Undisclosed working relationships between scholars in U.S. institutions and non-domestic entities (e.g., universities, companies, and governments) have increasingly been of concern to American science agencies. To support faculty in the required federal funding agency disclosures and to assist faculty in addressing any potential conflicts, the Office of Research and Innovation has developed the Global Activities e-Disclosure (GAED) web-based form to supplement other required disclosures. The FAQs below are intended to address some of the common questions that faculty may have while completing their disclosure. Step-by-step instructions on completing and editing the GAED form are provided in the Global Activities e-Disclosure job aid. For more information on the MSU’s implementation of the form, please see the Provost and VPRI letter. Disclosure requirements by agency, including examples of what must be included, can be found on the Current and Pending/Other Support Requirements by Sponsor webpage. If you have questions about how the disclosure should impact a specific project, please reach out to your assigned team in Office of Sponsored Programs at the proposal or negotiation stage or firstname.lastname@example.org in CGA at the award stage. Questions as they overlap with the Faculty Conflict of Interest Disclosure form should be directed to: FCOIIO@msu.edu.
When does the GAED need to be completed?
The form must be completed or edited within thirty days of acquiring any new resources or relationships with any non-U.S. entities or any change in current global activities.
Do I need to disclose any
of my collaborations or affiliations with entities that are located within the U.S.?
In some cases, non-domestic entities may have operations or locations within the U.S., and these would need to be reported. Some examples may include:
- A legal entity created under the laws of one or more non-U.S. governments, such as a company incorporated in another country that has locations or operations within the United States
- Any subsidiaries, affiliates, or agents of non-U.S. governments or legal entities
- A domestic entity acting on behalf of non-U.S. government or entity
Do large, well-known international collaborations, such as IceCube, ATLAS, and JINA, need to be disclosed?
Involvement in these types of collaborative groups should be disclosed except if the collaboration is funded under a Sponsored Program that was reviewed by OSP or Business Connect (BC). An acceptable way to simplify adding the Global Activity would be to name the collaborative group and provide a link to a site that identifies the collaborators. In order for MSU staff to understand and consider potential advice, the information referenced should be displayed in English.
I know 20 people in country X with whom I discuss topics related to my discipline, but I have an active collaboration where data are discussed with five people. Do I need to make 20 disclosures?
Based on the information provided you would need to disclose the five active collaborators. Additional information should be considered when determining whether any of the other fifteen should be disclosed. For instance, general discussions with colleagues related to your discipline may not need to be disclosed. On the other hand, please be aware that the disclosure should align with what we are learning from the Federal government on what is considered a significant scientific element (SSE). One sponsor, NIH, has indicated that prior approval is required when performance of a significant scientific element of the NIH-supported project is outside of the United States. They have given examples of SSE, such as:
- collaborating when it is anticipated that the discussions may lead to a joint publication
- use of facilities or instrumentation at a foreign site
- receipt of financial support or resources from a foreign entity
Do I need to add a separate disclosure for each of my various international collaborators?
Each organization that you collaborate with should be disclosed as a separate global activity. If you have multiple collaborators at one organization, the names of the collaborators can be listed in the Description field of the Global Activities e-Disclosure. We are looking into adding functionality that would allow you to copy a global activity, allowing for ease in entering collaborators that are from different organizations.
Active Research Collaboration – Researchers who are currently pursuing mutually beneficial research that may result in new knowledge, shared data or co-authorship. The word “Active” distinguishes collaborations that are currently taking place, and may need to be reported on Current & Pending Support.
Sponsored Project - A sponsored project is an activity defined in scope and goal generally undertaken by University faculty, often with the involvement of students and staff, utilizing University facilities and equipment and conducted with financial and/or other valuable support from an external sponsoring entity. For additional information on Sponsored Projects at MSU, visit the Manual of Business Procedures, section 315.