Faculty must disclose any financial or in-kind support from foreign organizations. Faculty must also disclose and seek prior approval if they plan to participate in certain outside professional activities with foreign entities (e.g., consulting, board positions, research through foreign universities, and more). Policies ACAF 1.50 and RSCH 1.06 provide additional details on which activities must be disclosed, and the process for making disclosures.
If new outside professional activities or financial interests arise during the year (e.g., items not listed in the annual disclosure), faculty must seek written approval from their local unit head before engaging in the activity. Approval shall be documented in written correspondence between the faculty member and their unit head. If the new activity or interest presents a potential conflict of interest, it must be approved in AIR with a corresponding management plan.
Faculty engaged in sponsored research must disclose any new significant financial interests within 30 days of discovering or acquiring the interest .
When developing a grant proposal, faculty must disclose any foreign components to their research as well as a range of items related to their research in the “other support” section of the grant. For example:
- In-kind contributions towards the research
- Visiting scholars including postdoctoral researchers funded by an entity other than USC
- Students funded by an entity other than USC
- Travel paid by an entity other than USC to perform research associated with the grant
This NIH FAQ provides additional examples and context on which international activities must be disclosed. If faculty have any questions about whether to disclose an activity, they should contact their representative in the Office of Sponsored Awards Management.
In recent years, the federal government has become increasingly concerned about inappropriate foreign influence and research security risks at U.S. academic institutions. NIH specified three areas of concern: failure of researchers to disclose resources from outside organizations (including foreign governments), diversion of intellectual property (IP) from grant funded projects, and sharing of confidential information with foreign entities.
Foreign Government Talent Recruitment Programs (FGTRP) are, broadly speaking, initiatives sponsored by foreign governments that provide compensation in exchange for individuals to transfer knowledge and expertise to the sponsoring country. Federal agencies have shared several definitions of what constitutes a FGTRP:
- National Security Presidential Memorandum (NSPM-33)- Sec.2.(e)
- National Science Foundation (NSF)
- Department of Energy (DOE)
Faculty considering participation in a FGTRP, must follow USC policy related to outside professional activities, including obtaining prior supervisory approval and disclosure of the activity.
If these collaborations relate to federally sponsored research, you may need to disclose the activities in the “other support” section of your grant proposal. Collaborations that would require disclosure include:
- Visiting scholars contributing to research activities, including postdoctoral researchers funded by an entity other than own institution
- Students contributing to sponsored research who are funded by an entity other than USC
- In-kind contributions (office/laboratory space, equipment, supplies, or employees or students) supported by an outside source
Faculty with nine-month appointments must report outside professional activity from the full year (e.g., including activities from the summer months). Before accepting a summer engagement in another country, faculty should receive written approval from their department chair to ensure the activity does not constitute a conflict with their USC duties.
If faculty are planning to travel internationally with research data subject to export controls, please contact Office of Research Compliance (email@example.com) to ensure you understand any limitations related to your research data.
Before engaging in paid outside consulting, a faculty member must obtain the approval of their local unit head. Such approval should be based on consideration of potential conflicts of interest and the impact of the outside activity on professional obligations to the university. Faculty considering engagements in countries under US government sanctions must ensure they understand any potential restrictions on their work in these countries. If you have any questions about these restrictions, please contact Brandi Boniface (firstname.lastname@example.org).
If you are planning to hire or host a non-U.S. citizen who will have access to University resources, the individual must be appointed either as an employee or as a non-salaried affiliate consistent with University policies. Please contact your HR liaison and the Office for International Scholars (OIS@sc.edu) at least 6 months in advance of the proposed activity. OIS provides quick guides with relevant procedures.
Faculty must disclose all financial and in-kind support from foreign organizations related to their work at UofSC. Faculty engaged in federally sponsored research projects must disclose this type of support as “other support” in their research proposal.
Disclosures help to protect the faculty member, the university, and stakeholders involved in sponsored research. Failure to disclosure required activities or outside financial interests is grounds for disciplinary action pursuant to the relevant university policies. Federal funding agencies may also pursue disciplinary actions, including civil or criminal enforcement.