Sponsor Who must disclose? What must be disclosed? When to disclose? Other
National Institutes of Health (NIH) All senior key personnel devoting any measurable effort to the project Other Support: Resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not the resources have monetary value. Disclosures should occur at the JIT stage and up to the time of award.
Also, any changes in active other support should be reported when submitting RPPRs.
Supporting documentation for all foreign activities and resources that are reported by Senior/Key Personnel under “Other Support,” must be included with Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs) submitted by NIH PIs on or after January 25, 2022. However, NIH PIs may be asked to provide these documents for all Senior/Key Personnel prior to this date, if necessary.

This means that NIH may require copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts, grants or other agreements are not in English, recipients must provide translated copies. See the FAQs provided by NIH for further guidance.

PIs or other Senior/Key personnel on an active NIH grant that fail to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, should notify SPO as soon as it becomes known.
  Foreign Components: Any significant scientific element or segment of the project will take place outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. If a foreign component is to be involved, the PI must attach a justification to the proposal describing why the facilities or other aspects of the proposed project are more appropriate than a domestic setting.
If the PI adds a foreign component after NIH makes the award, NIH prior approval will be required.
NIH does not define what is meant by “significant.” NIH has provided the following examples of a reportable foreign component:
  • 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
National Science Foundation (NSF) All senior project personnel See the NSF Policy Office NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support table. At the proposal stage, in project reports identify new support, and at the post-award stage if not disclosed at proposal submission. Detailed information about the content is available in the Proposal and Award Policies and Procedures Guide (PAPPG), Chapter, II.C.2.h.
Department of Defense (DOD) Persons identified as key personnel in the Senior/Key Person Profile (Expanded) form whether or not the individuals’ efforts under the project are to be funded by DOD.
  • A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
  • Title and objectives of the other research projects.
  • The percentage per year to be devoted to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.
Only in response to DOD Notices of Funding Opportunities (NFOs) pertaining to research and research-related educational activities. Always check the program solicitation and direct any questions to the SPO CGO assigned to your unit.
Department of Energy (DOE):
Financial Assistance Awards (Grants and Cooperative Agreements)
The PI and each senior/key person at the prime applicant and any proposed subawardees regardless of funding source. In addition to all Foreign Government Talent Recruitment Program (FGTRP) involvement, provide a list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; full-time, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. Provide the Current and Pending Support as an appendix to the proposal’s project narrative.

See: FY 2021 Continuation of Solicitation for the Office of Science Financial Assistance Program.
DOE requires the use of the format approved by the NSF, which may be generated by the Science Experts Network Curriculum Vita (SciENcv), a cooperative venture maintained by NIH at SciENcv and is also available at a fillable PDF from NSF.
DOE:
Contracts
DOE employees and contractor personnel (including individuals on DOE-sponsored programs at the University if they go on to a DOE site.) Participation in a Foreign Government Talent Recruitment Program (FGTRP) regardless of where the work is performed. Applies when:
  • An FGTRP  clause is included in the DOE agreement
  • Work is R&D
  • Work will be performed or partially performed on or at a DOE or National Nuclear Security Administration (NNSA) site or facility.
Definition of a FGTRP: An effort directly or indirectly organized, managed, or funded by a foreign government to recruit science and technology professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position).
Foreign Countries at Risk currently include: Russia, China, Iran, and North Korea.

When Order 486.1A is referenced in LBNL or other DOE Lab agreements, SPO will send an email to the PI with a link to a Foreign Government Talent Recruitment Program (FGTRP) Certification form. The PI and each member of the PI’s project team must complete this form.
DOE:
Foreign National Access Requirement (Applies to Contracts and Financial Assistance Awards)
Any foreign nationals working on the project who have access to DOE sites, information and technologies. Depends on the terms of the award. Some awards, mainly grants, indicate DOE may ask for information about foreign nationals, but does not require submitting information about foreign nationals prior to performing on the project. Other awards, including Cooperative Agreements and DOE Lab agreements, may require forms be completed by each foreign national for submission and review by DOE prior the foreign national performing on the project. SPO will inform the PI when disclosure of foreign national information is required. Do not submit foreign national information without contacting SPO. The submission of any personal information requires review to ensure it is within UC policy. Proposal stage:

PIs are advised to include a statement in the Scope of Work indicating that the proposed project will be “fundamental research.”

Award Stage:

PIs/Chairs may be asked to sign an an informed consent or informed participation agreement depending on the foreign national access terms in the agreement.

SPO should be notified if the PI or research team receives a request for citizenship or nationality information from DOE/DOE Lab.

Note: UCB may need to decline or terminate an award if DOE does not approve a foreign national’s participation on the project.
National Aeronautics and Space Administration (NASA)

(See NASA Proposer’s Guidebook)
PIs and Co-PIs and Co-Is proposing to spend 10% or more of their time to the proposed effort Not required for Co-Is at non-U.S. institutions and typically not required for students. Ongoing and pending projects and proposals (regardless of salary support) in which the individual is performing or will perform any part of the work. (See description on the website for the details.

Current and pending support with Chinese universities and other similar institutions or a Chinese-owned company at the prime recipient level and at all subrecipient levels, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.

The current proposal does not need to be listed unless submitted to another funding opportunity (NASA or another sponsor).

For reportable actions include:
  • Title of funded project or proposal title;
    Name of PI on award or proposal;
  • Program name (if appropriate) and sponsoring agency or organization, including a point of contact with their telephone number and email address;
  • Performance period;
    Total amount received by that investigator (including indirect costs) or the amount per year if uniform (e.g., $50 k/year); and
  • Time commitment by the investigator for each year of the period of performance.
For all non-contract proposals. The proposing PI must notify the NASA Program Officer identified for the FA immediately of any successful proposals that are awarded for substantially the same research as proposed to NASA, any time after the proposal due date and until the time that NASA’s selections are announced.

Note that NASA may have other requirements depending on the type of proposal/award. Always read the solicitation carefully.

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