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OVPR Quarterly Reports – FY19Q4

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Dear Colleagues,

Now that data have been finalized, I would like to provide you with the FY19 Proposals, Awards, and Expenditures report relating to sponsored program activity—both research and education/service—managed by Sponsored Program Services within the Office of the Vice President for Research at UConn and UConn Health.

In the report, data are presented in two ways: by the PI’s Academic Home Department and by the Managing Department or Center/Institute. Please refer to the first page of the report for definitions and information regarding the data. Should you have any questions regarding this report, please do not hesitate to contact me. Please visit the OVPR website to view current and archived reports: OVPR Reports.

Please note that we have included an additional Summary of Sponsored Program Activity, which includes the Effective F&A rate on awards. This information provides a snapshot of our activity as compared to the same period last year.

While fluctuations from year to year in both grant awards and proposal submissions are common, the government shut down in January further impacted the timing of some awards and proposal submissions this year, which likely contributed to the reductions in overall numbers of individual submitted proposals and awards received. New awarded amounts are up in total, with Storrs and regional campuses ending the year slightly below last year’s totals and UConn Health receiving $8.4M more than last year. Overall dollars requested in proposals increased from $1.24M in FY18 to $1.26M in FY19.

The OVPR continues to seek creative solutions that allow UConn and UConn Health to grow our research enterprise through federal funding, industry partnerships, and collaboration with foundations. I am confident we can continue upward trends by continuing to work together, aggressively applying for extramural funding, and pursuing new channels of support for the tremendous research, scholarship, and creative activities taking place every day at UConn and UConn Health.

Thank you for your continued commitment and contribution to our students, to your research and scholarship, and to UConn/UConn Health.

Sincerely,

Radenka

Dr. Radenka Maric
Vice President for Research
UConn/UConn Health

Research Involving Cannabis, Hemp, and Marijuana

Cannabis-related research – including research involving marijuana and hemp – must conform to federal and state laws as well as University of Connecticut (“UConn”) policies.

Under the Federal 2018 Agricultural Improvement Act (Farm Bill), hemp is no longer a controlled substance. Hemp is legally defined as Cannabis sativa L. that contains not more than 0.3% delta-9 tetrahydrocannabinol (“THC”) content on a dry-weight basis.  The Farm Bill currently restricts the growing of hemp to states that have established a Hemp Research Pilot Program.

Connecticut recently established such a program with the passing of Public Act 19-3: “An Act Concerning a Pilot Program for Hemp Production.” This act established the state of Connecticut Hemp Research Pilot Program (HRPP) to support research that advances the Department of Agriculture's understanding of hemp agriculture at national, regional, and local levels.  This legislation sets the state requirements for hemp growers, processors, and manufacturers to obtain a license, and establishes requirements for licensing, testing, and inspection.  State requirements apply to the cultivation, processing, and manufacturing of hemp.  State requirements also apply to academic and scientific research, teaching, and testing involving hemp.

UConn researchers who wish to participate in the Connecticut’s HRPP must register through the University and follow University guidelines related to growing, processing, and manufacturing hemp.  For more information on registering through the University, email contact information to HempProgram@uconn.edu.

Marijuana, including Cannabis sativa L. that contains more than 0.3% delta-9 THC, remains a Schedule I controlled substance, the most restrictive status, under the Controlled Substances Act.  The possession, production, processing, sale, or growth of marijuana remains illegal under Federal law, except under special licensing requirements established by the Drug Enforcement Agency (“DEA”).  Research with marijuana requires the researcher to have both a Federal Schedule I and a Connecticut Schedule II controlled substance license, and s/he may only receive marijuana from other DEA registrants or from the National Institute on Drug Abuse (“NIDA”) approved sources.  UConn researchers must also follow the University’s Controlled Substances Policy or the UConn Health Controlled Substances Policy.  For more information regarding marijuana research, contact HempProgram@uconn.edu.

FAQs

Who is the primary UConn point of contact for external relations issues and requests related to hemp and marijuana?

In the Office of the Vice President for Research, the Associate Vice President for Research Integrity and Regulatory Affairs is the primary UConn point of contact regarding hemp and marijuana. Questions regarding hemp and marijuana should be emailed to HempProgram@uconn.edu.

How do I register through the University in order to participate in the state program?

To register through the University, email contact information to HempProgram@uconn.edu. Registration will involve a criminal background check, designation of the location hemp will be grown or processed, and designation of the source of the hemp.

Can I grow or process hemp, or engage in manufacturing with hemp at UConn without registering?

No. Growing hemp, processing hemp, or engaging in manufacturing with hemp by an individual as part of their University responsibilities or position, as part of a University program, or in University facilities or on University land must register with the Connecticut through the University.

Can I have a personal hemp plant in my dorm room, office, or other location?

No. The University does not allow growing, processing, or use in manufacturing of hemp on any UConn campus or in any UConn facilities unless it has been registered with the state through the University.

Where can I find information regarding the Connecticut Hemp Research Pilot Program?

The Connecticut Hemp Research Pilot Program provides information on the state program.

Once the state has issued a license, what am I required to do as the project principle investigator?

Once issued a license, you must comply with the provisions of Public Act 19-3 (the “Public Act”), the federal act (as defined in the Public Act), and the Connecticut Department of Agriculture (“DOAG”) Compliance Policy. As a condition of being granted a grower license, you, as the principle investigator and on-site manager listed on the license, and the University agree to the requirements listed below. Note that submissions and notifications must be made through the University:
1. Comply with instructions from the DOAG and law enforcement agencies;
2. Agree to pay DOAG applicable licensing and inspection fees;
3. Consent to entry onto, and inspection of all buildings, equipment, supplies, vehicles, and records located on this real property where hemp or plants or materials are located, or licensed to be located, by the commissioner, and law enforcement agencies, at any time, with or without cause, and with or without advance notice;
4. Comply with DOAG’s criminal history records check requirements; and
5. Consent to forfeit and destroy, without compensation:
a. Material found to have a THC content in excess of three-tenths percent (0.3%) on a dry weight basis;
b. Hemp plants located in an area that is not licensed by the department; and
c. Hemp plants not accounted for in required reports for the department.
6. Notify the DOAG of all hemp growing, handling, and storage locations, including legal description and GPS coordinates in decimal degrees to the ten-thousandth place, and receive department approval for those locations prior to having hemp on those premises.
7. Submit a Site Modification Request Form, the appropriate fees based on the requested changes, and obtain prior written approval from the commissioner before implementing any change to the plot(s) stated in the grower license application.
8. Not grow, handle, or store hemp in any location(s) other than the location(s) listed in the grower license application.
9. Not interplant hemp with any other crop without express written permission from the DOAG.
10. Not apply and not allow anyone else to apply pesticide to hemp except by person(s) who hold a valid permit or certificate, if required, to apply pesticides in accordance with section 22a-54 of the Connecticut general statutes.
11. Comply with all legal requirements regarding minimum distances from certain structures, and outdoor recreational facilities.
12. Acknowledges that the risk of financial or other loss shall be borne solely by the License Holder.
13. Use a record keeping and product coding system for hemp to facilitate the effective tracking of hemp and hemp products. Such plot system shall be capable of tracing hemp placed into the wholesale or retail distribution chain back to the producing plot. Such records shall be maintained for a period of time that exceeds the expected shelf life of the hemp or five (5) years, whichever is longer. Records of hemp product coding and distribution shall be made available immediately upon request of the department or any law enforcement agency.
14. Ensure that any time hemp is in transit within Connecticut, a copy of the grower license, and certificate of analysis showing the sample to have a THC concentration at or below three-tenths (0.3) percent on a dry weight basis, shall be available for inspection upon the request of the commissioner or any law enforcement agency. In the event the hemp being transported is a hemp sample being transported to a laboratory, then the sample shall be contained in a sealed tamper evident sample package and accompanied by the department approved completed chain of custody form for hemp samples. The hemp sample label shall contain, at a minimum, the date and time the sample was collected, licensee name, licensee number, location where the sample originated, identification of the lot the sample represents and a sample identification number or laboratory accession number.
15. Upon request from the commissioner or a law enforcement agency, immediately produce a copy of his or her grower license for inspection.
16. Submit Planting Reports, Harvest/Destruction Reports, Production Reports, and other reports required by the commissioner, on or before the deadlines established in these regulations. These records shall be maintained for at least three (3) years after harvest or destruction of the hemp. These records shall be made available immediately upon request of the department or any law enforcement agency.
17. Scout and monitor plots for volunteer hemp plants and to destroy those volunteer hemp plants for three (3) years past the last date of planting reported to the department.
18. Not to rent land to cultivate hemp from any person who has a state or federal felony conviction for a controlled substance within 10 (ten) years of the date of this agreement.
19. Notify the department of any interaction with any law enforcement agency immediately by phone and follow-up in writing within three (3) calendar days of the occurrence.
20. Immediately notify the department and applicable law enforcement agency of any theft of hemp materials, whether growing or not.
21. Immediately notify the department and applicable law enforcement agency of any unauthorized cultivation of any plant, within each plot.
22. To destroy any hemp or cannabis that is obligated to be destroyed, only in accordance with state and federal law, and the department’s established procedures.
23. Acknowledge that failure to comply with terms and conditions established in the department’s Compliance Policy and any regulations shall constitute grounds for appropriate action, up to and including termination of the grower license and expulsion from the department’s program.
24. Acknowledge that a person who has been expelled from the program shall not be eligible to reapply to the program for a period of five (5) years from the date of expulsion.
25. Have read and understood the state and federal statutes and the department’s Compliance Policy and any regulations related to the conditional grower license that is being issued.
26. Understand the Commissioner shall revoke or terminate any conditional grower license, if the applicant’s or conditional licensee’s, (including signing authority and on-site manager) results do not meet the federal and state criminal history records check, or the requirements of the federal act, the Public Act and the Compliance Policy.

How should UConn researchers dispose of unwanted industrial hemp materials?

Currently, the only process for destruction of materials is burial or composting. Signed documentation of method of destruction, who destroyed the materials, and when the destruction occurred should be retained.

What is the definition of industrial hemp?

The definition of hemp under Connecticut and federal law is “a plant of the genus Cannabis and any part of the plant, whether growing or not, containing a delta-9 tetrahydrocannabinol (THC) concentration of no more than three-tenths of one percent (0.3%) on a dry weight basis.”

Is hemp different from marijuana?

Yes. Hemp and marijuana are varieties of the cannabis plant that are differentiated based on selective breeding. Hemp is bred for its fiber and seed oil. By both federal and state law, hemp cannot contain more than 0.3% THC on a dry weight basis. THC is delta-9 tetrahydrocannabinol and is the psychoactive component of marijuana. Marijuana is defined as cannabis that contains greater than 0.3% THC on a dry weight basis. Marijuana remains a Schedule I controlled substance. Schedule I controlled substances are subject to the most intense scrutiny by the DEA. In Connecticut, the Connecticut Department of Agriculture regulates hemp cultivation. Under the U.S. Farm Bill and Connecticut’s Pilot Program, institutions of higher education like UConn have latitude to cultivate and research industrial hemp, including its constituent compounds, without a DEA Schedule I license.

Does hemp include extracts that include cannabidiol or other cannabinoids?

The key defining characteristic of hemp is that it is Cannabis sativa L. that does not include THC at a concentration of more than 0.3% on a dry weight basis. If the extract meets that criterion, was lawfully grown in accordance with a state Pilot Program, and was processed in accordance with state law, then it would qualify for treatment as industrial hemp.

Can UConn researchers do hemp research under a DEA Schedule I registration?

No, a researcher may not perform research on hemp with a DEA Schedule I registration because hemp has been removed from the Federal Controlled Substances Schedule.

Can UConn researchers grow industrial hemp for research purposes?

Yes, but this requires registering through the University for a growers’ license from the Connecticut Department of Agriculture.

Where can UConn researchers obtain certified seed to grow hemp for research purposes?

UConn researchers should obtain certified hemp seed only from an agency authorized under the laws of a state, territory, or possession of the United States to officially certify hemp seeds and that has standards and procedures approved by the U.S. Secretary of Agriculture to assure the genetic purity and identity of the hemp seed certified. The seed must have a certificate or other instrument attesting to its genetic purity and identity.

Can UConn researchers obtain CBD (Cannabidiol) for research purposes?

A qualified yes. CBD and other materials derived from Hemp that contain a THC concentration of less than 0.3% on a dry weight basis are not subject to the Controlled Substances Act if the materials are cultivated and processed pursuant to the U.S. Farm Bill and the Pilot Program. In addition, the sourcing party must be properly licensed (for cultivation/processing) with the state’s proper licensing authorities. Please contact HempProgram@uconn.edu before undertaking such research. They can alert researchers to any issues that may exist with sourcing and licensing requirements.

I only want to purchase CBD (cannabidiol) or hemp for use in my research, not grow or process hemp. Are there any specific requirements?

Only hemp, CBD, and other hemp derivatives that can be traced back to lawfully cultivated Industrial Hemp through proper documentation can be used for research. You should only procure hemp and hemp derivatives from vendors that can provide such documentation. A copy of such documentation must be retained by the researcher. CBD or hemp derived from Industrial Hemp does not require a Connecticut State Hemp License or a DEA Controlled Substance License. However, CBD or hemp that is NOT derived from Industrial Hemp or that you DO NOT have documentation as being derived from Industrial Hemp is considered a Schedule 1 Controlled Substance. Possession of a Schedule 1 Controlled Substance is illegal unless you hold the appropriate State and Federal DEA licensure.

Can UConn researchers obtain hemp products from third parties for research purposes?

A qualified yes. Hemp materials and products (other than viable seeds) that contain a THC concentration of less than 0.3% on a dry weight basis are not subject to the Controlled Substances Act if the materials and products are cultivated pursuant to the U.S. Farm Bill and the Pilot Program. In addition, the third party must be properly licensed with a State Department of Agriculture’s Industrial Hemp Pilot Program, and its activities must have a research purpose. Thus, a researcher is permitted to receive and perform research on such materials and products from parties with which it enters collaborative research-focused agreements.

Can UConn researchers perform hemp research funded by third party industries?

Yes, subject to certain UConn and Connecticut Department of Agriculture approvals. However, accepting funds coming from the marijuana industry or any business related to it is restricted due to current federal banking regulations.

Can UConn researchers perform hemp research in a paid or unpaid sabbatical situation in a foreign country whose laws permit industrial hemp research in any capacity?

Yes.

Can UConn researchers license intellectual property rights resulting from hemp research?

Yes.

Does the Connecticut Hemp Research Pilot Program allow research with marijuana?

No. Marijuana research is defined as research that involves the growth, production, procurement, administration, or use of marijuana. It does not refer to observational research for which the researcher does not grow, produce, procure, or administer marijuana. Marijuana has the same meaning as in the definition provided by Connecticut General Statues § 21a-240(29).

Marijuana is categorized as a Schedule I drug by the DEA under the federal Controlled Substances Act. This means that federal regulations do not permit the use, production, processing, sale, or growth of marijuana, except for medical or research use conducted under special licensing requirements established by the DEA and the U.S. Food and Drug Administration (“FDA”) for use with humans or animals. Typically, research conducted under a DEA license also requires sourcing the marijuana from the NIDA. The U.S. Department of Justice’s (“DoJ”) previous guidance indicating that it will not focus its prosecutorial resources on the sale or use of marijuana in states where a well-regulated legal framework has been established was rescinded in 2018. To date, no exemption from the federal regulations has been granted to any state.

UConn is the recipient of considerable federal funding for research, education, capital projects, and healthcare. Accepting this funding obligates UConn to comply with the Drug-Free Schools and Communities Act and the Drug-Free Workplace Act. These federal regulations together prohibit UConn from unlawful manufacture, distribution, dispensing, possession, or use of any controlled substance at the University. Unlike the DoJ’s stance on enforcement of DEA regulations, there has been no statement suggesting that enforcement of the Drug-Free Schools and Communities Act or the Drug-Free Workplace Act has been, or will be, relaxed.

Consequently, despite the state of Connecticut’s legalization of medical marijuana, there is no provision that allows for the legal research of medical marijuana except as already established and involving compliance with DEA, FDA, and NIDA policies and regulations.

Where can I find information about courses or programs at UConn related to hemp?

The UConn College of Agriculture, Health and Natural Resources conducts courses related to hemp cultivation and production. Additional information can be found by searching the College of Agriculture, Health and Natural Resources web site.

Is anyone at UConn involved in testing as part of the state Hemp Research Pilot Program?

The UConn Center for Environmental Sciences and Engineering conducts testing as part of the Hemp Research Pilot Program. Additional information can be found on the Center for Environmental Sciences and Engineering web site or by contacting the Center for Environmental Sciences and Engineering Laboratory Director, Christopher Perkins by either email (christopher.perkins@uconn.edu) or phone (860.486.2668).

START Preliminary Proof of Concept Fund

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Dear Colleagues,

 

Through a generous grant provided by the CTNext Higher Education Fund last year, the Office of the Vice President for Research (OVPR) has been administering an early stage translational research funding program called the START Preliminary Proof of Concept (PPOC) Fund. Under the grant, funding is provided to investigators at Central Connecticut State University (CCSU), Southern Connecticut State University (SCSU), University of Bridgeport (UB), and UConn on a competitive basis.

 

The START program aims to support the preliminary validation of innovative early stage technologies that have possible commercial potential and is designed to advance those technologies to be more attractive for additional funding. Proposals for the START PPOC Fund are welcomed from across all disciplines for early stage projects that may one day result in inventions and technologies that address unmet needs and have potential for commercial application.

 

As we wrap up the first year on funding, I would like to take a moment to recognize recipients from these institutions and ask that you join me in congratulating them on their efforts to commercialize technologies developed in the course of their academic research. For a full list of recipients and project information, visit the OVPR website.

 

For more information about the competition, visit the program website.

 

Thank you for helping to foster the culture of excellence in your schools/colleges, departments, and centers that allows UConn faculty to engage in research, scholarship, and creative activities at the highest levels. 

 

 

Cheers,

Radenka

Celebrating UConn Research, Scholarship, and Creative Activities

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As we begin a new semester at UConn, I would like to reflect on our past academic year and share with you the excitement, successes, and progress we made in that time. As a public research university that engages globally in the creation of new knowledge, we measure our success by the impact of our scholarly and educational outcomes, research, innovation, and the creative work of our students and faculty. In the last few years, we have brought people together around shared goals across campuses and disciplines, an accomplishment that is palpable at UConn and has been critical to the success of our land-grant mission.

Our three consecutive years of growth in total awards have borne out the value of our collective efforts.

Thanks to the tireless work of our faculty, postdocs, students, and staff, our new extramural awards for FY19 reached a three-year high of $266.2M. In FY17, our total new awards were $184.5M and in FY18, they were $258M. UConn Health received over $100M in new awards this past fiscal year reaching an all-time high. Our combined efforts represent a 44% increase over three years. We also saw upward trends in our entrepreneurship and innovation ecosystem, with a record 39 high-potential startup companies joining UConn’s Technology Incubation Program, and a ranking of 93rd worldwide in the number of US patents issued for UConn inventions. It is a matter of great satisfaction for me to have helped position entrepreneurship and innovation as an equal mission for our faculty alongside teaching, scholarship, research and creative work.

Our committed focus on seed funding, proof of concept grants, and awards to support the arts and humanities has contributed to STEM and non-STEM excellence. In FY19, our office contributed $2.3M to internal funding programs and an additional $100K to support grant writing workshops and resources. We are thrilled to see engagement, collaboration, and distinction from all areas of the University, whether it be STEM, non-STEM, or a collaborative hybrid, and that these combined efforts are producing growth in research and extramural awards.

I would like to highlight a few new initiatives launched by the OVPR in FY19 that supported faculty success:

  • Convergence Awards for Research in Interdisciplinary Centers (CARIC): Support development of collaborative interdisciplinary teams to bid for major (>$5M) federally funded initiatives, such as research centers.
  • Support of UConn Human Rights Institute with two postdoctoral fellowships in collaboration with the Schools of Engineering and Business.
  • Program in Accelerated Therapeutics for Healthcare (PATH): In partnership with the Schools of Pharmacy and Medicine, aims to accelerate the translational pathway to convert discoveries into new medical therapeutics. The program seeks to quickly develop novel approaches focusing on well validated molecular targets for a specific disease area with an unmet treatment need in the current commercial marketplace.
  • Scholarship and Collaboration in Humanities and Arts Research Program (SCHARP): In partnership with the Humanities Institute, SCHARP supports innovative works in scholarship and creative activities in the arts and humanities that have the potential to transform a field of study, impact the common good, or chart a new direction in scholarly, creative, or artistic direction.
  • STEAM Innovation Grant: In partnership with the School of Fine Arts, STEAM encourages innovative collaborations between the arts and STEM disciplines. Projects funded by this grant may result in publications, exhibitions, performances, academic symposia, or other research outcomes.
  • Stamford Innovate, a new internship program that connects talented UConn students with opportunities in startups in one of the fastest growing regions of the state.

If you want to learn more, click here for a full list of our internal funding programs.

As educators, we all take great pride in our students’ successes, and I wanted to take a moment to recognize some new student projects that are truly remarkable. In collaboration with the Office of the Provost, the OVPR supported a student-led podcast called In Vivo. With regular interviews about science, the arts, current events, and other topics, In Vivo highlights the amazing faculty, students, and staff that give UConn life. The show is conducted out of UConn’s WHUS studio and is run entirely by UConn students. Check it out and consider subscribing for future episodes to learn more about UConn researchers.

Another new initiative is World Poetry Books to support its mission of publishing and vigorously promoting a minimum of six books of exceptional poetry in translation each year. This support offers our students the opportunity to gain hands-on, professional publishing skills, and establishes UConn as home of a preeminent publisher of exceptional world literature.

While sharing accomplishments is important, we also want to increase transparency and continue to maintain open lines of communication as we push to raise UConn’s research profile. In addition to sharing research and tech transfer metrics on the recently revamped UConn Research website, we encourage faculty and staff to reach out with suggestions regarding new opportunities and unmet needs. It is only together – as a team – that we will continue to drive the growth of scholarship, research, and creative pursuits at UConn.

I’d like to conclude with a personal note of gratitude. I cannot thank all of you enough for giving me the opportunity to work with so many talented, hardworking, and committed colleagues. To my staff, I am deeply honored to serve as VPR and grateful for your support, continued improvement, and service to our faculty and students. At the end of a hard day, I find great inspiration in the knowledge that UConn’s faculty and staff – whether they be musicians, chemists, or scholars of law or other disciplines – are some of the world’s most innovative and active researchers. Thank you for making UConn a special place with a vibrant community of caring, collaborative people.

We are opening a new chapter for UConn with a new President who is focused on our excellence, strengths, and new opportunities. I look forward to this journey with all of you, and please remember my door is always open!

Cheers,

Dr. Radenka Maric

Vice President for Research, UConn/UConn Health

SBIR and STTR

Various federal agencies provide funding to small businesses to conduct research and development with the goal of commercializing technology. This federal funding occurs via two different award mechanisms:

  • Small Business Innovation Research (“SBIR”)
  • Small Business Technology Transfer (“STTR”)

Both SBIR and STTR awards are made directly to a small business concern (“SBC”). A SBC is a for-profit company that is the applicant fora SBIR/STTR award. In this section of the guidance, we use the terms SBC and company interchangeably.

STTRs require that the SBC collaborate with a research institution (“RI”) for a certain portion of the award. SBIRs do not require RI involvement, but SBCs often collaborate with RIs on SBIRs. A RI is the research institution partner, such as UConn, that collaborates with an SBC for a SBIR/STTR award through a subcontract/subaward under the SBC.

UConn meets the criteria to serve as a RI for SBIRs and STTRs. UConn’s involvement in either a SBIR or a STTR occurs when it is either included in the proposal or the federal sponsor has provided approval to SBC to engage with the university and is awarded via a subcontract/subaward from the SBC to the university. In cases where there is a collaboration/subcontract/subaward between the SBC and the RI, there is an SBC PI and an RI PI (i.e. a PI for each side of the collaboration).

Requirements for SBIRs and STTRs

SBIR

Applicability Eligibility Requirements
SBC Must be an American-owned business

Must be independently operated

Must be a for-profit business

Must have five hundred or fewer employees

If sub-contract with another party, or with multiple parties: SBC must do at least two-thirds of research during Phase I; SBC must do at least one-half of research during Phase II
SBC PI Must be primarily employed with SBC
RI Involvement of RI not required

If the SBC subcontracts with RI: RI may conduct up to one-third of research during Phase I; RI may do up to one-half of research during Phase II

STTR

Applicability Eligibility Requirements
SBC Must be an American-owned business

Must be independently operated

Must be a for-profit business

Must have five hundred or fewer employees

Not less than 40% of the research/research development must be performed by SBC
SBC PI Must be primarily employed by either the SBC or the collaborating RI
RI Research Institution collaborator required

Must be one of the following: A non-profit college or university; A domestic non-profit research organization; or A federally funded Research and Development Center

RI required to conduct at least 30% of research and development but may conduct up to 60% of research and development

SBC Use of University Space

Small businesses certify in their SBIR and STTR applications and award documents to the federal government that the SBC research and development will occur in SBC facilities using company employees unless otherwise indicated in the SBIR or STTR application and approved in the funding agreement. Therefore, performing the SBC portion of such research in University space using University resources — unless specifically approved by the funding agency and allowed by the University – subjects the company to potential criminal, civil, or administrative sanctions.

Consulting for a Faculty Affiliated Company

As a general rule, if the faculty affiliated company is sponsoring research at UConn under an SBIR or STTR, the faculty member should not be paid as a consultant under the award.

The Same Individual Serving as University PI and SBC PI

For SBIR awards, the SBC PI must be primarily employed by the company. Most faculty members are fully employed by UConn and therefore cannot serve as the PI for an SBC. To serve as PI for a SBC, the faculty member cannot have a University position or appointment of greater than 49%.

For STTR awards, the PI named on the award may be primarily employed by either the company or the University. The exception is for NSF STTR awards, in which the PI named on the award must be primarily employed by the SBC.

For the work conducted for both SBIR and STTR awards, the SBC PI and the RI PI may not be the same individual. While not explicitly stated, the STTR/SBIR policy, instructions, and project percentage requirements make clear that establishing a separation of entities and roles is important. Having the same person on both sides of the collaboration blurs the respective parties’ project roles, responsibilities and effort/time commitments.

Specific sponsor policies or requirements may differ and be more restrictive. For example, the NSF guidance states that no person who is an equity holder, employee, or officer of the proposing small business may (1) be paid as a consultant, or (2) be paid through a subaward budget, in either case, unless recommended and approved by the NSF.

Faculty members that have an interest in an SBC must read all sponsor requirements for SBIR/STTR proposals and awards carefully and note what situations may be prohibited or that may require advance sponsor approval. It is strongly recommended that the SBC engage counsel to review and advice on the grant awards, and hire accountants with specific expertise in SBIRs and STTRs.

Management of Faculty Affiliated Company Grants

The faculty affiliated company/external entity is responsible for all grant administration relating to company grants, including SBIR and STTR grants.  The faculty affiliated company/external entity should seek professional advice on appropriate grant management and administration.

Federal and Sponsor Specific Guidance

 The US Small Business Administration provides guidance to small businesses wishing to pursue SBIR or STTR funding opportunities. Their website includes general information as well as links to individual federal sponsor programs. Sponsors may have additional guidelines or restrictions and those small businesses seeking to pursue a SBIR or STTR project should be careful to thoroughly review guidelines and restrictions.

Faculty Affiliated Companies / External Entities

What is the purpose of this page?

Assistance with identifying University requirements, policies, guidance, and procedures, including State Code of Ethics laws, related to faculty affiliated companies /external entities.

NOTICE:  If applicable, please review the notice for Faculty Obligations related to Engagement in Outside entities identified as Faculty Affiliated Companies.

Who should review this information?

 Faculty, staff, and students who hold a financial interest in, or conduct University activities with, a faculty affiliated company /external entity.

Why is this important?

Perceived or real conflicts may arise between University activities and activities of faculty affiliated companies /external entities. The University of Connecticut, its Regional Campuses and UConn Health (the University) are committed to fostering the entrepreneurial activities of its faculty and staff, in addition to its core missions of teaching, research and service. Consistent with its mission, the University encourages translational research, innovation and entrepreneurial activities. The University also is dedicated to ensuring transparency and compliance with University policy and State and Federal regulations.

Is everything I need to know here?

These pages are not an all-encompassing list of requirements, and members of the University community are expected to know and comply with all applicable University policies, and State and Federal regulations. In some cases, federal law and regulation will be stricter than State ethics laws and UConn policy, and such applicable portions of federal law will take precedence, while other aspects of State or University policy will remain in force. The federal and state regulations that govern these areas are complicated and these pages do not cover every situation that may need to be addressed. Therefore, the University recommends faculty, staff and students seek expert guidance in addition to adhering to the provided guidelines.

Who do I contact for more information?

The information available within these pages is also summarized in a Guidelines for Faculty, Staff, and Students who are affiliated with a Company document. The University strongly encourages any University employee affiliated with a company or acting as a consultant for a faculty affiliated company to seek advice from the Office of the Vice President for Research, the Provost’s Office, the State Ethics Liaison, and the Procurement Services group.  The Office of University Compliance is also available to assist with questions relevant to University policies or State and Federal regulations.

Purchasing Goods or Services

In general, State ethics laws prohibit faculty affiliated companies from selling goods or services to the University unless the company is awarded a contract through a public competitive procurement process. A UConn employee holding an interest in a faculty affiliated company / external entity should contact UConn Procurement Services and Sponsored Programs Services if the company would like to sell goods or services to UConn. Procurement Services will work with the appropriate departments to determine whether the sale would comply with State ethics laws and, if applicable, purchasing laws and regulations. If public competitive procurement is required, the UConn employee should play no role in the process (such as writing specifications for the good or service) and should not discuss the process with any UConn employee involved.

In addition, some research sponsors require advance notice or disclosure prior to purchasing goods and services from a faculty affiliated company. Sponsored Program Services must be contacted if there is a request or intent to purchase equipment or services from a company in which a faculty member on the award has significant financial interests to determine if prior approval from the sponsor or other steps are required.

Purchase and Use of Goods and Services from a Faculty Affiliated Company

Faculty affiliated companies /external entities (“the Company”) must comply with all state ethics obligations if and when the Company transacts business with the University or State of Connecticut.  For University employees who have an interest with a faculty affiliated company/external entity, the following obligations are worthy of particular note:

  • An individual with an interest in the Company may not participate in any procurement or contracting in which the University may buy products or services made or provided by the Company.
  • Unless an exception is granted by the Vice President for Research or designee, an individual with an interest in the Company may not participate in any subawarding process in which the University may subaward funds to the Company.  For additional information about subawards to/from faculty affiliated companies, please see Subawards and Subcontracts page.
  • The Company may be barred from a transaction if a University employee with an affiliation with the Company is privy to information that is not available to other companies and that would provide the Company with a competitive advantage over other companies.
  • The Company is generally only permitted to sell goods or services to the University or the State through an open and public process. For example, the Company is generally not permitted to sell “sole source” goods or services to the University or the State. The Office of University Compliance must be contacted prior to any such sale to determine whether the sale would comply with state law.

Obtaining and Moving Materials to/from a Faculty Affiliated Company

  • If a University employee obtains materials from the Company for their University research, Sponsored Program Services should be contacted for consideration of whether a Materials Transfer Agreement (MTA) is necessary.
  • If a University employee plans to move materials from their University laboratory to the Company, Technology Transfer and Venture Development should be contacted for an MTA.

Policies and Regulations

State of Connecticut Ethics Laws

University Guide to the State Code of Ethics

All University faculty and staff are subject to the Connecticut state ethics laws.  Connecticut State ethics laws are designed to prevent a state employee, his/her family, and any associated business(es) from benefiting personally from his/her position as a state employee. The guidance on Consulting Approval, Purchasing Goods or Services, Employment of Students, and Use of University Facilities/Resources, are intended to help the University community comply with state ethics laws and University policy.  While the University has developed its own policy based upon state ethics laws, the University Guide to the State Code of Ethics, the final authority to interpret and enforce these laws rests with the Office of State Ethics, an independent regulatory division of the state.

This policy includes several considerations related to conflicts of interest.

For guidance regarding individual situations, contact the Ethics Liaison.

University Policies

The following University policies are of particular importance for members of the University community who hold a financial interest in, or conduct University activities with, a faculty affiliated company.  Additional guidelines on these topics are available within this site.

Code of Conduct

The Code of Conduct includes campus-wide standards on conflict of interest.

For guidance regarding individual situations, contact the Office of University Compliance.

Faculty Consulting Policy

This policy addresses when a faculty member is working for a faculty affiliated company in a paid or unpaid capacity, including as an employee, consultant, or advisor.

For guidance regarding individual situations, contact the Faculty Consulting Office.

Use of Students in Outside Employment

This policy addresses if a student is to be employed by a faculty affiliated company / external entity.

Financial Conflict of Interest in Research (UConn Storrs/Regionals)

Individuals at UConn Storrs, School of Law, School of Social Work, and the Regional campuses who are involved in University research as an Investigator must make full and timely disclosures of financial interests, including any financial interests with a faculty affiliated company /external entity, according to this policy.

Important Information from the NIH and NSF

Posted on by

Dear Investigator,

On July 10th, the National Institutes of Health (NIH) published a reminder on NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components.  This was followed on July 11th by a Dear Colleague Letter on protecting research funded by the National Science Foundation (NSF) from NSF Director, Dr. France Córdova. These notices relate to the ongoing concerns regarding foreign influence in federally funded research.

In response to these publications, the OVPR recommends that any collaborations with foreign entities or individuals, or appointments with foreign entities (including foreign talent or similar programs) be disclosed to the NIH or NSF program officer, your Dean, and the OVPR (contacts and additional information listed below).

The OVPR has posted additional guidance on our site regarding Active and Pending Support and Foreign Collaborations. For any questions or for guidance on this and other related matters, please contact:

Thank you for your cooperation,

Radenka Maric, PhD
Vice President for Research
UConn/UConn Health

 

 

Important Information from the NIH and NSF for UConn/UConn Health Investigators

The NSF Letter references the draft NSF Proposal and Award Policies & Procedures Guide published in May 2019.  Clarifications in the draft Guide related to current and pending support and biographical sketches include:

  • Providing information for all current and pending support irrespective of whether such support is provided through the proposing organization or directly to the individual.
  • Expanding examples of current and pending support to include non-profit organizations and consulting agreements.
  • Reporting all projects and activities requiring a time commitment (no minimum has been established), even if the support received is only in-kind.
  • Appointments should include any titled academic, professional, or institutional position whether or not remuneration is received.

The Dear Colleague Letter also states the NSF will be issuing a policy that NSF personnel and Intergovernmental Personnel Act (IPA) assigned personnel cannot participate in foreign government talent-recruitment programs.

The NIH Notice reminds applicants that in regards to Other Support, they must:

  • List all positions and scientific appointments, both domestic and foreign, held by senior/key personnel which are relevant to an application including affiliations with foreign entities or governments such as titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
  • Report all resources and other support for all individuals designated in an application as senior/key personnel – including the program director/principal investigator and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. All current support for ongoing projects must be included, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual who supports the senior/key personnel’s research efforts.
  • Report all current projects and activities involving senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees), including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support.
  • Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel.

 

The Notice also reminds applicants of the need to determine whether projects include a foreign component, defined as the existence of any “significant scientific element or segment of a project” outside of the United States including:

  • Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
  • 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.

 

If a significant portion of a project will be conducted outside the United States, then there is a foreign component and NIH prior approval is required.  If all project activity is conducted within the United States, but there is a non-U.S. resource supporting the project, it must be reported as other support.

Program in Accelerated Therapeutics for Healthcare (PATH) Awards

Posted on by

Dear Colleagues,

I’m very pleased to announce that the Office of the Vice President for Research (OVPR) has recently finalized award decisions for the inaugural cycle of the Program in Accelerated Therapeutics for Healthcare (PATH).  PATH is a partnership that includes the OVPR, the School of Pharmacy, and the School of Medicine to accelerate the translational pathway for researchers to convert their discoveries to new medical therapeutics. Under PATH, funding is provided to academic research programs designed to quickly develop novel therapeutic approaches focusing on well validated molecular targets for a specific disease area with an unmet treatment need in the current commercial marketplace. Projects focusing on a wide range of therapeutic interventions (small molecule, biologic, antibody, peptide, gene therapy) are eligible for consideration.

Given your leadership role in the University, I want you to be among the first to hear the results of this competition so you can join me in congratulating the awardees.  Seven PATH grants were awarded in two categories after a highly selective competition:

 

PATH Trailblazer Grants – $75,000

Xiuling Lu, Pharmaceutical Science
Cutting Cancer at Its Root: Inhibition of Acute Leukemic Stem Cells Using Doxorubicin-Loaded Nanoparticles

Jessica Rouge, Chemistry
Determining the Pharmacology of a Novel DNAzyme-therapeutic Formulation for the Treatment of Allergic Airway Disease

 

PATH Ascent Grants – $10,000

Brian Aneskievich, Pharmaceutical Science
Establishing Protein Conformational Flexibility to Enhance Next-Step Drug-Screen Targeting

Nicholas Leadbeater, Chemistry
Towards Development of Novel Therapeutics for Treatment of Toxoplasmosis

Rajkumar Verma, Neuroscience, UConn Health
Discovery of Novel Purinergic P2X4 Receptor Antagonist for the Treatment of Ischemic Stroke

Simon White, Molecular and Cell Biology
Screening for Small Molecule Inhibitors against Enterovirus D68 2C Helicase

Ming Xu, Genetics and Genome Sciences, UConn Health
Discover Drugs Targeting Cellular Senescence to Improve Healthspan and Lifespan

For more information about PATH, visit the program website.

Thank you for helping to foster the culture of excellence in your schools/colleges, departments, and centers, that allows UConn faculty to engage in research, scholarship, and creative activities at the highest levels.

Cheers,

Radenka

OVPR Internal Funding End Date / Project Change Requests

OVPR Internal Funding End Date / Budget / Scope Change Request

This form can be used by PIs or staff who wish to request changes to an awarded OVPR internal funding project. These changes can include the end date of the project, changes in how funds are to be spent, or substantial changes in project approach or scope. The information gathered on this form will help the OVPR understand the request and its impact on the project so that an approval decision can be made. Fields marked with an asterisk (*) are required.

  • Principal Investigator Information

  • Must be a valid UConn email address.

  • Administrative Contact Information

    In case information is needed. If you are submitting this form on behalf of the PI put your contact information here.

  • Award Information

  • For Storrs Awards, please provide KFS account. For awards based at UCH, please provide Banner account number.
  • Please indicate the OVPR program under which the award was made. A full list of OVPR programs can be found here: https://ovpr.uconn.edu/services/research-development/internal-funding-opportunities/
  • When was this award originally scheduled to end? If you requested and received a revised timeline at award setup, you can reference that revised end date. If you requested and received an end date extension after the project began, do not include that extended date here.
    MM slash DD slash YYYY
  • MM slash DD slash YYYY
  • Please provide a brief summary of which project aims (as proposed in the original application) have been accomplished so far and what work remains to be completed before the project can be concluded.
  • Please provide a brief description of what delayed the project, and indicate whether those delaying elements have been resolved.
  • Will the project be able to proceed as described in the original proposal and budget? Or will there need to be changes in the plan of work and/or how the budget is spent? If so, what changes are anticipated and how do they impact the project)?
  • This field is for validation purposes and should be left unchanged.

dbGaP

  1. Request access to the controlled data sets from the appropriate dbGaP (Database of Genotypes and Phenotypes) Data Access Committee (DAC): https://dbgap.ncbi.nlm.nih.gov/aa/dbgap_request_process.pdf.
  2. Download and complete the model Data Use Certification (DUC) for the controlled data set of interest:
    • Visit the dbGAP site at http://www.ncbi.nlm.nih.gov/gap.
    • Search for the study from which data are requested. For example, “joint addiction, aging, mental health” results in number of studies.dbgap1
    • Click on the linked study title of interest for instructions on how to download the model DUC and determine if IRB approval is required. Model DUC and IRB Requirements can be found under the “Study” tab in the “Authorized Access” section (as shown in screenshot).
      dbgap2dbgap3
    • If IRB approval is required, go to the section for “dbGaP Access Request” found at https://ovpr.uchc.edu//rcs/hspp/irb/irb-instructions-forms-and-samples/
      download and complete the form “dbGaP Access Request Form for IRB Certification.”
  3. Complete the Data Security and Data Release Form (MS Word) (PDF).
  4. Email the completed Model Data Use Certification, IRB Approval for dbGaP Data Access (if required), and Data Security and Data Release Reporting form to the AVP for Research, Research IT Services – Dr. Khamis Abu-Hasaballah – at khamis@uconn.edu. Upon verification and approval of these documents, the AVP for Research will issue a certification letter signed by him, the Institutional Chief Security Officer, and the Institutional Signing Official (SPS Director).

Foreign Collaborations

INTERNATIONAL RELATIONSHIPS, FOREIGN COMPONENTS, AND SPONSORED PROGRAMS

It protects everyone’s interests – those of the Federal government, UConn, individual investigators, and their international collaborators – to have international relationships disclosed and vetted to determine if there are any potential conflict of commitments, duplications of research, and/or diversion of intellectual property in the performance of federally funded research. In some cases, failure to disclose all relationships could result in the termination of funding for a project and potential ineligibility for future funding. Noncompliance can also threaten not only the funding for individual projects, but overall funding for the University. UConn encourages international collaborations and the OVPR strongly urges investigators to err on the side of transparency in disclosing these collaborations to the University and Sponsors.

MALIGN FOREIGN TALENT RECRUITMENT PROGRAMS

Beginning 8/9/2024, all federal agencies must prohibit participation in a malign foreign talent recruitment program by covered individuals involved with research and development awards from those agencies.

UPDATE 8/7/2024: UConn has established a Malign Foreign Talent Program Participation Policy, which requires that Covered Individuals listed in a proposal for a research award from a Federal Sponsor must certify as part of the proposal submission that they are not currently participating in, nor will they participate in, a Malign Foreign Talent Recruitment Program.

Foreign Talent Recruitment Programs (Section 10631(b), Creating Helpful Incentives to Produce Semiconductors [CHIPS] and Science Act of 2022)

Section 10631(d) of the CHIPS and Science Act of 2022 requires federal research agencies to issue a policy on foreign talent recruitment programs, along with a policy specific to malign foreign talent recruitment programs. The Act prohibits “covered individuals” from participating in a federally funded research and development project if they are currently participating in a “malign foreign talent recruitment program.” Federal research agencies may request supporting documentation from applicants, and take a range of funding-related actions. The Act defines “covered individual” as “an individual who A. contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and B. is designated as a covered individual by the Federal research agency concerned.” (Agencies may define other individuals as covered persons as appropriate and consistent with their mission.

A malign foreign talent recruitment program is any type of program, position, or activity that involves one or more of the following:

  • Unauthorized transfer of intellectual property, materials, data or other nonpublic information;
  • Recruitment of trainees or researchers to enroll in such program, position or activity;
  • Establishing a laboratory or entity in a foreign country in violation of terms and conditions of a federal research award;
  • Accepting a faculty position, or undertaking any other employment or appointment in violation of the standard terms and conditions of a federal research award;
  • Being unable to terminate the activity except in extraordinary circumstances;
  • Being limited in capacity to carry out a federal research award;
  • Requirement to engage in work that overlaps or duplicates a federal research award;
  • Requirement to obtain research funding from the foreign government’s entities;
  • Requirement to omit acknowledgement of the U.S. home institution and/or the federal funding agency;
  • Requirement to not disclose participation in the program, position, or activity; OR
  • Having a conflict of interest or commitment contrary to a federal research award.

AND is sponsored by one of the following:

  • A foreign country of concern (currently defined as the People’s Republic of China including Hong Kong and Macau, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State); or
  • An entity based in a foreign country of concern; or
  • An institution or program on certain prohibited lists (contact the Director of Research Integrity and Security for screening).

AGENCY-SPECIFIC GUIDANCE

National Science Foundation

Individuals who are a current party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after May 20, 2024. As of the effective date of May 20, 2024 of NSF 24-1 Proposal and Award Policies and Procedures Guide (PAPPG), the Authorized Organizational Representative (typically the Pre-Award Senior Grants and Contracts Specialist) must certify that all individuals identified as senior/key personnel have been made aware of and have complie3d with their responsibility to certify that the individual is not a party to a malign foreign talent recruitment program. IN ADDITION, each identified senior/key person must certify, in signing their Biographical Sketch form via SciENcv (required), that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award.

Misrepresentations and/or omissions may be subject to prosecution and liability pursuant to, but not limited to, 18 U.S.C. §§ 287, 1001, 1031 and 31 U.S.C. §§ 3729-3733 and 3802.

National Institutes of Health

Full transparency in NIH applications and throughout the life of an NIH grant is critical. NIH requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards. NIH uses this information when making its funding decisions to determine if the research being proposed is receiving other sources of funding that could be duplicative, has the necessary time allocation, or if financial interests may affect objectivity in the conduct of the research.

NIH Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114)

Department of Defense

Beginning August 9, 2024, the Department of Defense is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022. 

On March 20, 2019, DoD issued a memo directing that all new DoD Notices of Funding Opportunities pertaining to research and research-related educational activities include a requirement that proposers provide additional information on the other support and commitments of all key personnel, regardless of whether the proposal is funded.

Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education

Department of Energy

DOE Order No. O 486-1: Department of Energy Foreign Government Sponsored or Affiliated Activities prohibits DOE employees and contractors participating in foreign talent recruitment programs from certain countries from receiving DOE funding. Universities must therefore disclose whether a researcher currently involved in a DOE award has participated in either a funded or unfunded Foreign Government Talent Recruitment Program.

Additional Resources

White House Office of Science and Technology Policy Foreign Talent Recruitment Program Guidelines

Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise (National Science & Technology Council)

GOVERNMENT CONCERN

  1. The National Institutes of Health (NIH) issued a Notice on March 30, 2018, reminding research institutions that PIs, sub-awardees and co-PIs must disclose all financial interests received from higher education or governmental institutions in countries outside the United States (NOT-OD-18-160). NIH Director Dr. Francis S. Collins also sent a memo.pdf to institutions on Aug. 20, 2018, stating that the failure to properly disclose foreign relationships threatened to distort decision-making about the use of NIH funds.
  2. The Department of Defense
    • 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 … ”
    • Memorandum from the Office of the Under Secretary of Defense dated October 10, 2019 which states that “the challenge of protecting the integrity of our research enterprise is a national priority.”  The letter lays out DoD’s steps to date to “limit undue influence by countries that desire to exploit DoD research, science and technology, and innovation enterprise through foreign talent programs and other means” and steps DoD plans to pursue, and calls for a dynamic, Government wide, partnership, “ No laboratory, university, industry partner, or Government agency can address the full scope of this challenge alone, and solutions to this problem can only result from a dynamic partnership between our public and private sectors.”
    • Memorandum titled “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies” dated March 20, 2019.  Directing for all new DoD Notices of Funding Opportunities related to research and research-related educational activities include requirements that “proposer submit additional Current and Active support information for all key personnel, whether or not the individuals are to funded by the DoD.
  3. The National Science Board issued a statement on “Security and Science” dated October 23, 2018, stating that US universities must “embrace transparency and rigorously adhere to conflict of interest and conflict of commitment policies.”
  4. The National Science Foundation, issued a letter on July 11 from the NSF Director to colleagues on “Research Protection” related to other support, financial conflicts of interest and foreign components (NSF 19-200).
  5. The Department of Energy issued a notification on February 1, 2019, stating that DOE plans to implement a policy, which will mandate that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.”
  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” (grant restrictions, contract restrictions.pdf).

Foreign Components

Foreign components of federally funded research should be disclosed in proposals, progress reports, and final technical reports. Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended”. The definition of “foreign component” (which can be found here) may include a large number of collaborative activities, 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.” Other sponsors have similar requirements to disclose foreign components.

NIH Policy on Foreign Component 

NIH requires recipients to determine whether activities it supports include a foreign component, defined as the existence of any “significant scientific element or segment of a project” outside of the United States, in other words:

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.

  • If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component.  See NIH FAQs on Other Support and Foreign Components. The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, as outlined in the NIHGPS (Section 8.1.2) Prior Approval Requirements.
  • If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.
    For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI’s NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI’s grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.
  • Foreign Other support must be disclosed to the NIH in advance by including it in the Just-in-Time Other Support submission on a new or renewal award, or updated in the annual RPPR, or submitted by letter to the awarding office and thereafter included in the RPPR.
  • Foreign Components applies to NIH work scope performed in a foreign location, either funded by the NIH grant or by other sources, domestic or foreign.

Also see NIH’s “Protecting U.S. Biomedical Intellectual Innovation.”

Foreign Payments

The University’s Consulting Policy  requires prior approval of any remuneration, compensation, honorarium, stipends, non-university salary, or other similar payments for providing consulting, advice, services, support or other similar activities from any source, including foreign entities or persons.  The University’s Financial Conflicts of Interest in Research Policy requires disclosure of remuneration, compensation, honorarium, stipends, non-university salary, or other similar payments totaling over $5,000 in a 12 month period from a single entity, and any paid or reimbursed travel totaling over $5000 in a 12 month period by a single entity.  This include any foreign entity (e.g. governments and institutions) or persons.

Current and Other Support 

“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” or “Current & Pending” form.   See here for guidance.

Past Communication

December 2020 Email from President Katsouleas: “Reminder: Threats to Research”

December 2019 Updates

How to Get Assistance?

Faculty and investigators who have questions or concerns about disclosure requirements should contact the OVPR for guidance and assistance.

Contact the OVPR