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Foreign Disclosure General Guidance for Principal Investigators

The University of Pittsburgh encourages its faculty to engage in foreign collaborations, but it is important to understand reporting obligations related to these activities. If unsure, err on the side of transparency when considering or reporting a foreign activity. The following guidance is provided so that faculty are aware of what they have to disclose, where they have to disclose, and who to contact for internal assistance.

Foreign Disclosure General Guidance for Principal Investigators

Read sponsor guidelines, Funding Opportunity Announcements (FOAs), proposal questions, and award documents carefully to ensure that you and other project personnel are correctly answering the questions that address foreign engagements, foreign affiliations, and Foreign Components and collaborations, as required by the sponsor.

Review agency definitions to verify that your interpretation of your sponsor's Terms and Definitions is correct. The Office of Sponsored Programs and your sponsor's program and grants management staff can be contacted with questions about definitions.

Approach the Office of Sponsored Programs with internal questions concerning activities being proposed in a foreign country and identify the foreign countries where the research activities are being conducted.

Cite in manuscripts only the funding which specifically supports the work in the publication. Do not cite unrelated financial support in publications.

The federal government has been updating its guidance to the research community and has created the following “NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support” table to assist researchers in knowing where to disclose certain foreign engagements to federal agencies.