In March 2018, the National Institutes of Health (NIH) issued a notice reminding research institutions that Principal Investigators (PIs), co-PIs, and sub-awardees must disclose all foreign financial interests. In August 2018, NIH Director Dr. Francis Collins testified before Congress regarding the risk of inappropriate foreign influences on research integrity. Subsequent to that testimony, Dr. Collins issued a “Dear Colleagues” letter to the NIH grantee community describing “threats” from foreign entities, reiterating the requirement of disclosing “relevant affiliations,” and identifying three areas of concern for grantees: (1) improper handling of intellectual property, (2) peer review violations, and (3) failure to disclose “substantial resources.” As a result of this letter, the NIH also convened a working group to develop and recommend to NIH formal policy guidance. The working group issued its final recommendations in December 2018. Additional policy guidance from NIH is expected in the near future. On July 10, 2019, NIH issued “Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components,” again reiterating expectations for disclosure of other support, foreign components, and financial conflicts of interest. NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.” Other Support includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” FAQ can be found here.
