Transparency in Disclosure of Foreign Relationships and Activities
All foreign components of federally funded research should be disclosed during proposals, progress reports, and final technical reports. Investigators with external funding should carefully review the sponsor’s current disclosure requirements and contact the UMaine Office of Research Administration (ORA) for assistance or further guidance. In addition, investigators should:
- Review and update ‘Current and Pending Support’ (C&P) information and ‘Other support’ information in pending proposals and active awards per sponsor-specific guidance.
- National Science and Technology Council (NSTC) Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization (external link) – Sept. 1, 2022
- NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support (external link)
- NSF Guidance & Frequently Asked Questions on C&P Support (external link)
- NIH Other Support (external link) (Updated March 12, 2021 in response to NOT-OD-21-073 [external link])
- DoD Memorandum “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies” (PDF) (external link)
- DoD policy on Risk-Based Security Reviews of Fundamental Research (external link) (includes a Decision Matrix DoD will use to assess a researcher’s associations, affiliations, collaborations, and funding)
- National Aeronautics and Space Administration (NASA): Grant Notice GN 24-01: Forthcoming Grant Policies in Response to 2 CFR Revisions and NSPM-33 (PDF) (external link) – Sept. 5, 2024
- Review and update biosketches and ensure all professional appointments and collaborations, both foreign and domestic, are disclosed according to sponsor requirements in proposals and reports.
- NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization (external link) – Sept. 1, 2022
- NSF Pre-award & Post-Award Disclosures relating to the Biographical Sketch and Current & Pending Support (PDF) (external link) – Sept. 1, 2021
- NSF-Approved Formats for the Biographical Sketch (external link)
- NIH Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest (external link)
- DoD policy on Risk-Based Security Reviews of Fundamental Research (external link) (includes a Decision Matrix DoD will use to assess a researcher’s associations, affiliations, collaborations, and funding)
- NASA: Grant Notice GN 24-01: Forthcoming Grant Policies in Response to 2 CFR Revisions and NSPM-33 (PDF) (external link) – Sept. 5, 2024
- Ensure appropriate disclosure of foreign components for NIH-supported projects (see NIH Other Support and Foreign Components Frequently Asked Questions [external link]).
Conflicts of Interest
Faculty and staff should also familiarize themselves with the University of Maine System (UMS) and UMaine policies applicable to Conflict of Interest and outside employment and be fully transparent in disclosing outside interests and commitments. These policies include:
- The University of Maine System Conflict of Interest Policy
- UMaine Policies and Procedures for Financial Disclosures and Conflicts of Interest in Extramurally Sponsored Activities (Word)
- More information on UMaine’s Financial Conflict of Interest process can be found on the Office of Research Compliance (ORC) website: Financial Conflict of Interest
- Outside Employment Article(s) in your applicable bargaining unit contract (UMS Labor Relations)
Foreign Talent Recruitment Programs (FTRP)
The federal government has directed the university community to exercise extreme caution related to involvement with Foreign Talent Recruitment Programs (FTRP) due to the concern they may be used by foreign governments to acquire U.S. government-funded scientific research and valuable intellectual property. The CHIPS and Science Act of 2022 (external link) (CHIPS Act) directs federal research sponsors to maintain policies which:
- Require covered individuals to disclose all participation in FTRPs, and
- Prohibit recipients of federal support from participating in any Malign FTRPs (MFTRPs).
Researchers must familiarize themselves with institutional and agency requirements for disclosure of participation in FTRP and prohibitions against participating in any MFTRPs. The University of Maine policy and additional information about FTRP and MFTRP, including sponsor-specific information, can be found on the University’s guidance on Foreign Talent Recruitment Programs.