The University of Missouri-St. Louis values international collaborations and recognizes that such collaborations are integral to fulfilling our mission as a public, land-grant university, but it is important that UMSL investigators be open and fully transparent about their foreign relationships and activities. UMSL's Office of Research(ORA) has compiled the following information to provide guidance and resources for our researchers, and to remind them of their reporting obligations to federal sponsors and to UMSL.
The U.S. Government has expressed concerns about the failure of researchers to disclose their relationships and activities with foreign institutions and foreign funding agencies to their research sponsors and/or to their own institutions. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize an investigator’s or an institution’s eligibility for future funding.
In response, the DoD has announced that key personnel supported by DoD sponsored research and research-related educational activities will be required to disclose information about all sources of their research support, regardless of whether those individuals’ efforts are to be funded by the DoD. The memo specifies that the information to be collected will be “used to support protection of intellectual property…[and]limit undue influence, including foreign talent programs, by countries that desire to exploit United States' technology.”
The requirement to disclose all sources of research support has always been a part of the sponsored research enterprise; requests for full and open disclosures are not new mandates being implemented by research sponsors. Instead, sponsors are looking to reduce the discrepancies they have noted in some researchers’ disclosures of affiliations and funding.
UMSL supports and encourages most international collaborations but also recognizes that Federal sponsors have legitimate concerns about protecting U.S. government (taxpayer funded) research and development activities such as those performed at UMSL.
The items below contain guidance regarding the types of relationships and activities that researchers are expected to disclose to their sponsors and/or to the University. Additional information about relevant University of Missouri - St. Louis policies and NIH and NSF requirements is provided in the resources section below. Other federal agencies may have other, specific reporting requirements.
Other sponsors may have similar requirements to disclose foreign components.
There are multiple ways in which foreign components can be disclosed, e.g.,
In addition, NSF requires the disclosure of Collaborators and Other Affiliations (COA) in order to collect information about certain types of relationships and collaborations for each individual in a proposal identified by name as "senior project personnel." The information required in the COA tables includes organizational affiliations for the previous 12 months and all co-authors and research collaborators for the previous 48 months.
Most federal sponsors will have their own guidance on how to complete their forms. It is ultimately the responsibility of the individual researcher to ensure that all proposal forms, progress reports, and other documents submitted to a sponsor are complete and accurate to the best of his or her knowledge.
Those researchers who submit grant proposals to, or receive research or other sponsored funding from, federal agencies such as the NIH and NSF should review and update their relevant documents and disclosures as needed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Adminstration to have the error corrected. The addition of a foreign component to an existing grant award should be reported to the Office of Research Administration to obtain the federal agency prior approval. The PI should submit their request for prior approval to the Office of Research Administration to obtain agency approval prior to the engagement of the new entity.
The definition from CHIPS and Science Act of 2022 is: The term ‘‘malign foreign talent recruitment program’’ means:
The Office of Science and Technology Policy has provided additional guidelines on Malign Foreign Talent Recruitment Programs in the Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs.
Participation in a Malign Foreign Talent Recruitment Program is prohibited by the University of Missouri-St.Louis. For more information please visit: https://www.umsystem.edu/ums/rules/collected_rules/personnel/ch330/330.120-malign-foreign-talent-recruitment-program.
If you are unsure whether an external activity constitutes an outside interest that meets the threshold for required disclosure, please contact the Conflict of Interest Office at coioffice@umsl.edu. Disclosures of outside interests can be made by logging into the eCompliance system.
