International Relationships and Activities

Disclosure Requirement:

UT HOP 5-2011

Who Must Disclose:

• All 12 & 9 month faculty
• Full time professional and administrative employees
• Part time faculty/staff only if the activity reasonably appears to create a conflict of interest

What to Disclose:

Disclose and seek approval in advance for any of the following:

• All outside employment or other compensated activities;
• All outside teaching related to the discipline taught at UT;
• All service on outside boards (see exceptions below);
• Any uncompensated activity that reasonably appears to create a conflict of interest or conflict of commitment, such as:
  • Any substantial interest in a business entity
    • Controlling interest
    • >$5,000 ownership interest
    • >10% equity interest
    • Service as an officer
  • Any gifts >$250 to you or immediate family
  • Any activity of immediate family related to your responsibilities at UT

Exceptions to disclosure requirements (these should be reported to your department chair through the annual performance evaluation process):

• Serving on a federal, state, or local government agency committee, panel, or commission;
• Acting in an editorial capacity for a professional journal;
• Reviewing journal or book manuscripts, or grant or contract proposals;
• Attending and presenting talks at scholarly colloquia and conferences;
• Developing scholarly communication even when resulting in financial gain;
• Serving as a committee member, an officer, or board member of a professional or scholarly society.

When to Disclose:

Annually and within 30 days of a change

Where to Disclose:

Disclose in UT Systems Portal.

Disclosure Requirement:

HOP 7-1210

Who Must Disclose:

• Anyone involved in research who is a Covered Individual
• Covered Individual: any individual, regardless of title or position, who is independently responsible for the design, conduct, reporting, review, or oversight of research including a PI, co-investigator, or project director

What to Disclose:

Disclose any of the following for the prior 12-month period of time:

1. Compensated activities including:
   • Payment(s) from or equity interest in a publicly traded entity that in aggregate are >$5,000
   • Payment(s) from a non-publicly traded entity that in aggregate are >$5,000
   • Any equity interest ($0 minimum) in a non-publicly traded entity
2. Intellectual Property rights or Royalty payments
3. Travel or reimbursement for travel paid for by an entity other than UT
4. Gifts from a single entity that in aggregate are >$250
5. Any compensated position in a for-profit or nonprofit entity:
   • Board member
   • Officer
   • Advisor
   • Executive / management position

When to Disclose:

Annually and within 30 days of a change

Where to Disclose:

Disclose in the Financial Interest Disclosure system.

Disclosure Requirement:

Travel Authorizations

Who Must Disclose:

All travelers when traveling for business during the normal working period

What to Disclose:

Complete a Request for Travel Authorization (RTA)

When to Disclose:

Prior to start of travel

Where to Disclose:

• Typically, a Departmental or Unit process or complete an electronic VE5 document in DEFINE.
• Approval granted by Supervisor.

Disclosure Requirement:

• Travel Authorizations
• International Travel to Restricted Regions

Who Must Disclose:

All travelers when traveling for business during the normal working period

What to Disclose:

Complete a Request for Travel Authorization (RTA)

When to Disclose:

Prior to start of travel

Where to Disclose:

• Typically, a Departmental or Unit process or complete an electronic VE5 document in DEFINE.
• Approval granted by Supervisor.
• Some foreign destinations are considered restricted regions and travel must be approved by the UT International Oversight Committee.
• Foreign travel to be paid by a research sponsor must be pre-approved by the sponsor.

Disclosure Requirement:

UT Export Control website

Who Must Disclose:

Export Control regulations can apply whenever:

• To any research involving a restricted or classified technology if the research is not fundamental research or a foreign national is working in the lab where the controlled technology is being used.
• International travel where controlled technology will be taken outside the US. Laptops are considered controlled.
• Shipping controlled technologies outside the US.

What to Disclose:

Contact the UT Export Control Officer, David Ivey for assistance in determining if export control regulations apply to you. For more information see the UT Export Control website.

When to Disclose:

• Whenever it is unclear whether export control regulations apply.
• Before international travel. Loaner laptops are available.
• Before shipping technology or materials internationally.

Where to Disclose:

Contact the Export Control Officer.

Agency Requirement:

• NIH Reminders of NIH Policies on Other Support, etc.
• NIH FAQ – Other Support & Foreign Components
• Open Mike Blog Post clarifying long-standing NIH policies on disclosing other support

Other Support:

For ALL Senior / Key Personnel who contribute to scientific development or execution of a project in substantive, measurable way regardless of whether salary or compensation is requested for each individual:

1. All positions & scientific appointments (domestic & foreign)
   1. Includes compensated & uncompensated appointments
   2. Includes affiliations with foreign entities or governments
2. All resources and other support for ongoing projects
   1. Include all irrespective of whether support is provided through the applicant institution (UT), through another domestic or foreign organization, or is provided directly to an individual
   2. Include all even if in-kind support
   3. All research resources must be reported:
      • Foreign financial support
      • Research or laboratory personnel, lab space, scientific materials
      • Selection to foreign “talents” program
      • Other foreign or domestic support
   4. Total award amount for the entire award period covered & number of person-months per year to be devoted to each ongoing project by senior/key personnel

Foreign Component:

Foreign Components are “the existence of any significant scientific element or segment of a project outside of the United States.” Foreign components must be disclosed.

1. Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
2. Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

Agency Requirement:

• Draft Proposal & Award Policies & Procedures Guide May 2019
• Proposal & Award Policies & Procedures Guide February 2019

Other Support:

All individuals designated as senior personnel on NSF proposals must disclose:

1. All current and pending support, including for the proposed project, for ongoing projects, and for any proposals currently under consideration by any source.
   1. Report all regardless of whether funds provided through the proposing organization (UT) or directly to the individual [e.g., Federal, State, local, foreign, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects]
   2. Include the proposed activity and all other projects and activities, current and proposed, that require a time commitment, even if the support is only in-kind or no salary support is being provided
   3. Provide the total award amount for the entire award period covered (including indirect costs)
   4. Provide the number of person-months (or partial months) per year to be devoted to the project for each senior personnel
   5. If the project being proposed has been previously funded by NSF or otherwise, provide required information for the last period of funding

Foreign Component:

International Activities:

• Identify all international activities - “defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies.”
• List applicable countries

Foreign Organizations via subaward or consulting arrangement:

• Explain in the proposal why local support is not feasible and why the foreign organization can carry out the proposed activity more effectively. The proposal must demonstrate that the foreign organization:
  • Contributes a unique organization, geographic location, and/or access to unique data resources not generally available to US investigators, or other resources that are essential to the success of the proposed project; or
  • Offers significant science and engineering education, training or research opportunities to the US

Agency Requirement:

March 20, 2019 DoD Memo identifying other support disclosure requirements

Other Support:

For all key personnel, regardless of whether effort will be funded by the DoD:

• All current projects the individual is working on
• Any future support the individual has applied for from any source
• Title and objectives of the other research projects
• Percentage per year to be devoted to the other projects
• Total amount of support the individual is receiving in connection to each of the other research projects or will receive if awarded
• Name and address of the agencies and/or parties supporting the other projects
• Period of performance for the other projects

Other Support:

Proposers must submit the following for all key personnel, whether or not the individuals’ efforts under the project are to be funded through the award:

• Previous (award period of performance ending within the past 5 years), current, and pending research support including:
  • Title
  • Time commitments
  • Supporting agency
  • Name and address of funding agency’s procuring contracts/grants officer
  • Performance period
  • Level of funding
  • Brief description of project goals
  • Specific aims
  • Identify any overlap with other existing and pending research projects or state there is no overlap

Foreign Component:

Identify any partner organizations and their contribution(s), including location/country of the partner.

How do I disclose my foreign outside activities?

Foreign outside activities should be disclosed using the UT System’s Outside Activity Portal at https://apps.utsystem.edu/ActivityPortal/. Please visit the Provost Office’s Conflict of Interest, Conflict of Commitment, & Outside Activities page for information about UT’s outside activity policies at https://provost.utexas.edu/finance-reporting-compliance/conflict-of-interest-conflict-of-commitment-outside-activities/.

Please note, any employee of UT, including any person who holds a faculty appointment, regardless of compensation or length of appointment, must seek pre-approval prior to engaging in all compensated activities, outside employment, and academic appointments at non-UT institutions and organizations.

I received an honorary visiting professorship at a foreign institution. Do I have to disclose it?

Yes. In addition to disclosing it through UT System’s Outside Activity Portal at https://apps.utsystem.edu/ActivityPortal/, you must disclose all such affiliations in your Biosketch submitted as part of a grant application.

I am a 9-month academic year faculty member at UT and will be working at a foreign institution over the summer for two months and will receive salary support during this time. Do I need to disclose this?

Yes, you are required to disclose the nature and extent of all outside employment or other compensated activity through UT System’s Outside Activity Portal at https://apps.utsystem.edu/ActivityPortal/, as well as to your federal sponsor in your Biosketch. If you receive monetary payment (salary support or an honorarium) that equals or exceeds $5,000 annually, you must also disclose this to UT via the Financial Interest Disclosure system at https://spike.orsc.utexas.edu/fid by answering “Yes” to the first question in the Components section of the FID form. Furthermore, financial support and in-kind support (research space, equipment, materials or data, personnel/staff support) for any research you conduct at a foreign institution should be disclosed as Other Support or Current & Pending Support to your federal sponsor, as required. (NSF policy requires these in-kind resources to be included as part of the Facilities, Equipment, and Other Resources section of the proposal instead of the Current & Pending Support section only if these resources are intended for use on the project being proposed to NSF.)

Please note, any employee of UT, including any person who holds a faculty appointment, regardless of compensation or length of appointment, must seek pre-approval prior to engaging in all compensated activities, outside employment, and academic appointments at non-UT institutions and organizations.

I am an adjunct professor at Fudan University. I am listed as a Co-Investigator on a Chinese National Science Foundation award held by that University. I do not personally receive any compensation, but the grant pays for technicians’ salaries and the supplies for the research that I work on when visiting Fudan. Do I need to disclose this?

Yes. In addition to disclosing it through UT System’s Outside Activity Portal at https://apps.utsystem.edu/ActivityPortal/, you must disclose all such affiliations in your Biosketch submitted as part of a grant application. In addition, this financial resource directly supports your research endeavors and is required to be reported in your Current & Pending or Other Support to your federal sponsor, as required.

I have many foreign collaborators. How do I know if I should report a collaboration?

While most foreign collaborations are acceptable and encouraged, we recommend researchers err on the side of transparency. It is best practice to disclose any outside employment, academic appointments, and research activities involving a foreign entity to UT and to your federal sponsor, as appropriate. For further guidance please contact either the Office of Research Support and Compliance at coi@austin.utexas.edu or the Office of Sponsored Projects at osp@austin.utexas.edu.

As part of a collaboration effort with a colleague at a foreign institution, we are submitting a joint application for funding to a foreign entity. What disclosures do I need to make?

You should consult with the Office of Sponsored Projects (OSP) at osp@austin.utexas.edu about receiving a subaward to UT should the proposal be funded. All such applications must be disclosed in your Current & Pending or Other Support to federal sponsors. If the proposal is funded, OSP will assist with accepting the subaward and establishing a budget account for the receipt of the funds.

What if I author a publication that acknowledges federal (e.g., NIH, NSF, DOD, etc.) support for the work, and the publication has a foreign co-author and/or acknowledges support from a foreign entity – is that an international collaboration I should disclose?

It depends on the level of activity of the foreign author:

• If the foreign author performed a limited part of the work (e.g., ran some statistics) and the paper does not acknowledge any foreign funding, you should be prepared to answer a question regarding the author’s role but don’t need to do anything else.
• If the foreign author acknowledges funding for his or her limited work, and the collaborative research project is on-going, that funding would be considered in-kind support that should be disclosed on progress reports for the existing federal funding and as Current & Pending or Other Support on future funding proposals.
• If the work done by the foreign author is significant then it constitutes a Foreign Component, which requires prior approval by NIH. If the foreign collaboration was described in the federal funding proposal, it is already approved. If it was not in the proposal, prior approval must be requested from the grants management official before initiating the collaboration.

What are “foreign talent recruitment programs” and why is there concern about them?

A foreign talent recruitment (or similar) program has been defined as a state-sponsored foreign entity that compensates an individual in exchange for the transfer of knowledge, expertise, or other intellectual assets to the foreign country in furtherance of the country’s scientific development, economic prosperity, and national security. As described by the FBI, these programs target individuals working in specific areas of interest to the foreign government, to include scientists, engineers, academics, researchers, and entrepreneurs. Compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration. The federal government is concerned that foreign talent recruitment programs may be used by foreign governments to acquire, legally and illegally, US government-funded scientific research, proprietary technology or software, unpublished data and methods, and intellectual property in order to modernize the foreign government’s military, as well as dominate high technology sectors currently led by US entities.

Involvement in a foreign talent recruitment program is not illegal or against UT policy; however, you may violate US law if you don’t properly disclose your affiliation on US government-funded applications. Furthermore, UT policy requires that all employees must disclose and seek pre-approval for involvement in any and all programs sponsored, funded, directed, or controlled by a foreign government, foreign agency, or foreign institution, which, by definition, would include a foreign talent recruitment program. In addition, federal sponsoring agencies have exhibited recent concerns about foreign talent recruitment programs with a specific number of federal sponsors prohibiting involvement in a foreign talent program if working on or applying for federally-funded research.

Questions about involvement in a foreign talent recruitment program can be directed to the Science and Security office within the Office of Research Support and Compliance at sas@austin.utexas.edu.

I have several Visiting Scholars and Scientists in my lab. They are paid by their home institution, which is located in another country. The Visiting Scholars/Scientists are not Key Personnel on my federal grant. Does this need to be disclosed?

Yes, Visiting Scholars and Scientists who are paid by their home institution and supporting your research endeavors should be disclosed to the federal sponsor as Other Support or Current & Pending Support. (NSF policy specifically requires these in-kind resources be included as part of the Facilities, Equipment, and Other Resources section of the proposal instead of the Current & Pending Support section only if these resources are intended for use on the project being proposed.)

I have an unpaid researcher/student working in my lab who will assist in my proposed research project. How should I disclose this in-kind support?

Scholars, researchers, and students working in your lab with direct support from any organization other than UT (including those who identify as “self-funded”) and intended for use on your proposed project must be listed in the Other Support or Current and Pending Support section of the proposal. However, because these in-kind resources will be directly supporting your proposed research, NSF policy specifically requires they be included as part of the Facilities, Equipment, and Other Resources section of the proposal instead of the Current & Pending Support section.

I have an unpaid researcher/student working in my lab who will not be assisting in my proposed research project. Do I need to disclose this?

Yes, you must disclose all in-kind research and laboratory personnel, to include scholars, researchers, and students, supporting all of your research endeavors whether or not they are intended for use on the project being proposed as Other Support or Current & Pending Support.

I am receiving in-kind support such as equipment, supplies, and other scientific materials that will be used in my proposed research project. How should I report this?

All in-kind research resources that’s available to you in support of and/or related to all of your research projects must be reported in Other Support or Current & Pending Support of the proposal. NSF policy requires that in-kind resources specifically intended for use in your project being proposed must be included as part of the Facilities, Equipment, and Other Resources section of the proposal and need not be replicated in the Current and Pending Support section.

What do I do if I now see something I need to disclose to UT or a sponsor that I have never previously reported?

If you have an on-going outside activity not previously disclosed to UT, you should submit a disclosure to the Outside Activity Portal at https://apps.utsystem.edu/ActivityPortal/ as soon as possible. You should inform your supervisor that this is an ongoing activity that has not previously been submitted for approval. If you have a financial interest or position that should be reported on the Financial Interest Disclosure form, you should update your FID at https://spike.orsc.utexas.edu/fid/ as soon as possible. You should also indicate (where open text is allowed) the date that you acquired the financial interest and/or the date when you accepted the position.

If you need to correct an omission or error in a previously submitted proposal or progress report to your federal sponsor, or you have a new activity to report to the federal sponsor, please contact the Office of Sponsored Projects at osp@austin.utexas.edu (pre-award) or spaa@austin.utexas.edu (post award) for assistance.