Disclosing Foreign Support and International Activities: Difference between revisions

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[[Compliance Program]] | [[Compliance Hotline]] | [[Investigations by Third Parties]] | [[Research Integrity]] | [[Export Control]] | [[Code of Conduct]] | [[Use of Human Anatomical Material]] | [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] | [[Contracts]] | [[Conflict of Interest]] | [[Red Flag Identity Theft Prevention Program]] | [[Principles of Financial Stewardship]] | [[Human Tissue Use and Transfer]] | [[International Research Policy]] | [[Health Care Vendor Interactions]] | [[Credit Hour Definition]] | [[Whistleblower]]
[[Compliance Program]] | [[Compliance Hotline]] | [[Investigations by Third Parties]] | [[Research Integrity]] | [[Export Control]] | [[Code of Conduct]] | [[Use of Human Anatomical Material]] | [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] | [[Contracts]] | [[Conflict of Interest]] | [[Red Flag Identity Theft Prevention Program]] | [[Principles of Financial Stewardship]] | [[Human Tissue Use and Transfer]] | [[Disclosing Foreign Support and International Activities]] | [[Health Care Vendor Interactions]] | [[Credit Hour Definition]] | [[Whistleblower]] | [[Electronic Digital Signatures and Records]]<br />
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Policy No.: '''8014'''<br />
Policy No.: '''8014'''<br />
Effective Date: '''06/26/15'''<br />
Effective Date: '''06/26/15'''<br />
Revised Date: '''12/16/19 DRAFT '''<br />
Revised Date: '''07/09/24'''<br />
Reviewed Date: ''' ''' <br /><br />
Reviewed Date: '''07/09/24 ''' <br /><br />


'''<big>Disclosing Foreign Support and International Activities</big>''' <br /><br />
'''<big>Disclosing Foreign Support and International Activities</big>''' <br /><br />
==Authority==
==Authority==
Statutes, regulations, and policies related to disclosures of foreign support and relationships with foreign entities or individuals include, but are not limited to:
Statutes, regulations, and policies related to disclosures of foreign support and relationships with foreign entities or individuals include, but are not limited to:
*[https://uscode.house.gov/view.xhtml?path=/prelim@title42/chapter163/subchapter6/partC&edition=prelim 42 U.S.C. §§ 19232 and 19237]
*Nebraska Conflict of Interest Statute, [https://nebraskalegislature.gov/laws/statutes.php?statute=49-1493 Neb. Rev. Stat. §49-1493]  
*Nebraska Conflict of Interest Statute, [https://nebraskalegislature.gov/laws/statutes.php?statute=49-1493 Neb. Rev. Stat. §49-1493]  
*Board of Regents Bylaws [https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/board-of-regents-bylaws.pdf?la=en sections 3.4.5, 3.8 and 3.10]
*Board of Regents Bylaws [https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/bor.pdf sections 3.4.5, 3.8 and 3.10]
*[https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/board-of-regents-policies.pdf?la=en Board of Regents Policy] RP-3.2.8, Conflict of Interest and conflict of Commitment
*[https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/board-of-regents-policies.pdf?la=en Board of Regents Policy] RP-3.2.8, Conflict of Interest and Conflict of Commitment
*[https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/board-of-regents-policies.pdf?la=en Board of Regents Policy] RP-4.4, Intellectual Property
*[https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/board-governing-documents/board-of-regents-policies.pdf?la=en Board of Regents Policy] RP-4.4, Intellectual Property
 
*[https://nebraska.edu/-/media/unca/docs/offices-and-policies/policies/policies/university-of-nebraska-travel-policy.pdf University of Nebraska Travel Policy TO-01]
*
*UNMC Policy No. 1098, [[Corrective/Disciplinary Action]]
*UNMC Policy No. 1098, [[Corrective/Disciplinary Action]]
*UNMC Policy No. 6014, [[Travel and Reimbursement]]
*UNMC Policy No. 6014, [[Travel and Reimbursement]]
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===Support(ed)===
===Support(ed)===
"Support(ed)" includes any financial or non-financial support for any aspect of any activity. Non-financial support may include exchanges of data or materials; donations of equipment, software, or other materials; or payment of travel and related expenses, including meals and lodging.
"Support(ed)" includes any financial or non-financial support for any aspect of any activity. Non-financial support may include exchanges of data or materials; donations of equipment, software, or other materials; or payment of travel and related expenses, including meals and lodging.
===Activities Supported by Foreign Entities or Individuals===
===Activities Supported by Foreign Entities or Foreign Individuals===
"Activities Supported by Foreign Entities or Individuals" are any activity for which a Foreign Entity or Foreign Individual provides financial or non-financial Support, including without limitation:
"Activities Supported by Foreign Entities or Foreign Individuals" are any activity for which a Foreign Entity or Foreign Individual provides financial or non-financial Support, including without limitation:
:a. Serving as an employee or agent of a Foreign Entity or Foreign Individual;
:a. Serving as an employee or agent of a Foreign Entity or Foreign Individual, including honorary and adjunct positions, whether or not compensation is received;
:b. Collaborating in research with a Foreign Entity or Foreign Individual, including designing experiments, collecting and analyzing data, preparing manuscripts for presentation or other publication, and presenting or otherwise publishing the results of research;
:b. Collaborating in research with a Foreign Entity or Foreign Individual, including designing experiments, collecting and analyzing data, preparing manuscripts for presentation or other publication, and presenting or otherwise publishing the results of research;
:c. Providing consulting services to a Foreign Entity or Foreign Individual, whether or not such services are compensated;
:c. Providing consulting services to a Foreign Entity or Foreign Individual, whether or not compensation is received;
:d. Developing partnerships or other business relationships with a Foreign Entity or Foreign Individual;
:d. Developing partnerships or other business relationships with a Foreign Entity or Foreign Individual;
:e. Accepting gifts, including donations of funding, accommodations, travel-related expenses, equipment, software, or any materials to be used in support of research or clinical activities, from a Foreign Entity or Foreign Individual; and
:e. Accepting gifts, including donations of funding, accommodations, travel-related expenses, equipment, software, or any materials to be used in support of research or clinical activities, from a Foreign Entity or Foreign Individual; and
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When applying for external research funding, UNMC personnel must also comply with any disclosure requirements imposed by the funding organization. In many cases, this may require making separate disclosures to UNMC in addition to any disclosures required by the external funding organization.
When applying for external research funding, UNMC personnel must also comply with any disclosure requirements imposed by the funding organization. In many cases, this may require making separate disclosures to UNMC in addition to any disclosures required by the external funding organization.
==Violations==
==Violations==
Failure to comply with this policy will result in corrective or disciplinary action as provided under UNMC Policy No. 1098, [[Corrective/Disciplinary Action]] including termination, dismissal, or exclusion from participation in federally funded activities.
Failure to comply with this policy will result in corrective or disciplinary action as provided under UNMC Policy No. 1098, [[Corrective/Disciplinary Action]], including termination, dismissal, or exclusion from participation in federally funded activities.


==Additional Information==
==Additional Information==
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*Contact the [mailto:exportcontrol@unmc.edu Export Control Director]
*Contact the [mailto:exportcontrol@unmc.edu Export Control Director]
*Department of Energy Order 486.1, [https://www.directives.doe.gov/directives-documents/400-series/0486.1-border/@@images/file Department of Energy Foreign Government Talent Recruitment Programs]
*Department of Energy Order 486.1, [https://www.directives.doe.gov/directives-documents/400-series/0486.1-border/@@images/file Department of Energy Foreign Government Talent Recruitment Programs]
*[https://grants.nih.gov/policy/foreign-interference/requirements-for-disclosure#:~:text=NIH%20requires%20the%20disclosure%20of%20all%20sources%20of,for%20senior%2Fkey%20personnel%20on%20research%20applications%20and%20awards. NIH Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest]
*NIH Notice No. [https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html NOT-OD-19-114]
*NIH Notice No. [https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html NOT-OD-19-114]
*White House Office of Science and Technology Policy Letter to the United States Research Community (Sept. 16, 2019) [https://www.whitehouse.gov/wp-content/uploads/2019/09/OSTP-letter-to-the-US-research-community-september-2019.pdf (“Policy Letter”)]
*[https://grants.nih.gov/grants/guide/notice-files/NOT-OD-23-139.html NOT-OD-23-139]
*NSF Letter [https://www.nsf.gov/pubs/2019/nsf19200/research_protection.pdf 19-200]
*NSF Letter [https://www.nsf.gov/pubs/2019/nsf19200/research_protection.pdf 19-200]




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