Dear Colleagues:

I am writing with important guidance about federal and institutional policies related to foreign collaborations, disclosure requirements, and authorship. As this situation is very fluid, we will post regular updates to the Federal Updates webpage and encourage you to visit the page for the latest guidance.

Federal grants come with multiple terms, conditions, and policies, for which Brown University (i.e., the grant recipient) must comply. These include NSF’s Other Support Disclosure requirements, the NIH’s Other Support Disclosure policies,  Foreign Component Policy, and Stevens Amendment, and NASA’s special restrictions related to China (the “Wolf Amendment”, which prohibits NASA funds from being used for bilateral research engagements with China).

There are several important updates to these policies that reflect the federal agencies’ increased efforts in monitoring our compliance. In many instances, agencies are reviewing academic publications as part of their compliance checks. Publications that cite funding from a specific federal grant and that include co-authors from other countries may be flagged for further review, for compliance with (for example) the NIH’s Foreign Component Policy or NASA’s China restrictions. NIH supported publications may also be reviewed for compliance with the Stevens Amendment. 

Considering the increased focus on compliance, I want to urge researchers applying for federal funding to pay particular attention to the agency’s policies and requirements related to disclosure and foreign collaborations, which can be found on the Agency-Specific Proposal Guidance on the Division of Research’s website.

Researchers funded by the National Health Institutes (NIH) should pay particular attention to NIH’s most recent Notice on Foreign Components (NOT-OD-26-084) and the Stevens Amendment (NIH Grants Policy Statement 4.2.1). In the Notice on Foreign Components, NIH states that they consider most instances of foreign co-authorship to represent a foreign component. While there may be some exceptions, NIH specifically directs award recipients to report a foreign co-authorship to the funding institute or Center as soon as they are aware of it to determine what steps, if any, need to be taken. Under the Stevens Amendment, each publication describing research supported by the Department of Health and Human Services (DHHS), which includes NIH, must include specific acknowledgement of the NIH grant support, including the level of NIH funding, as well as a disclaimer statement. More information can be found on DoR’s website.

Finally, I want to take the opportunity to remind the community of the standards and best practices related to authorship. A summary of these standards is attached for reference. Brown’s Authorship Guidelines can also be found on the Division of Research’s website. 

Please direct any questions to  VP_research@brown.edu and visit the Federal Updates page for the latest guidance.

Thank you. 

Greg Hirth (Vice President for Research)