Emerging Federal Guidance on Outside Influence
Integrity is the hallmark of all great universities. MSU, like our peer institutions, requires honesty and full disclosure of material facts related to outside affiliations in faculty research and creative activities.
Recently, the U.S. government began a multifaceted effort to raise compliance standards related to outside influence on research, intellectual property, and associated technology implementation.
The Office of Research and Innovation wants to emphasize to colleagues at all levels that full and timely disclosure regarding research support and conflicts of interest is essential to the transparency the government requires and MSU expects. Currently the University requires all faculty to:
- Complete a Conflict of Interest disclosure at the time a new grant proposal is submitted, and at least annually:
- Complete the Outside Work for Pay disclosure and approval process, as required by policy:
- Fully and accurately complete all required forms and respond to all funding agency requests regarding any current and pending support.
The Office of Research and Innovation has created this web page to help MSU faculty and staff stay current with emerging federal guidelines. The page will be updated as new information, guidelines, and resources become available.
MSU values its international collaborators and inter-institutional affiliations. Preservation of important international relationships will be facilitated by our careful attention to federal requirements of transparency in research and related activity.
Please read the memo dated July 3, 2019, from MSU leadership for more information.
Also see President Stanley's op-ed from The Hill dated July 30, 2019.
Note: The staff within the Office of Research and Innovation recognizes that federal guidelines continue to use "foreign" influence and that the term does not align with MSU's values. Our team has attempted to replace "foreign" with "outside" or other terminology where appropriate. For background, please refer to the memo from university leadership dated February 2, 2020.
Non-Domestic Influence – Frequently Asked Questions
Undisclosed working relationships between scholars in U.S. institutions and non-domestic entities (e.g., universities, companies, and governments) have increasingly been of concern to American science agencies. These FAQs include general information related to issues of non-domestic influence.
Current and Pending / Other Support Requirements by Sponsor
Current and Pending Support, also known as Other Support, is a form typically used by federal sponsors to request information for the PI(s) and Key Personnel’s current and pending research projects. Most federal agencies require Current & Pending Support documents to be submitted with the proposal or just before an award is issued, and if awarded, they may require any changes to be disclosed in progress reports. If applicable to your proposal/award, please remember to include ALL support including grants, and contracts from all non-U.S. and domestic sources, including MSU project support. The format of this requirement varies by sponsor. It is the responsibility of the Investigator/Key Person to make sure that all research projects and affiliations are disclosed and that the document is completed in its entirety.
Global Activities e-Disclosure
To support faculty in the required federal funding agency disclosures and to assist faculty in addressing any potential conflicts, the Office of Research and Innovation has developed the Global Activities e-Disclosure (GAED) web-based form to supplement other required disclosures. The GAED form asks for disclosure of any current or pending, compensated or uncompensated collaborations, appointments, affiliations, or resources with or from any non-domestic entities. Responses will help MSU understand the scope of interactions with non-domestic entities and what assistance is needed to enable compliance with university and federal agency requirements.
Disclosure of Involvement
- Letter to U.S. Research Community from Office of Science and Technology Policy - September 16, 2019
- NSF Dear Colleagues Letter: Research Protection - July 11, 2019
- Department of Defense Memo - Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies - March 20, 2019
- Science article on DOE policies - February 8, 2019
- NIH Dear Colleagues Letter - August 20, 2018
Disclosure of Funding Support
- Current and Pending - Other Support Requirements by Sponsor
- Science magazine update re: NIH investigation - June 22, 2020
- Department of Education Reminder to report ownership/control by, and contracts/gifts from, foreign sources - June 22, 2020
- Science article on NIH investigation – July 5, 2019
- Additional information from MSU's Sponsored Programs on NIH July 10, 2019 Notice
- Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components NOT-OD-19-114 - July 10, 2019
- Advisory Committee to the NIH Director Working Group on Foreign Influences on Research Integrity
- NIH Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests - March 30, 2018
Funding Agency Positions
For questions related to proposal and award requirements, e.g., Current and Pending Support, Foreign Component, please contact the appropriate group below:
- If you are developing a proposal, please contact your Proposal Team
- If you have a question related to an award that has already been funded, please email firstname.lastname@example.org
- Alternatively, you may email Twila Reighley at email@example.com
For questions related to Export Control and Trade Sanctions, please email firstname.lastname@example.org or call 517-432-4499