Best Practices for Disclosing Foreign Relationships and Activities

While international collaborations are encouraged and acceptable, researchers should be transparent in all of these engagements.  Below, please find guidance regarding the types of relationships and activities that Oregon State University researchers are expected to disclose:

“Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s grant endeavors. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through OSU, through another institution or provided directly to the researcher. (NIH’s most recent guidance can be found at NOT-OD-19-114. An FAQ can be found here.)

An issue that is garnering a great deal of scrutiny by the federal government is participation in foreign talent programs, such as China’s Thousand Talents Program. Not only should participation in a foreign talent program be disclosed to federal sponsors, OSU researchers should also communicate with their Associate Deans of Research to discuss such activity, even if they previously disclosed their participation to other university officials. Depending on an individual’s research portfolio, he or she may be advised to terminate their affiliation with the foreign talent program.

Under the National Institute of Health (NIH) Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended". The definition of “foreign component” may include a large number of collaborative activities, such as “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.” Other sponsors have similar requirements to disclose foreign support for research.

Foreign components can be disclosed in multiple ways:  

  • Identifying a “foreign component” in an NIH grant application;
  • Listing a “non-U.S. performance site;”
  • Identifying foreign relationships and activities in a biosketch;
  • Answering “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
  • Disclosing financial resources even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a nine-month appointment at OSU spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Sponsored Programs to have the error corrected.

OSU-affiliated investigators must disclose all financial interests related to their research and their institutional responsibilities - including any interests that are based outside of the U.S. - as described in the Research Conflict of Interest (RCOI) program policy.  The university RCOI policy is based on federal regulation requirements described in 42 CFR Part 50, Subpart F, Objectivity of Research.

The ongoing requirement for investigators to include financial interests that are based outside of the U.S. in their disclosures to the university was reiterated in the NIH notice Investigator Disclosures of Foreign Financial Interests NOT-OD-18-160, published March 30, 2018. 

See also: Is an Investigator required to disclose all financial interests received from a non-U.S. Institution of higher education or the government of another country?

OSU-affiliated investigators can access their RCOI disclosure form in iRIS, and update it as needed.  If you have questions or need assistance, please contact the RCOI program office at, or call (541) 737-2762, or visit the RCOI website:

There are multiple types of institutional disclosures that may be required:

Conflicts of Interest in Research:

Conflicts of Interest in Research (RCOIs) are disclosed to the institution via OSU’s online submission system, iRIS, which can be accessed via this link:

  • RCOI disclosures must account for the investigator’s significant financial interests - and those of their spouse/domestic partner and dependents - when those interests relate to the investigator’s research program or their institutional responsibilities.  This includes interests based outside of the U.S. as well as those based within the U.S.
  • RCOI disclosures must be updated at least annually, and sometimes more often.  When an investigator acquires a new financial interest related to their research or institutional responsibilities, they must update their RCOI disclosure to include the new interest within 30 days.
  • Contact the RCOI Program Administrator with questions:, (541) 737-2762, or visit the RCOI website at:


Conflicts of Commitment:

Conflicts of Commitment (COCs) are disclosed according to OSU’s COC Policy and the related Outside Activities Request form.  More information is available at the links below:


See also: Inventions and Intellectual Property disclosures, below.


Conflicts of Interest in Procurement and Contracts:

Conflicts of interest in institutional procurement of goods and services are disclosed according to OSU’s Procurement and Contract Services (PaCS) policy and procedures:

Contact the Office of Information Services regarding any compromised accounts or other IT threats.

Promptly report inventions or intellectual property to Oregon State University Advantage.