How do I....use facilities or materials at my partner institution overseas?
- if my funding source is NIH:
NIH Grant Policy Statement 2.5.1 requires disclosure of these in-kind contributions.
- if my funding source is NSF:
Unfunded international collaboration support for the proposed project should be documented in the Facilities, Equipment and Other Resources section of the proposal, AND "all other projects or activities requiring a portion of time of the PI and any other senior personnel must be included, even if they receive no salary support from the project(s)" must be listed under Current and Pending Support per the PAPPG.
- if my funding source is Department of Energy:
This may not be allowable depending on the program. If allowed, review with the Export Controls Officer & Intellectual Property Officer should be done prior to submission to set up secondary agreements such as Materials Transfer Agreement.
- if my funding source is Department of Defense:
Follow the same procedure as Department of Energy.
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How do I....participate in a conference or conduct research overseas?
- if my funding source is NIH:
List the planned travel in the budget and provide a complete budget justification. Follow institutional procedures to protect intellectual property while en route and overseas.
- if my funding source is NSF:
List the planned travel in the budget and provide a complete budget justification. Follow institutional procedures to protect intellectual property while en route and overseas. NSF IPA detailees should avoid foreign talent recruitment programs.
- if my funding source is Department of Energy:
Review the event carefully to ensure it is not a foreign talent recruitment program in the guise of a presentation or conference. Participation in such an event is prohibited by DOE Order 486.1 when William & Mary is serving as a contractor to DoE. Assistance agreements are currently exempt. Agency prior approval may be required for contracts. Follow institutional procedures to protect intellectual property while en route and overseas.
- if my funding source is Department of Defense:
Same talent recruitment restrictions as DOE.
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How do I....include my co-PI at an overseas institution?
- if my funding source is NIH:
After confirming the funding type permits a foreign collaboration, use the NIH FAQ tool to first determine if the work overseas qualifies as a “significant foreign component.” Address leadership structure in the Leadership Plan proposal document.
- if my funding source is NSF:
NSF will allow participation by foreign institutions as a sub-award or consultant, but in most cases will not provide funding support (other funds must be identified). There are additional special conditions noted in the PAPPG. Check the requisite box on the cover page.
- if my funding source is Department of Energy:
DoE has different Intellectual Property terms and conditions for international applicants than it does for domestic ones. Confirm partner institution is willing to accept DoE IP terms.
- if my funding source is Department of Defense:
Review funding announcement to confirm overseas partners are eligible consortium members.
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How do I....collaborate on a research project with a foreign partner or institution in a paid or unpaid capacity, whether through my institution or individually?
- if my funding source is NIH:
NIH applicants must report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources 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 must be reported.
- if my funding source is NSF:
Unfunded collaboration support should be documented in the Facilities, Equipment and Other Resources statement. Current & Pending Support documents for NSF proposals must include all current project support from whatever source (e.g., Federal, State, local, foreign, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects) must be listed. The proposed project and all other projects or activities requiring a portion of time of the PI and any other senior personnel must be included, even if they receive no salary support from the project(s).
- if my funding source is Department of Energy:
DOE has created a list of emerging “research areas and technologies that are in the U.S. national interest to limit sensitive country foreign nationals (SCFN) access,” referred to as the Science & Technology (S&T) Risk Matrix (although it does not appear to be publicly accessible); DOE will implement enhanced vetting requirements for all foreign nationals visiting or assigned to DOE labs; and prohibits SCFNs from certain activities; and generally prohibits travel to sensitive countries.
- if my funding source is Department of Defense:
Disclose all applicable “Other Support” as required by DOD application documents.
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How do I....hire a foreign national to work on my project on-campus?
- if my funding source is NIH:
Fundamental research exemption should preclude any special action.
- if my funding source is NSF:
Fundamental research exemption should preclude any special action.
- if my funding source is Department of Energy:
Review funding announcement to confirm foreign nationals are eligible as staff members. Review with W&M Export Controls Officer may be necessary.
- if my funding source is Department of Defense:
Review funding announcement to confirm foreign nationals are eligible as staff members. Review with W&M Export Controls Officer may be necessary.
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How do I....let the funding agency know I have a courtesy/affiliate appointment at a foreign institution?
- if my funding source is NIH:
List this affiliation in the Biosketch section. Even though the researcher is not receiving monetary compensation, if lab space, materials, and/or staff are resources made available in support of and/or related to research efforts, it should be disclosed as "Other Support." Other payments, such as travel or living expenses must also be reported.
- if my funding source is NSF:
The 2020 PAPPG includes an expanded definition of “professional appointments” and your affiliation should be noted in the biographical sketch under the "appointments" section and your COA file should reference the appointment. If lab space, materials, and/or staff are resources made available in support of and/or related to research efforts, it should be disclosed as "Other Support." Other payments, such as travel or living expenses must also be reported.
- if my funding source is Department of Energy:
List this affiliation in the Biosketch or CV attached to the proposal.
- if my funding source is Department of Defense:
List this affiliation in the Biosketch or CV attached to the proposal.
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How do I....document that I received a fellowship as an individual and not through my home institution?
- if my funding source is NIH:
Identify this direct award, including the duration and dollar amount, as part of the current & pending support documentation.
- if my funding source is NSF:
The 2020 PAPPG notes that gifts and awards made to individual researchers should be documented in that senior personnel member’s Current & Pending Support document.
- if my funding source is Department of Energy:
Identify this direct award, including the duration and dollar amount, as part of the current & pending support documentation.
- if my funding source is Department of Defense:
Identify this direct award, including the duration and dollar amount, as part of the current & pending support documentation.
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