USF Guidance on Disclosing Foreign Relationships

How do I protect myself and my research?

USF already has policies and procedures in place to ensure you and your research are protected.

Outside Activity and Conflicts of Commitment

USF Compliance and Ethics Program (CEP) – This program coordinates and manages all USF compliance and ethics activities. The CEP provides assurance to the USF Board of Trustees that such activities are reasonably designed, implemented, enforced, and effective in preventing and detecting violations of law, regulations, and policies, as well as violations of ethical principles of conduct. They assist USF employees in meeting their nepotism, outside activity, and Florida Code of Ethics (FCOE) disclosure responsibilities under USF Policy 0-027 (PDF) and USF-UFF Collective Bargaining Agreement, Article 19 (PDF). These disclosures are made in eDisclose, with the exception of USF Health faculty who disclose their outside activities in ROAD (see below). For more information about nepotism, outside activity, and FCOE disclosure requirements, contact the CEP, 813-974-2705, or visit the CEP website.

USF Health Faculty

Faculty appointed in the Morsani College of Medicine, the Colleges of Nursing, Public Health and Pharmacy, or in any unit reporting directly the Senior Vice President of USF Health are obligated to disclose all activity outside of USF which provides them any form of compensation or financial interests (e.g., direct pay for services/consulting, reimbursement, travel expenses, or stock options; see USF Policy 0-027) or any non-compensated outside activity which may constitute a conflict of interest or commitment with their USF assignment. Disclosure obligations include not only activity involving domestic entities within the U.S., but also include foreign entities doing business within the U.S. Compensation is broadly defined by USF and, in addition to the examples given above, can include, but is not limited to: payments/travel reimbursements received from foreign academic or corporate institutions or foreign governments, or living expenses or stipends from such entities. Such disclosures are to be made in the ROAD system.

Research Related Significant Financial Interest (SFI) Disclosure

Remuneration received from and travel sponsored or reimbursed by foreign academic institutions and governments are not exempt from research COI reporting and must be disclosed. Federally funded Investigators must disclose new SFIs within 30 days of acquisition/discovery. SFIs may result from speaking, consulting and/or advising fees that exceed $5,000 in a 12-month period; ownership interests such a stock, stock options and entitlements to equity; intellectual property; serving on a board of directors or as a trustee (with or without compensation) and sponsored/reimbursed travel from non-exempt entities. USF Policy 0-309 (PDF) provides detailed information on what constitutes an SFI. All Investigators, regardless of funding source, must submit a project-specific disclosure via ARC for research related to an SFI prior to engaging in research or within 30 days of acquisition/discovery for ongoing studies. For additional information, including how to disclose reimbursed or sponsored travel, contact the COI Program or 813-974-5638 or visit the COI website.

International Collaborations

Export Controls

Export Controls involves regulations and laws governing the export of sensitive items used in research and other university activities—equipment, technology, and information—which can affect USF faculty, staff, and students in many ways. The Office of Export Controls is here to help you navigate any international collaboration. If you are planning to travel internationally or would like to engage in an international collaboration, please do not hesitate to reach out to this office for guidance. For additional information, please contact the Export Controls program or visit the Export Controls website.

USF World

USF World supports faculty and staff with information on the university's international partnerships, resources for international research, funding for global events on campus, Fulbright opportunities, and the Discovery Hub where you can connect across all USF campuses and access data on USF's global profile. For additional information, visit the USF World website.

Intellectual Property

All university employees must disclose inventions or other works to the Technology Transfer Office (TTO) according to this policy and procedures statement: Statement of Policy and Procedures for Inventions and Works -- USF Policy 0-300 and USF-UFF Collective Bargaining Agreement, Article 18 (PDF). Disclosure forms are available online. For questions and additional information, call 813-974-0994 or visit the TTO website.

Sponsored Research (Other Support)

Disclose all financial support or resources received from any foreign entity that supports active or proposed research projects for which key/senior personnel will provide effort or oversight. This includes all financial support or resources received from a legal entity outside the U.S. whether Federal, non-Federal, commercial or institutional. All key/senior personnel on a research project must provide a disclosure.

“Financial Support” that must be disclosed includes, but is not limited to:

  • Sponsored funding provided to the University of South Florida that supports the researcher’s USF activities;
  • Students, post-docs, or scholars working with the researcher here at the University of South Florida who are paid or supported (e.g., receive salary, a stipend, travel expenses, living expenses, etc.) directly from a foreign entity; and
  • Funding (e.g., salary, stipend, honorariums, etc.), expense reimbursements, travel or lodging costs provided directly to the researcher as a consultant, visiting scholar, lecturer, collaborator, or other non-USF activity or appointment, regardless of whether the activities were performed in the U.S. or abroad. For faculty on nine-month appointments, this includes support received for activities completed over the summer term.

The disclosure requirements include support researchers receive through USF (research grants, cooperative agreements, contracts, and/or institutional awards) or support provided directly to the researcher.

NIH Other Support

On all NIH applications, researchers must indicate whether the project includes a “foreign component”, and, if yes, provide a foreign justification document. A foreign component is defined as “the performance of a significant scientific element of the NIH-supported project outside of the United States. Once a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component.”

For NIH awards, all financial support or resources that support active or proposed research projects must be disclosed during the Just-in-Time process as Other Support or within the Research Performance Progress Reports submitted annually. 

  • Other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resources and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.). Other support does not include training awards, prizes, or gifts. Other support is required for all individuals designated in an application as senior/key personnel.
  • Prior to uploading any requested Just-in-Time information, Principal Investigators should work with their department’s Unit Research Administrator to gather all information. Submit all documents via email to the department’s Sponsored Research Administrator (PDF) for review. Once the department’s SRA has reviewed the provided documents, the PI or URA will upload all Just-in-Time information onto the eRA Commons system and notify the department’s SRA to then submit for NIH review. 

Researchers must include all activities—foreign and domestic—on their Biosketch (e.g., affiliations or appointments at another institution, whether or not remuneration is received, and whether full-time, part-time, or voluntary—including adjunct, visiting, or honorary).

Additionally, federal sponsors require disclosure of participation in foreign talent recruitment programs. Some affiliations or participation in foreign talent recruitment programs may also meet the definition of Other Support. If so, researchers should disclose the activity in the current and pending support section.

Additional NIH guidance:

 

NSF, DOE, DOD, and other non-NIH Federal Agencies Other Support

All financial support or resources that supports active or proposed research projects and all foreign activities must be disclosed in the Current & Pending Support section at the time of proposal submission. Current & Pending Support is required for all individuals designated as senior/key personnel. The department’s Sponsored Research Administrator (PDF) will review the proposal package as standard practice.

Researchers must include all activities—foreign and domestic—on their Biosketch (e.g., affiliations or appointments at another institution, whether or not remuneration is received, and whether full-time, part-time, or voluntary—including adjunct, visiting, or honorary).

Additionally, federal sponsors require disclosure of participation in foreign talent recruitment programs. Some affiliations or participation in foreign talent recruitment programs may also meet the definition of other support. If so, researchers should disclose the activity in the current and pending support section.

Additional NSF guidance: