Faculty Disclosure and Reporting Guidance

A “foreign component” is the performance of a significant scientific element of the National Institutes of Health-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.

See the frequently asked questions (FAQs) for foreign components on the NIH site. 

Some examples of activities that may be considered a significant element of the project include, but are not limited to: 

• 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

Disclosure Requirements

• Grant proposal
• Progress and final reports to the funding agency
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page.
• The CWRU Outside Interests Disclosure Form. The Conflict of Interests (COI) Office can assist with creating an individual’s form. Contact the office at cwrucoi@case.edu.
• DOD, DOE and NASA require the disclosure of all activities outside the United States or partnerships with international collaborators. Please contact resadm@case.edu for more information about this requirement if you are submitting to or are funded by these agencies. 

Paid or unpaid academic, professional, or institutional appointment with or without an expectation to teach/lecture with a foreign or domestic entity that is full-time, part-time, visiting, adjunct, honorary or voluntary. 

Approval Requirements

• Per the CWRU Faculty Handbook, prior approval is required by the provost. Faculty should start by submitting a request to the faculty member's chair or dean. See Section III. G. Non-University Activities of Faculty Members During the Contractual Period. Faculty members may not hold appointments in another institution without a written approval in advance by the provost: request for approval should be directed to the faculty member's department chair or, in a school without departments, the dean (or designee of the chair or dean).

Disclosure Requirements

• The CWRU Outside Interests Disclosure form is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Biographical Sketch in Section B "Positions, Scientific Appointments and Honors. The NIH requirement is effective for all proposals submitted after 5/25/2021. Please see below for more detail regarding the implementation of this policy.
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page.
• NSF Biographical Sketch
• NSF Current and Pending Support
• DOD Other Support DOD per Memorandum from Defense Undersecretary March 20, 2019. 
• NASA, DOD, and DOE Bioskecthes or CVs submitted with proposals
• CV
• Annual Faculty Review

Payments or in-kind support for your research from a domestic or foreign entity that is not provided through an agreement between the domestic or foreign entity and CWRU.

Type of In-Kind Support 

• For more information see NIH Other Support and Foreign Component FAQs. 
• In-kind lab or office space (this is space that is provided to you by entities other than CWRU, UH, VA, CCLCM, or Metro that are related to or support your research).
• Any visiting faculty, scholars, students (graduate, undergraduate, and high school), post-docs, or scientists supported from outside CWRU who are participating in your research projects. 
• Technology, chemicals, etc. intended for use on the project being proposed to NIH (such as reagent).
• Contributions not intended for use on the project being proposed.
• Materials and resources uniquely available and received from collaborators including the source, a summary of the in-kind contribution, and the estimated value.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Other Support (OS) NOT-OD-21-073.
• Resources and Environment Section of NIH applications. The information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated on OS. 
• Facilities, Equipment, and Other Resources for NSF applications: Project or in-kind contributions without a time commitment that are intended for use with the project/proposal being proposed must be included.
• CV
• Annual Faculty Review

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Other Support NOT-OD-21-073.
• Annual Faculty Review

Advisory or board position with a domestic or foreign entity that is either paid or unpaid.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• Annual Faculty Review
• CV

Remuneration, regardless of amount, from a foreign institution of higher education, including any affiliated research institutions, foreign academic teaching hospital or medical center, the government of a foreign country, or a foreign company.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Other Support NOT-OD-21-073.
• CV
• Annual Faculty Review

A program organized, managed, funded, or supported by a foreign government or institution to recruit scientists, engineers, or researchers to facilitate the acquisition or transfer of knowledge. 

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Biographical Sketch in Section B "Positions, Scientific Appointments and Honors. 
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page.
• NSF Biographical Sketch
• NSF Current and Pending Support
• Other Support DOD per Memorandum from Defense Undersecretary March 20, 2019.
• Other funding agencies may also have disclosure requirements.
• CV
• Annual Faculty Review

Resources and/or financial support from all foreign and domestic entities that are available to the faculty/researcher for work and research that are not listed above.

Examples of types of support

• Financial support for laboratory personnel (supported at CWRU or located in another country)
• Provision of high-value materials that are not freely available (e.g., biologics, chemicals, model systems, technology, etc.)

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page.
• Resources and environment section of NIH applications. The information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated on Other Support. 
• NSF Current and Pending: Support only for contributions with a time commitment.
• Facilities, Equipment, and Other Resources for NSF applications: Project or in-kind contributions *without a time commitment* that are intended for use with the project/proposal being proposed must be included.
• Annual Faculty Review
• CV

A prize or training award is recognition based upon competition or other criteria can be monetary or non-monetary.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• CV
• Annual Faculty Review

Grants and contracts received from any entity (direct and pass-through included, Federal, non-Federal, and foreign) that are awarded to CWRU

Disclosure Requirements

• NIH Biographical Sketch in Section A "Personal Statement.” Only include projects recently completed and ongoing that you want to bring attention to.
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page. 
• NSF Biographical Sketch 
• NSF Current and Pending Support
• DOD Other Support DOD per Memorandum from Defense Undersecretary March 20, 2019.
• Other funding agencies may also have disclosure requirements.
• CV
• Annual Faculty Review

Start-up funds received from entities other than CWRU.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page. 
• CV
• Annual Faculty Review

Research collaborators are those whose experiments have directly benefited the research being proposed or funded through CWRU.

Types of Collaborators

• Another scientist in the U.S. whose experiments have directly benefited the research being proposed or funded and the experiments were conducted with funds awarded to the collaborator's institution.
• Another scientist outside the U.S. whose experiments have directly benefited the research being proposed or funded and the experiments were conducted with funds awarded to the collaborator's institution. 
• Unfunded research collaborations that do not have any direct funding (current or proposed) that may lead to publication. When faculty agree to collaborate on a defined project where each party is responsible for its own costs.

Disclosure Requirements

• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page. 
• NSF Current and Pending Support
• Annual Faculty Review

Summer research for a faculty member with a nine-month appointment who conducts research outside the United States under a foreign or domestic award either to CWRU or directly to the faculty member.

Example: An award from the National Endowment for the Arts (NEA) to the faculty for a research project outside the United States.

Disclosure Requirements

• NIH Other Support (OS) Page. NOT-OD-21-073 updated the requirements to include key personnel submitting OS pages are required to also submit copies of contracts, grants, or other agreements (appointment letters) or employment agreements as part of the OS page. 
• NSF Current and Pending Support
• Annual Faculty Review
• CV

Sponsored travel is travel that is paid for on behalf of the investigator/faculty and not reimbursed to the investigator so that exact monetary value may not be readily available.

Activities that may fall under this category: cultural exchange trips and panel discussions
Excluded from the disclosure requirement is travel that is reimbursed or sponsored by a United States federal, state or local government agency; United States institution of higher education; United States academic teaching hospital; United States medical center or United States research institute affiliated with an institution of higher education. As a result of this guidance, United States grant-funded travel is excluded from disclosure requirements. Travel that is reimbursed or sponsored by a foreign entity must be disclosed in all cases.

Disclosure Requirements

• CWRU Outside Interests Disclosure is due annually on April 1 for the previous year. Faculty are required to update their COI disclosure within 30 days of a change or additional reportable activity.
• Annual Faculty Review

Items that should be disclosed on your annual faculty summary CV:

• Collaborations that result in co-authorship based upon oral agreement with former trainees or other collaborators.
• Travel paid for by a sponsored project/award for travel related to the project.
• Honorarium for reviewing a grant proposal, when there is not a formal written agreement. If there is a formal written agreement then the interaction is not an honorarium and should be reported as part of a consulting agreement or formal appointment. 
• Journal editor, regardless if paid or unpaid and the location of the journal (If the journal is in Iran then the engagement must be reported to the Office of Compliance due to Export Control requirements).
• Committee service for domestic or international scientific societies (If the journal is in Iran then the engagement must be reported to the Office of Compliance due to Export Control requirements).
• Advising responsibilities that are part of an academic appointment at CWRU.
• Thesis/dissertation review for entities outside CWRU.
• Faculty/Start-Up or retention packages.

During the transition to the new Biosketch format, NIH will not withdraw applications that include the previous Biosketch format. Beginning with applications submitted on or after Jan. 25, 2022, failure to follow the appropriate Biosketch format may cause NIH to withdraw your application form consideration.

• NASA has additional guidance on restrictions on funding activities in China with prior approval requirements for Chinese nationals working on a project.
• DOE requires two additional certifications for Foreign Government Talent Recruitment Programs (FGTRP's) or Other Foreign Government Sponsors or Affiliated Activities (FGSAA). 
• DOD and DOE require the reporting of all activities.