JHU SOM Update on NIH Policy on Foreign
NIH has recently (January 17, 2019) provided clarification of their foreign collaboration policies as follows:
Please remember that existing Public Health
Service (including NIH) conflict of interest regulations are applicable
to payments you may receive from foreign universities, research organizations,
and government agencies.
New Institutional Letter of Support Required for Institutional Training Grant Applications
Effective January 25, 2019, NIH institutional training grants
(T15, T32, T34, T35, T36, T37, T90/R90, TL1, TL4) must include
an letter outlining the institutional policies and procedures JHU
has in place to prevent discriminatory harassment and practices. The
letter is available for download on the SOM Research Administration
Read the full NIH policy notice here: NOT-OD-19-029. Please do not hesitate to contact your assigned Grants team representative if you have questions.
The National Science Foundation ("NSF") released a final
grant term and condition on September 21, 2018, requiring institutions
that receive NSF funds to report to the NSF findings about any NSF
funded principal investigator or co-principal investigator ("PI/co-PI")
of sexual harassment, sexual assault, or other harassment based on
a protected category (such as race, religion, sexual orientation or
national origin). The new reporting requirement applies to NSF grants
awarded on or after October 21, 2018, and to any funding amendments
to existing NSF awards issued on or after October 21, 2018. The NSF
grant term also requires reporting of any administrative action that
Johns Hopkins may take during the pendency of any investigation (including
suspensions, bans from campus or restrictions on the PI/co-PI's ability
to interact with lab members) which may affect the NSF funded work.
The Office of Institutional Equity will work closely with the responsible
research offices at Johns Hopkins to ensure that, should a report
to NSF be required by this new grant term, the appropriate report
is made to the NSF Office of Diversity and Inclusion within ten business
days. Should the NSF require any changes in an award as the result
of a report, the responsible research office will work with the NSF
to implement such changes.
Johns Hopkins is committed to ensuring that its work, research and
teaching environment is free of all forms of harassment and discrimination
based upon a protected class, including sexual misconduct. More information
about the NSF grant term and condition is available here: https://www.nsf.gov/od/odi/term_and_condition.jsp.
More information about Johns Hopkins policies and procedures related
to investigating and responding to allegations of sexual harassment,
sexual assault, or discrimination are available here: http://oie.jhu.edu/.
If you are submitting a revised application
that does not qualify as an A1 resubmission, you are prohibited from
referring to the prior review and must present the application as
a new application. Recently a limited RFA application, submitted because
the revised application was also unfunded, was rejected because the
PI included reference to the prior review and priority score of the
prior resubmitted application. Get more information on this policy
or view Frequently
Asked Questions about resubmissions.
Foreign collaborations involving NIH funding have always required
prior approval. Recent congressional concern over the U.S. losing
IP to foreign countries has led to a reminder announcement in May,
recent close review of RPPR cited publications to confirm compliance
and a special announcement by NIH Director Collins. While most PIs
understand that the policy applies to sub-awards of federal $s for
foreign performance of part of the work scope, the latest announcement
has clarified that the policy also applies to foreign conduct of any
of the work scope regardless of the source of funding. Based on
program officer reviews recently received, such involvement also includes
unfunded collaborations with a foreign entity or a foreign person,
including visiting scholars, graduate students, and fellows funded
by their home country, exchanging material and/or data, or other use
of foreign resources. The announcement in May appears below.
NIH Policy: Foreign Components Added to a Grant to a Domestic or Foreign Organization
Adding a foreign component under a grant to a domestic or foreign organization requires NIH prior approval. For purposes of this policy, a foreign component is defined as performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended. Activities that would meet this definition include the following:
Examples of other grant-related activities that may be significant are:
A change in the performance site within a foreign country or the addition of a performance site in a country other than that specified in the approved application requires NIH awarding IC prior approval. The transfer of work by a domestic grantee to a foreign component also requires awarding IC prior approval. For more information on this policy, visit: http://grants.nih.gov/grants/policy/nihgps_2013/
The next time you are completing your interim or final Research Performance
Progress Report (RPPR) for your NIH grant, pay special attention to
writing the project Outcomes section (Section I). Any project outcomes
submitted on or after October 1, 2017 will be made available to the
general public via NIH's Research Portfolio Online Reporting Tool
Matchmaker is a new extension of the NIH RePORTER website system
that makes it easy to find similar projects already funded by the
NIH. Matchmaker takes user-submitted scientific text, and analyzes
it for relevant terms and concepts and compare those terms and concepts
to other funded research projects from the NIH. Matchmaker then returns
up to 100 similar projects, including a graphical overview highlighting
the study sections that reviewed similar projects, the NIH institutes
and centers that funded the projects, and the activity codes of those
similar projects. More information about Matchmaker and NIH RePORTER
page can be found at http://projectreporter.nih.gov.
You may also view this short
informational video about Matchmaker.
The NIH Office of Extramural Research (OER) has developed several video tutorials to walk researchers through the process of applying for grants. The 4-part series covers the basics of preparing, writing, and submitting an application. Review these video tutorials on the NIH OER website.