Best Practices – Foreign Component

            Best Practices for the UNC School of Medicine Researcher
Awareness of Foreign Components

1. Foreign Component: Overview of Awareness and Understanding

1. The University of North Carolina at Chapel Hill strongly supports and encourages international collaboration and values our partnerships with universities and other organizations worldwide.
2. Federal funding agencies have advised that there will be a heightened focus on ensuring compliance with respect to mandatory reporting of all sources of research support, financial interests, and relevant affiliations, as well as steps to reduce risk to Intellectual Property security.
3. All UNC Researchers must have a heightened awareness and interest in understanding the relationships they may have with foreign governments, entities, universities or collaborators..

2. Reach out to the School of Medicine’s, Sponsored Programs Office (SPO) leadership team if you have a question or to request an informational meeting as needed. SPO – Sherry Whitaker – grants@unc.edu

3. “Significant scientific element or segment of a project” is the phrase used to evaluate the elements of the project that is being conducted outside the United States whether or not NIH Grant funds are expended.

1. Activities that ARE considered significant are:
   –  Involvement of Human or Animal Subjects
   –  Extensive Foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities
2. Activities that MAY BE considered significant are:
   –  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.

4. The University will make the initial determination of “Significance”, but the NIH will make the final determination.

5. It is possible to determine the activity is NOT considered a Foreign Component, yet it could be listed as a foreign resource, within the Other Support document.

6. Reach out to the export control officer at exportcontrol@unc.edu if you would like to review your research to ensure compliance with the export control regulations.

Details and resources available for Awareness of Foreign Components:

• New Sample Template for NIH Other Support
• Guidance on Science and Security
• Science and Security slides Webinar presentation 04/09/2020
• Listen to the Webinar Recording (Audio / Video / Transcript) of the slides presented on 04/09/2020
• The NIH Other Support document SPO Best Practices