Research Disclosures and International Relationships

Transparency regarding research activities, appointments, affiliations, collaborations, and sources of research support is an important component of research security.

Federal research funding agencies and University policies require researchers to disclose certain professional activities, appointments, affiliations, research support, and other relationships. Requirements may apply to both domestic and international activities and vary by sponsor, award, and individual role.

Researchers are responsible for providing complete, current, and accurate information in required University and sponsor disclosures.

What May Need to Be Disclosed

Depending on the applicable sponsor, award, or University requirement, disclosures may include:

• Academic, professional, or institutional appointments and positions;
• Domestic and foreign affiliations;
• Current and pending research support;
• In-kind contributions and research resources;
• Consulting and other outside professional activities;
• Research funding, laboratory space, personnel, equipment, materials, travel, or other resources provided by an outside entity;
• Participation in foreign government-sponsored programs or activities;
• Participation in foreign talent recruitment programs; and
• Other activities, relationships, or commitments required by the applicable sponsor or University policy.

Disclosure requirements are not necessarily limited to activities for which an individual receives salary or direct monetary compensation. In-kind support and access to resources may also require disclosure.

Federal Research Disclosure Requirements

Federal research security requirements emphasize transparency regarding appointments, affiliations, research support, and other professional activities associated with federally funded research.

Requirements may be implemented through sponsor disclosure documents and processes such as:

• Biographical Sketch or Common Form;
• Current and Pending (Other) Support;
• Other Support;
• Collaborators and Other Affiliations;
• Conflict of Interest or Conflict of Commitment disclosures; and
• Sponsor-specific certifications, updates, or reporting.

Requirements differ among federal agencies. Researchers should follow the disclosure requirements applicable to the specific proposal, award, and sponsor.

International Research Relationships

International collaboration is an important part of the University's research mission. A relationship with a foreign researcher, institution, or organization does not by itself indicate a research security concern.

Certain international relationships, however, may require disclosure, screening, approval, or additional review. Researchers should seek guidance when an activity involves:

• A foreign appointment, employment relationship, or institutional affiliation;
• Research funding or other support from a foreign source;
• Laboratory space, personnel, equipment, materials, travel, or other resources provided by a foreign institution or organization;
• Formal or informal research arrangements with foreign institutions or organizations;
• Foreign government-sponsored programs or talent recruitment activities;
• Access to non-public research information, technology, software, data, or other University research resources; or
• An institution, organization, or individual that may be subject to federal restrictions.

Early review can help determine whether disclosure, screening, sponsor approval, export control review, mitigation, or other action is required.

Foreign Talent Recruitment Programs

Federal law and agency policies establish requirements concerning participation in certain foreign talent recruitment programs, including Malign Foreign Talent Recruitment Programs (MFTRPs).

Participation in an international collaboration, scholarly exchange, professional organization, or foreign program does not automatically constitute participation in an MFTRP. The determination depends on the specific program, sponsoring entity, terms, obligations, activities, and applicable federal requirements.

Researchers who are offered or participate in a foreign appointment, talent recruitment program, or similar arrangement should contact the Office of Research Integrity for review when there is uncertainty about applicable research security requirements.

Keeping Disclosures Current

Disclosure obligations may continue throughout the lifecycle of a proposal and award.

Researchers should update or correct required disclosures when circumstances change or when previously omitted information is identified, in accordance with applicable sponsor and University requirements.

When uncertain whether an appointment, affiliation, activity, relationship, or source of support should be disclosed, researchers should seek guidance before submitting the applicable disclosure or certification.

Applicable Requirements

Research disclosure and international relationship requirements may arise from:

• National Security Presidential Memorandum 33 (NSPM-33) and federal implementation guidance;
• CHIPS and Science Act of 2022;
• Federal research funding agency policies and award requirements;
• Federal requirements concerning Malign Foreign Talent Recruitment Programs;
• Applicable Louisiana requirements; and
• University disclosure, conflict of interest, conflict of commitment, outside employment, and related policies and procedures.

Agency-specific requirements should be consulted because disclosure requirements may differ by sponsor and change over time.

Assistance

For research security questions involving appointments, affiliations, international collaborations, talent recruitment programs, research support, or other research relationships, contact:

Office of Research Integrity
Research Security & Export Controls
researchsecurity@louisiana.edu
337-482-1533

Questions concerning proposal- or award-specific disclosure requirements should also be coordinated with the appropriate Sponsored Programs representative.