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Global Activities e-Disclosure FAQs

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 awards@cga.msu.edu 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.

FAQs

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All MSU investigators (PIs, Co-PIs, Co-Is) and Key Personnel included on federal proposal submissions are required to complete the GAED.

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.

“Non-domestic” refers to all countries except the U.S. and its territories.

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

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.

You are responsible for disclosing research collaborations that directly impact your research endeavors or publications. If you are working together to solve a problem, you are using or letting the colleague use data or tools from research, or the discussions may lead to joint authorship, these are examples of “uncompensated collaborations” that should be reported. In the interest of full transparency, you should err on the side of disclosure.

Yes, this relationship would need to be disclosed. The collaborating scientist’s organization should be disclosed in the Organization Name field and the Type of Activity would be “teaching or research collaboration.” The name of the scientist(s) should be included in the Description of Activity field with a brief explanation of the collaboration.

Yes, this should be disclosed. The collaborating institution should be listed in the Organization Name field of the GAED and the time commitment associated with teaching the student the technique should be reported. The name of the student and a brief explanation of the arrangement should be included in the Description of Activity field of the GAED.

The NIH expects disclosure of travel funding from a foreign institution or government if the value is equal to or greater than $5,000 within a one-year period, so MSU has incorporated the same threshold for the GAED. Although disclosure is not required at lower amounts, caution should still be observed. For instance, resources that involve time commitments need to be disclosed, and faculty should not accept resources from entities that are on any of the Federal restricted party lists.

Yes, this should be disclosed if the value of the travel being covered is equal to or greater than $5,000 within a one-year period.

Yes, global activities that take place during non-duty periods must be disclosed.

No. Only current and pending activities (existing and proposed) need to be reported on the GAED.

No.  Sponsored projects that have routed through MSU’s Sponsored Research System (i.e. Kuali Coeus) do not have to be reported on the GAED.  Collaborations with non-domestic entities need to be identified in the grant application, or if added post-award, prior approval may need to be requested.  For instance, if NIH funding, performance of a significant scientific element of the NIH-supported project is outside of the United States then this is considered a foreign component and would need prior approval from the Agency.  Please check with your OSP Proposal Team if you have questions on what needs to be disclosed in a grant application, or with the CGA Awards Group if you have questions on what needs to be disclosed post-award.

No. Visiting scholars that are 100% funded on sponsored research projects awarded to MSU do not need to be disclosed on the GAED. If visiting scholars change their appointment, and are no longer paid through a MSU sponsored project, they would then need to be disclosed.

The GAED disclosure can be updated or corrected. If you select “Yes” to the main question, you can click on the “Edit” button at the bottom right of your previously submitted disclosure, as shown in the screenshot below.

Yes, I need to add/edit a global activities disclosure statement highlighted above an example disclosure and Edit button

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  

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.

Yes, new global activities must be disclosed within thirty days of acquiring new resources or relationships with any non-U.S. entities. Click the Add a Global Activity button to add a new global activity, as shown in the screenshot below.

Add a Global Activitiy Disclosure button highlighted on the Global Activities e-Disclosure form

If you know you will be compensated, but are unsure of the amount, you can estimate the amount or add a note in the Description field. If you will not be paid, enter $0.

If the organization that is hosting the conference is non-domestic, then your participation on the advisory committee for putting together the conference should be disclosed. The hosting organization would be listed as the Organization Name.

The organizations of individuals that are included on the same committee with you don’t inherently need to be disclosed on the GAED. Active research collaborations* with these individuals would need to be disclosed (under the name of their organization).

If the hosting organization or institution is located in another country, this should be disclosed in the Global Activities e-Disclosure. You do not need to disclose the institutions or countries of the individual attendees, unless you develop an active research collaboration* with them.

You only need to disclose the organization of international co-authors with whom you have an affiliation or active research collaboration.

Definitions

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.

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