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International Activities Disclosures

The University of Missouri-St. Louis values international collaborations and recognizes that such collaborations are integral to fulfilling our mission as a public, land-grant university, but it is important that UMSL investigators be open and fully transparent about their foreign relationships and activities. UMSL's Office of Research(ORA) has compiled the following information to provide guidance and resources for our researchers, and to remind them of their reporting obligations to federal sponsors and to UMSL.

Background Information

The U.S. Government has expressed concerns about the failure of researchers to disclose their relationships and activities with foreign institutions and foreign funding agencies to their research sponsors and/or to their own institutions. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize an investigator’s or an institution’s eligibility for future funding.

  1. National Institutes of Health (NIH)
    The NIH has issued communications to the research community at large and to its grantee institutions (including UMSL) to convey the NIH's pride in supporting researchers from all over the world who have made “seminal biomedical discoveries” at U.S. institutions and universities. However, the NIH also noted in these communications their concerns about the integrity of the biomedical research it funds and the risk that foreign influence poses to that integrity. Among the issues identified, the NIH is troubled by the
    • Diversion of intellectual property (IP) in grant applications or produced by NIH-supported biomedical research to other entities, including other countries; [and the]
    • Failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.
  2. Department of Defense (DoD)
    The FY 2019 National Defense Authorization Act (NDAA) directs the DoD to work with academic institutions to limit the undue influence of foreign talent programs and support protection of intellectual property. It further calls for the DoD to develop regulations in this area and limit or prohibit funding for institutions or individual researchers who violate them. Additionally, the NDAA directs the DoD to prioritize funding of academic institutions that have a record of excellence in industrial security.

    In response, the DoD has announced that key personnel supported by DoD sponsored research and research-related educational activities will be required to disclose information about all sources of their research support, regardless of whether those individuals’ efforts are to be funded by the DoD. The memo specifies that the information to be collected will be “used to support protection of intellectual property…[and]limit undue influence, including foreign talent programs, by countries that desire to exploit United States' technology.”

The requirement to disclose all sources of research support has always been a part of the sponsored research enterprise; requests for full and open disclosures are not new mandates being implemented by research sponsors. Instead, sponsors are looking to reduce the discrepancies they have noted in some researchers’ disclosures of affiliations and funding.

Best Practices

UMSL supports and encourages most international collaborations but also recognizes that Federal sponsors have legitimate concerns about protecting U.S. government (taxpayer funded) research and development activities such as those performed at UMSL.

The items below contain guidance regarding the types of relationships and activities that researchers are expected to disclose to their sponsors and/or to the University. Additional information about relevant University of Missouri - St. Louis policies and NIH and NSF requirements is provided in the resources section below. Other federal agencies may have other, specific reporting requirements.

Disclosures to Federal Sponsors
  1. Faculty submitting proposals for or performing federally funded research that involves a "foreign component" (NIH), an "international activity" (NSF), or any other similar work must state that in proposals, progress reports, and final technical reports.

    The NIH defines a "foreign component" as "any significant scientific element or segment of a project outside of the United States…whether or not grant funds are expended". The NIH also provides examples of collaborative activities that it considers to be a foreign component, including "collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity." Similar to the NIH, proposals to NSF require disclosure of any "international activity," which NSF defines as "research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies." This could include international travel to attend conferences, or funding a foreign entity through a sub-award or consulting agreement.

    Other sponsors may have similar requirements to disclose foreign components.

    There are multiple ways in which foreign components can be disclosed, e.g.,

    • Identifying a "foreign component" in an NIH grant application
    • Listing a "non-U.S. performance site"
    • Identifying foreign relationships and activities in a biosketch
    • Checking "yes" to the question on the Research & Related Other Project Information Form asking, "Does this project involve activities outside of the United States or partnerships with international collaborators?"
    • Indicating that a proposal involves "international activities" on the Cover Sheet for Proposal to the National Science Foundation
    • Providing letters of commitment or letters of support from foreign collaborators
  2. UMSL researchers should ensure they disclose all applicable "Other Support" (NIH), "Current and Pending Support" (NSF, DoD), or as otherwise required by federal sponsors.
    • "Other Support" includes all financial resources, domestic or foreign, available in direct support of a researcher’s research endeavors. Such support should be disclosed on an "Other Support" form in response to a Just-in-Time (JIT) request or as a part of an annual or final Research Performance Progress Report (RPPR).
    • "Current and Pending Support" includes all current (sponsored) project support, regardless of the funding source.
    • Financial resources originating from a foreign entity, government, or institution 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 nine-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.
  3. Biosketches and the NSF "Collaborators and Other Affiliations" (COA) documents should be current and thorough. This would include disclosure of joint appointments or employment at other institutions, foreign or domestic. The NIH requires disclosure of appointments relevant to the scope of work in the grant proposal while NSF requests that all "academic/professional appointments" be included in the biosketch.
  4. Participation in Malign Foreign Talent Recruitment Programs (defined in the CHIPS and Science Act of 2022) is a major concern for federal funding agencies. Not disclosing other support (also known as current and pending support) is a breach of trust with our sponsors and demonstrates a lack of transparency. As such, after completing the technical merit review to decide which proposals to fund, federal agencies are beginning to complete a decision matrix to evaluate risks associated with the funding of fundamental research proposals. 

In addition, NSF requires the disclosure of Collaborators and Other Affiliations (COA) in order to collect information about certain types of relationships and collaborations for each individual in a proposal identified by name as "senior project personnel." The information required in the COA tables includes organizational affiliations for the previous 12 months and all co-authors and research collaborators for the previous 48 months.

Most federal sponsors will have their own guidance on how to complete their forms. It is ultimately the responsibility of the individual researcher to ensure that all proposal forms, progress reports, and other documents submitted to a sponsor are complete and accurate to the best of his or her knowledge.

Those researchers who submit grant proposals to, or receive research or other sponsored funding from, federal agencies such as the NIH and NSF should review and update their relevant documents and disclosures as needed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Adminstration to have the error corrected. The addition of a foreign component to an existing grant award should be reported to the Office of Research Administration to obtain the federal agency prior approval. The PI should submit their request for prior approval to the Office of Research Administration to obtain agency approval prior to the engagement of the new entity.

Malign Foreign Talent Recruitment Program

The definition from CHIPS and Science Act of 2022 is: The term ‘‘malign foreign talent recruitment program’’ means:

  • (A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual
    • (i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;
    • (ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;
    • (iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
    • (iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
    • (v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;
    • (vi) being required to apply for and successfully receive funding from the sponsoring foreign government’s funding agencies with the sponsoring foreign organization as the recipient;
    • (vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the federal research and development award;
    • (viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
    • (ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and
  • (B) a program that is sponsored by
    • (i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern;
    • (ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 2358 note; Public Law 115-232); or
    • (iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 2358 note; Public Law 115-232).


The Office of Science and Technology Policy has provided additional guidelines on Malign Foreign Talent Recruitment Programs in the Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs.

Disclosures to the University

  1. External activities related to work within the scope of a researcher’s University responsibilities ("outside interests") must be disclosed through the UMSL Conflict of Interest (COI)/Conflict of Commitment (COC) process and through any NIH or NSF required reporting mechanism. The definition of "outside interest" is included in UM CRR 330.015, which requires disclosure of all activities, regardless of whether those activities occur within the state of Missouri, inside the U.S., or internationally, when those activities include:
    1. Grants and contracts involving an employee financial interest
    2. Overlapping business activities
    3. Full-time employment — faculty and exempt personnel
    4. Teaching
    5. Faculty-authored textbooks and other educational materials
    6. Consulting

If you are unsure whether an external activity constitutes an outside interest that meets the threshold for required disclosure, please contact the Conflict of Interest Office at coioffice@umsl.edu. Disclosures of outside interests can be made by logging into the eCompliance system.