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You may need to update Other Support and M-Inform
If you have not yet done so, you need to disclose the foreign talent recruitment program, appointment/affiliation, and/or monetary resource (2.a.b.c. above) in M-Inform and in sponsors’ Current and Pending / Other Support documentation, if applicable.
Questions 2a - 2d of the Sign PAF and Sign Award Record activities in the eResearch Proposal Management (eRPM) system address the project's international engagements.
The Sign PAF and Sign Award Record activities include questions regarding international engagements. As stated there, "The full and transparent disclosure of your international engagement is critical, especially as it relates to: (i) participation in a foreign government talent recruitment program, (ii) holding an appointment or affiliation with a foreign entity/institution, and (iii) receiving resources from a foreign entity that support or are related to any of your research endeavors."
Staff in ORSP and the Conflict of Interest (COI) offices are conducting a pilot project to use the information provided by investigators in the eRPM "Sign PAF" activity to complete a congruence review with sponsor-required documentation such as "Other Support" and "Current & Pending Resources."
How to answer questions 2a - 2d in eRPM
Below are the international engagement questions that appear in the eRPM "Sign PAF" and "Sign Award Record" activities, along with some guidance you may find useful when answering these questions.
In general, the information entered in the eRPM "Sign PAF" and "Sign Award Record" activities should also be included in your Current & Pending Support or Other Support documentation for the sponsor and in your M-Inform disclosure (questions 2a-2c only).
2a. Do you participate in a foreign/international talent recruitment program?
The White House Office of Science & Technology Policy (OSTP) states:
A foreign government-sponsored talent recruitment program is 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).
- Many countries sponsor talent recruitment programs for legitimate purposes of attracting researchers in targeted fields
- Many programs utilize legitimate means of attracting talent, including offering research fellowships and grants to incentivize researchers to physically relocate
- However, some programs encourage or direct unethical and criminal behaviors
- Contracts for participation in some programs, including some sponsored by the Chinese government, include language that creates conflicts of commitment and/or conflicts of interest for researchers
- Requirements to attribute awards, patents, and projects to the foreign institution, even if conducted under U.S. funding
- Requirements to recruit or train other talent recruitment plan members, circumventing merit-based processes
- Requirements to replicate or transfer U.S.-funded work in another country.
Transparency and full disclosure are essential to properly assess risks.
2b. Do you have an appointment, affiliation, or other relationship outside the U-M with a foreign entity/institution?
Per the NIH, in their Other Support documentation applicants must list all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
In completion of the Biosketch, NSF requires applicants to list "all the individual's academic, professional, or institutional appointments, beginning with the current appointment." With regard to professional appointments, senior personnel must identify all current domestic or foreign professional appointments outside of the individual's academic, professional, or institutional appointments at the proposing organization.
2c. Has a foreign entity provided to you any monetary resources that support or are related to your research endeavors (with the exception of grants, contracts, or gifts awarded/given to U-M)?
When reporting monetary resources in "Other Support," NIH requires that applicants include "all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual's research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts do not need to be included."
When reporting "Current & Pending Support," NSF requires applicants to include "all resources made available to an individual in support of and/or related to all of his/her research efforts."
When answering question 2c in the "Sign PAF" activity, U-M Investigators do not need to include grants, contracts, or gifts awarded/given to U-M.
2d. Has a foreign entity provided to you any non-monetary resources (e.g., equipment, materials, personnel) that support or are related to your research endeavors (with the exception of non-monetary resources arranged through U-M as Unfunded Agreements (UFAs) e.g., material transfer agreements, data use agreements)
NIH states that, when providing "Other Support" information (usually during the "Just In Time" (JIT) process) investigators must include "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 resource 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.).
When providing "Current & Pending Support" information, NSF requires investigators to include "all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students. In-kind contributions not intended for use on the project/proposal being proposed also must be reported."
When answering question 2d in the "Sign PAF" activity, U-M Investigators do not need to include non-monetary resources arranged through U-M as Unfunded Agreements (e.g., material transfer agreements, data use agreements) or resources acquired through U-M Procurement processes (e.g,. purchase order).