The University of Tennessee encourages international collaborations, but it is important for our investigators to be transparent about their foreign relationships and activities.  The University of Tennessee’s Office of Research has compiled the following information to provide guidance and resources to assist University of Tennessee researchers in meeting their compliance obligations to federal sponsors.


Why is this Important?

It protects everyone’s interests – individual researchers, their international collaborators, the University of Tennessee, and the Federal government – to have international relationships disclosed and vetted to determine if there are any potential conflicts of commitment, duplications of research, and/or diversion of intellectual property in the performance of federally funded research.

In extreme cases, failure to disclose all relationships could result in the termination of funding for a project and potential ineligibility for future funding or other disciplinary actions. Noncompliance can also threaten not only the funding for individual projects, but overall funding for the University.


Background Information

The U.S. Government has expressed concerns regarding inappropriate influence by foreign entities over federally funded research (see below).  One of the major issues is the failure of federally-funded researchers at U.S. institutions to disclose their relationships and activities with foreign institutions and funding agencies. To address this concern several Federal agencies have added new requirements or clarified existing requirements for their programs.

  1. The National Science Foundation issued a Dear Colleague Letter on July 11, 2019, outlining its plans to “address emerging risks to the nation’s science and engineering enterprise.”
  2. The Department of Energy issued a directive dated June 7, 2019, mandating that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs” on new DOE contracts and subcontracts. DOE managed laboratories have also added this requirement into projects that university personnel will be working on in the DOE facilities.
  3. The National Institutes of Health (NIH) issued a Notice on July 10, 2019, reminding research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap” (NOT-OD-19-114). 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.” An FAQ can be found here.
  4. The National Defense Authorization Act, signed in August 2018, included Sec. 1286, which stated that “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities . . . to limit undue influence, including through foreign talent programs, by countries to exploit United State Technology … ”
  5. The Department of Defense (DoD) issued a memo on March 20, 2019, outlining disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements. A second memo issued on October 10, 2019, providing additional updates on the DoD’s efforts to address this issue.
  6. As a reminder, NASA has long-standing restrictions on using NASA funds to enter into agreements “to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement” which are detailed in the grant restrictions or contract restrictions.


Recommendations for Disclosing Foreign Relationships and Activities

While most international collaborations are perfectly acceptable and encouraged, we urge researchers to be transparent about their activities.  The items below contain guidance regarding the types of relationships and activities that University of Tennessee researchers are expected to disclose:

  1. University of Tennessee researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors.  “Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through the University of Tennessee, through another institution, or provided directly to the researcher himself or herself. It is ultimately the responsibility of the individual researcher to ensure that the report of Other Support is complete and accurate to the best of his or her knowledge.

    An issue that is garnering a great deal of scrutiny by the federal government is participation in foreign talent programs. Not only should participation in a foreign talent programbe disclosed to federal sponsors, University of Tennessee researchers are required per the Faculty Handbook to report in writing to their immediate supervisor any potential conflicts of interest between their University duties and responsibilities and their outside interests.

  2. Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports. Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

    Listed below are some ways in which foreign components should be disclosed in applications and progress reports:

    • Identifying a foreign component in an application;
    • Listing a non-U.S. performance site;
    • Identifying foreign relationships and activities in a biosketch;
    • Checking “yes” to the question on the federal grant application form asking “Does this project involve activities outside of the United States or partnerships with international collaborators?”


  3. Significant financial interests received from any foreign entity, including governments and universities, must be disclosed, per University of Tennessee policy FI0125.  Additionally, all foreign consulting and other outside business activities are also required to be disclosed.