Transparency Requirements
Anyone applying for or in receipt of a US Institutes for Health (NIH) grant must be wholly transparent about financial and in-kind support from, and affiliations with, international institutions. There have been successful prosecutions in the U.S. of federally funded academics; the need for full transparency IS legally enforced.
Full details of the requirement for transparency at the time of grant application and thereafter are available at https://grants.nih.gov/policy/protecting-innovation.htm and https://grants.nih.gov/grants/oer.htm.
Please note that in the context of NIH funding 'international' institutions are institutions outside the United States of America, i.e. including EU and UK institutions.
Examples of what to disclose to NIH on Applications and Awards
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Type of Activity |
Report in Biosketch / Application |
Report as Foreign Component in Application |
Obtain Prior Approval and Report as Foreign Component in Progress Report (RPPR) |
Report as Other Support (Just-in-Time procedures) |
Report as Other Support (RPPR) |
Review for potential Foreign Conflicts of Interest (FCOI) |
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All positions and affiliations, including volunteer positions, relevant to the application |
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If personal payments to the individual |
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Relevant appointments at foreign institutions – even if labelled as “guest,” “adjunct,” “honorary,” with or without salary support |
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If personal payments to the individual |
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The number of person-months devoted to projects, even if there is no salary support or direct personal payments to the scientist |
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If new |
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Income, salary, consulting fees, and honoraria in support of an individual's research endeavours |
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If new |
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Participation in a foreign talent or similar-type programs |
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If new |
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Ongoing and completed research projects from the past three years that the applicant wishes to highlight |
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All resources and other support, both domestic and foreign, for ongoing research projects, including those conducted at a different institution |
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If new |
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In-kind contributions from domestic and foreign institutions or governments that support research activities |
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Performance of any significant part of an NIH project outside of the US, whether or not funds are expended |
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If new |
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Post-doc, student, or visiting scholar supported by a foreign government or institution |
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If new |
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Travel paid by a foreign institution or government over $5,000 per year |
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Financial interests received from a foreign Institution of higher education or a foreign government |
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