As Jim Luther, Duke Vice President for Finance and Sponsor Liaison and Research Compliance Officer emphasized, foreign relationships, regardless of financial components, should be considered for management & appropriate disclosure in grant documents.
- In the context of international collaborations, special considerations should be given to intellectual property, the peer review process and the overlap between scientific and financial commitment.
- National Institutes of Health requires that intellectual property is protected through the entire process of grant application and selection
- Department of Energy mandates that all DOE contractor personnel fully disclose and, if necessary, terminate affiliations with foreign government-supported talent recruitment programs
- Department of Defense limit or prohibit funding for institutions or individual researchers who violate regulations
Training and resources
Lindsey Spangler, JD, Assistant Dean for Research Facilitation at the School of Medicine advised:
- Additional guidance from the NIH is forthcoming, and when received, will be posted on Duke’s Grant Support website (grantsupport.duke.edu)
- If submitting a proposal to the NIH, be sure to review the definition of “Foreign Component.” To update the NIH on new or changing foreign components, work with your grant administrator to submit a prior approval request through your assigned central research administration office (ORA or ORS).
- Note that the definition of foreign component may include publications with foreign co-authors, so it’s important to ensure proper disclosure to NIH if your publication will meet the definition of foreign component.
Conflict of Interest
Angie Solomon, Associate Director of the School of Medicine Conflict of Interest advised:
- Full disclosure of financial support is required to Duke, funding agencies, collaborators and journal editors; non-disclosure can compromise the credibility of research even if nothing unethical happened.
- Investigators with research sponsored by the U.S. Public Health Service (PHS) of the U.S. Department of Health and Human Services are required to disclose certain information about all sponsored or reimbursed international travel with a few exceptions.
International Shipping and Exports/ Imports regulations
Dan Vick, MBA, Director of Duke Export Controls, advised:
- Contact Duke Export Controls Office to determine if export licenses or import permits are required for international shipment and, if so, to apply for these.
- Contact Duke Export Controls for advice on travel to restricted destinations.
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