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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.

We encourage initial completion of the form by March 8, 2021, and annually thereafter. 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:

  • An individual who is not a citizen of the U.S. who is residing within the United States
  • 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.

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