Approvals and Disclosures to Federal Agencies

Federal Sponsor Disclosure and Prior Approval Requirements Relevant to International Collaboration

Given governmental concerns regarding undue foreign influence on federally-funded researchers, federal agencies are revising and clarifying their disclosure requirements to ensure federally-funded researchers disclose their relationships and activities with non-US institutions, organizations and funding agencies. Failure to properly and timely disclose foreign relationships and activities may jeopardize current funding and PI-eligibility for future funding. We therefore strongly encourage all faculty members to review their University and federal sponsor disclosure obligations in the context of their international collaborations and affiliations with foreign institutions.

NIH-Specific Guidance

In addition to the specific guidance below, you can also consult this chart developed by NIH, which provides examples of what to disclose to NIH about Senior/Key Personnel on Applications and Awards.

Disclosure of Reimbursed and Sponsored Travel

Travel expenses that are reimbursed to, or paid directly on behalf of, NIH-funded personnel (other than by an excluded organization listed below) must be disclosed in the AURA COI system. Disclosures should be made throughout the year as sponsored travel is received and reported within 30 days of the completion of the sponsored travel. For clarity, travel sponsored or reimbursed by foreign governments and institutions, including foreign universities, must be disclosed.

Disclosure does not need to include the monetary value of the travel, but it must include (1) the purpose of the trip; (2) the identity of the sponsor/organizer; (3) the destination; and (4) the duration.

Exclusions for Sponsored Travel. Excluded from this disclosure requirement is travel reimbursed through the University of Chicago or travel that is sponsored by:

U.S. Federal, state or local government agencies entities
U.S. Institutes of higher education
U.S. Research Institutes affiliated with Institutes of higher education (e.g., MBL)
U.S. academic teaching hospitals and medical centers

NIH clarified its expectations regarding Reimbursed and Sponsored Travel reporting in its October 2012 Notice NOT-OD-13-004 and related FAQ.

Disclosure of Other Support

NIH requests disclosure of “Other Support” as part of its Just-in-Time procedures and in annual research performance progress reports (RPPR). Effective January 25, 2022, NIH will require use of a revised Other Support Format, as described in its March 2021 Notice NOT-OD-21-073 and NOT-OD-21-110. However, NIH is encouraging applicants and recipients to use the updated Other Support format for applications, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs) as of May 25, 2021.

Updated Other Support resources, including FAQs and sample Other Support format pages can be found here. The Other Support Format changes include the following.

Supporting Documentation for Foreign Appointments/Employment: For Other Support submissions that include foreign activities and resources, the University is required to submit copies of contracts, grants or any other agreements specific to senior/key personnel foreign appointments and/or employment with a foreign institution as supporting documentation. NIH has indicated they will review the documents to confirm that all information provided in the Other Support submission is accurate and complete. If the documents are not in English, the University must provide translated copies (machine-read translations are acceptable).

Certification that Other Support Disclosures are Accurate and Complete: Each individual form will need to be electronically signed by the PD/PI or other senior/key personnel each time the form is submitted to the NIH. The original electronic signature must be made available to NIH upon request. NIH has indicated e-signatures will be integrated into their forms starting in 2022. Until then, signatories should use DocuSign or Adobe Acrobat to apply their own e-signature to the form.

Please contact any staff member in URA if you have questions about these requirements or the NIH reporting obligations more generally and check this website for up-to-date information. Accurate and timely Other Support disclosure is critical as NIH requires immediate notification of the cognizant GMS once the University knows that a PI or other Senior/Key personnel on an active NIH grant failed to timely disclose Other Support information outside of Just-in-Time or the RPPR, as applicable.

The NIH describes “Other support” very broadly, to include “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).” Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.

Other Support does not include training awards, prizes, or gifts, with gifts described as “resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return.” NIH does not consider an item or service given with the expectation of an associated time commitment to be a gift and instead views this as an in-kind contribution that must be reported as Other Support.

While the following list is not inclusive of all “Other Support”, investigators should be particularly mindful of the following types of relationships and report them.

Disclosure of Other Appointments

All positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments should be disclosed. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

In addition to disclosure of the appointment itself, if compensation and other monetary support is provided through an appointment (e.g., visiting professorship at a foreign university), these financial terms should be included in the Other Support disclosure.

Per the NIH FAQs, even if a researcher is not receiving monetary compensation under the appointment, if lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts (whether or not such research is supported by Federal funds), the appointment constitutes Other Support. Note, other payments, such as travel or living expenses must also be reported.

Please review the NIH’s supporting documentation requirements for foreign appointments and/or employment with a foreign institution.

Disclosure of Participation in Foreign Talent Programs

Disclosure of Participation in “Foreign Talent Programs”. NIH has indicated that selection to a foreign “talents” or similar-type program constitutes Other Support and therefore must be disclosed. However, the NIH has not provided a definition of these programs. If you have questions or wish to discuss whether a particular activity constitutes a disclosable talent program, contact Mallory Snyder, Director, Research Integrity ((773) 702-4857; mallorysnyder@uchicago.edu). Please note that talent program participation is likely to constitute an outside professional or commercial activity that must be disclosed to and receive prior approval from your Chair and Dean in addition to requiring disclosure under the University’s COI/COC Policy.

Please review the NIH’s supporting documentation requirements for foreign appointments and/or employment with a foreign institution.

In-kind Support

NIH has also clarified that “Other Support” includes non-monetary support, such as laboratory space, personnel, and access to equipment and facilities. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.

Although NIH has clarified that gifts, which it describes as “resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return” are not Other Support, when an item or service is given with the expectation of an associated time commitment, NIH does not consider that to be a gift and instead views this as a form of reportable in-kind support.

Consulting Agreements

Consulting arrangements whereby the faculty member or other senior/key personnel will be conducting research as part of the consulting activities on behalf of or at the facilities of a third party must be disclosed as Other Support. Non-research consulting activities are not considered to be Other Support.

Participation of Visiting Researchers/Scholars

Because NIH has clarified that all resources and other support for the PI and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way (whether or not they request salaries or compensation) must be reported, it appears NIH requires disclosures regarding visiting scholars or visiting scientist working in a laboratory while supported by another organization. This is irrespective of whether such support is provided through the University, another domestic or foreign organization, or directly to the individual visitor that is supporting the research efforts.

With respect to visiting researchers that perform research in University labs, investigators should also be sure to comply with all requirements relating to Export Controls

Support Received Outside of Appointment Period (for 9-month Appointees)

PIs with a 9-month appointment should disclose support received for research they conduct during the year, even if outside of their 9-month appointment. For example, if the PI spends two months at a University outside of the U.S. during the summer conducting research under a foreign award, NIH has indicated this should be disclosed as other support.

Disclosure of a Foreign Component

Obtaining Prior Approval of Foreign Components (including foreign subawardees)

Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports. Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended" Examples of other grant-related activities that may be 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.” NIH has also indicated that NIH-approved foreign subawardees constitute Foreign Components and should be noted as such in all RPPRs.

For additional guidance on Foreign Components, see the NIH July 2019 Notice NOT-OD-19-114 and related FAQ.

How to request prior approval of a Foreign Component

There are multiple ways in which foreign components can be disclosed to NIH, e.g.,

At the Proposal Stage:

Identifying a “foreign component” in an NIH grant application;
Listing a “non-U.S. performance site” in an NIH grant application;
Checking “yes” to the question on the Cover Page Supplement Form at Proposal Submission asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”

During the life of the Award:

Contact your URA Post-Award Administrator to prepare a written Prior Approval Request to the NIH Grants Management Specialist.

Note: if an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as Other Support.

FAQ: Other Support – Foreign Employment/Appointment Agreements

These FAQs are supplemental to those provided by the NIH regarding Other Support and Foreign Components, which are available here: https://grants.nih.gov/faqs#/other-support-and-foreign-components.htm

If your question is not addressed in the NIH FAQs of the University Supplemental FAQs below, please contact: Jennifer Ponting ponting@uchicago.edu or Michael Ludwig mrludwig@uchicago.edu.

Other Support: In-kind Contributions

I have received rare tissue samples as an in-kind contribution toward my research. How should I value these contributions in my Other Support documentation?
- For unique items such as these, you should estimate the value based on the cost of comparable samples from a supplier. If there is no information available about the cost of similar items, you should state, “No market value available.” Note that if the samples will be used for the project being proposed, they should be listed under Facilities and Other Resources.
I received unique materials through a material transfer agreement several years ago. Do I need to disclose them?
- NIH has clarified that only materials provided within the past 3 years, that are still in use, must be included in Other Support.
I am planning to invite a visiting postdoc from another university to spend a year collaborating on research in my laboratory. Do I need to disclose this person in my Other Support? Are there other considerations?
- If this person will be self-funded, through their home institution or otherwise, you need to disclose them as an “in-kind contribution,” because they will be directly supporting your research endeavors. You will need to include information about the source(s) of funding that may be supporting this person. However, if the relationship is solely a mentor/mentee arrangement, with no research activities (e.g., associated time commitment), then this person is not a resource, and does not need to be reported.
- You must also follow all other University requirements for academic visitors, and should screen your institutional and individual collaborators against US restricted party lists (Note: The University currently screens individuals who come as Visiting Scientists, Visiting Scholars and BSD’s External Academic Research Scientists (EARS)). Requests can also be submitted through Service Now here. A response will generally be provided within two business day.
I have graduate students and postdocs in my lab who are self-funded. Do I need to disclose them?
- It depends.
  - If they are working on the project being proposed, they should be disclosed in the Facilities & Other Resources section of the proposal. If they worked on an active NIH-funded project at least one person month during a reporting period, they should be included as “Participants” in section D.1 of the RPPR, regardless of the source of the compensation.
  - If they are working on other projects in the lab, you should include them in Other Support.
  - If they are not contributing to your research at all, but they are simply observing, or working solely on their own projects, then you need not disclose them to NIH.
I am continuing to collaborate with a former graduate student/postdoc who now has their own laboratory at a non-U.S. university. Do I need to disclose this collaboration to NIH?
- If the collaboration is “directly supporting your research endeavors,” it should be disclosed as “Other Support.” That would be the case if, for example, it results in co-authored publications.
- In addition, in some instances, such a collaboration could be considered a “foreign component,” if the collaborator is contributing a significant scientific element to an NIH-supported project from a non-U.S. location (see NIH FAQs regarding foreign component here). In such cases, prior approval would be required. You should work with your URA Post Award manager on any prior approval requests.
I have multiple research collaborations with researchers at other institutions, both domestic and foreign. Do I need to disclose them?
- It depends. If the collaborations will directly support your research endeavors, you should disclose them in Other Support, under In-Kind Contributions. This would be the case if, for example, you would include your collaborator as a coauthor on a publication or as an investigator on a sponsored project. Similarly, if the collaboration involves provision of high-value materials, it should be disclosed like any other In-Kind Contribution.
- If the collaborations do not directly support your research endeavors, then they do not need to be disclosed in Other Support.

Other Support: Internal Funding, Prizes and Clinical Trials

Do I need to disclose internal University awards in Other Support?
- Yes. Internal awards such as pilot grants, seed grants, Provost's Global Faculty Awards, or other internal awards to fund specific research projects must be included. Start-up packages provided to the researcher from the University are not included in Other Support, but start-up packages from outside organizations, including foreign entities, must be included in Other Support.
I understand that prizes are excluded from Other Support. How are prizes distinguished from projects requiring disclosure?
- Prizes are typically awarded to an individual to recognize their overall accomplishments or achievements, and the funds are completely unrestricted. They also typically do not require any reporting or acknowledgement in publications. In contrast, a sponsored project has defined aims and objectives, and the funding must be expended in accordance with the project’s scope. If you have a question about whether a particular item can be excluded as a prize, please contact URA.
How should I disclose clinical trials?
- You should disclose clinical trials in the same way as other projects. Other Support: Outside Consulting Activities
Does consulting need to be included in Other Support?
- Consulting needs to be included in Other Support only where the PI or senior key person is conducting research as part of the consulting engagement that falls outside of the PI or senior key person’s University appointment (i.e., not conducted through a University agreement). Non-research consulting activities are not Other Support.
How do I know whether a consulting engagement “involves the conduct of research?”
- Consulting roles that involve the design, conduct or reporting of research may be considered to involve the “conduct of research.” These would include, for example, consulting roles that warrant co-authorship or result in joint publications. On the other hand, if the engagement is purely advisory, it should not be disclosed as Other Support.
I have a consulting engagement that involves the conduct of research. How should I describe the effort involved in this outside activity?
- Consulting is typically an outside activity that is not part of an individual’s University effort and does not require an effort commitment. For this reason, NIH has stated that, “Consulting should be estimates for the amount paid, rather than time and effort reflected in calendar months. Therefore, it will not count towards the 12 calendar months of effort.” However, as is always the case with respect to outside activities, you must ensure that any consulting engagement meets the University’s conflict of commitment requirements. See the University’s Conflict of Interest and Conflict of Commitment.
What should I do if I have signed an agreement for consulting activities with a foreign organization that is disclosable as Other Support?
- Login to the AURA COI application https://aura.uchicago.edu/ and disclose that an agreement exists. The agreement should be sent to coi@lists.uchicago.edu for review by an institutional official prior to submission to NIH. Any questions or concerns identified in the review will be discussed with you in advance of submission to NIH.
- If the agreement is in a foreign language, the agreement must be translated to English prior to sending the document. The University has negotiated a preferred provider agreement with Multilingual Connections for providing PIs with these translation services. To initiate a service request, contact the dedicated support team at uofc@mlconnections.com. For more information on pricing, turnaround time, and order placement visit the supplier contract announcement page for Multilingual Connections found here.

Biosketch: Positions and Scientific Appointments

What constitutes “Positions and Scientific Appointments” that need to be disclosed in the Biosketch?
- NIH requires disclosure of all current positions and scientific appointments. This includes any current affiliations with foreign entities or governments and also all “titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).” A scientific appointment may include, but is not limited to, participation in study sections, editorial positions, and membership of data safety monitoring committees. If you are uncertain as to whether an activity should be included in the Biosketch, contact your URA Pre Award manager to discuss. NIH requires only current scientific appointments to be disclosed in the Biographical Sketch. Any resources associated with the scientific appointment should be disclosed as in-kind contributions in the Other Support format pages.

Biosketch or Other Support Omissions

I realized that I forgot to include an item in my Other Support or my Biosketch. What should I do?
- Inadvertent omissions happen from time to time and URA has experience addressing omissions with NIH and other federal sponsors. If this happens, you should contact URA as soon as you identify the omission. They will work with you to submit updated information to NIH. NIH expects that we will report updated information within 30 days after it becomes known.

Non-US Subawards

I have a non-U.S. subrecipient for a project. How should the PI on the non-U.S. subaward report Other Support? Do they need to disclose their employment agreements with the subaward recipient institution?
- The PI on the non-U.S. subaward must follow the same rules as U.S. investigators. They do not need to disclose their employment agreements with the subaward recipient institution, but they must disclose any Other Support, including any appointments with additional entities that involve research or access to resources for research endeavors.

NSF-Specific Guidance

NSF’s 2020 Proposal and Award Policies and Procedures Guide (PAPPG), reflects several significant changes regarding Current and Pending Support as well as Biographical Sketches, as detailed below.

Biographical Sketches

Any titled academic, professional, or institutional position or appointment, whether or not remuneration is received. These appointments must be disclosed using this NSF-approved format, for each individual designated as senior personnel on the proposal. NSF has clarified that the following arrangements are disclosable appointments:

Current and Pending Support

Information must be provided about all current and pending support, including the applicable project, any ongoing projects, and for any proposals under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual. Sources include, for example, Federal, State, local, foreign, public or private foundations, non-profits, industrial or other commercial organizations, consulting, or internal funds allocated toward specific projects.

The following arrangements must be disclosed as current and pending support information using this NSF-approved format, for each individual designated as senior personnel on the proposal. NSF has also provided additional clarifications in its FAQ on Current and Pending Support.

In-kind contributions (such as office/laboratory space, equipment, supplies, employees, students). Donated items or services (including those of visiting researchers, whether working on the funded project or not) are reportable as in-kind contributions if the donated item or service is given with the expectation of an associated time commitment by senior personnel.
- If the in-kind contributions are intended for use on the project being proposed to NSF, the information must be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be duplicated in the current and pending support submission
- If the in-kind contributions is NOT intended for use on the project being proposed to NSF it must still be reported in the current and pending support submission. If the time commitment or dollar value is not readily ascertainable, reasonable estimates should be provided.
- If there is a time commitment associated with mentorship of a funded student or visiting researcher involved in your research activities (outside of the proposed research) the underlying funding should be disclosed as in-kind contribution along with the time associated with mentorship
- In-kind contributions that are not intended for use on the project and have no associated time commitment should not be reported in current and pending support.
Outside consulting arrangements that involve the conduct of research as part of the consulting services must be disclosed as current/pending support.
All projects and activities, current or proposed, that require a time commitment for each individual designated as senior personnel on the proposal (no minimum has been established), even if the support received is only in-kind (such as office/laboratory space, equipment, supplies, employees, students).

DOD-Specific Guidance

On March 20, 2019, the Undersecretary of Defense announced new requirements for all new DOD Notices of Funding Opportunities (NFOs) pertaining to new research and research-related educational activities after April 19, 2019. Proposers must submit the following information for all key personnel whether or not the individuals' efforts under the project are to be funded by the DOD:

A list of all current projects the individual is working on.
Any future (pending) support the individual has applied to receive, regardless of the source.
Title and objectives of each of these research projects.
The percentage per year each of the key personnel will devote to the other projects.
The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
Name and address of the agencies and/or other parties supporting the other research projects.
Period of performance for the other research projects.

The above information is to be included in a Senior Key Person Profile form included in all Notices of Funding Opportunities (NFOs), using OMB Form 4040-0001 Research and Related Senior/Key Person Profile (Expanded).

Please see the full March 20, 2019 memo attached for additional details.

Department of Energy (DOE)-Specific Guidance

Department of Energy Directive 486.1A prohibits DOE employees and DOE contractor personnel (which is defined to include joint appointees, subcontractors and individuals performing R&D work within the scope of a prime DOE contract at a DOE site or facility) participation in foreign government talent recruitment programs of countries designated by DOE as a foreign country of risk.

DOE Interim Conflict of Interest Policy

On December 21, 2021, the Department of Energy issued its Interim Conflict of Interest Policy Requirements for Financial Assistance, which sets forth specific disclosure requirements for investigators and recipient organizations receiving DOE financial assistance awards. The policy is “interim” because DOE has indicated it also intends to amend its financial assistance regulations to incorporate requirements to address financial conflict of interest, organizational conflict of interest, and conflicts of commitment.

A brief summary of the Interim Policy requirements for DOE-funded investigators are set forth below. All researchers involved in DOE-funded projects at the University are strongly encouraged to review the Interim Policy and the relevant definitions to ensure they are aware of these new DOE requirements. While these requirements are similar to the existing requirements under the University’s COI/COC Policy, the University is currently evaluating what revisions to its COI/COC Policy are required to align with the DOE’s Interim Policy.

DOE-funded investigators must disclose the following (via the University’s AURA COI System). Please note these DOE disclosure requirements are generally expected to apply only to the principal Investigator and those other individuals who are “responsible for the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE”, DOE program offices have the discretion to expand the definition to include also any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. DOE indicates that any such expanded disclosure obligations will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award.

Significant Financial interests

Significant Financial Interests of the DOE-funded Investigator, and those of the Investigator's spouse and dependent children, must be disclosed to the University, with updates required to be made in AURA within 30 days

DOE defines SFIs as those financial interests that reasonably appear to be related to the Investigator’s institutional responsibilities.
Although the Interim Policy sets a $5000 threshold in its definition of SFI, the University has established a zero threshold for disclosure reporting both in dollar value and in percentage (%) of equity holding, meaning that if the financial interest could reasonably appear to be related to the Investigator’s institutional responsibilities, it must be reported even if its dollar value or percentage is de minimus.
The Interim Policy clarifies that SFIs do not include income from seminars, lectures, or teaching engagements sponsored by or income from service on advisory committees or review panels for, a U.S. Federal, state, or local government agency of the United States, a domestic Institution of Higher Education, or a U.S.-based research institute.

Reimbursed and Sponsored Travel

Any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) related to the individual’s institutional responsibilities.

The disclosure should specify the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration
Note: travel that is reimbursed or sponsored by a U.S. Federal, state, or local government agency of the United States; a U.S. Institution of Higher Education; or a U.S.-based research institute that is affiliated with a U.S. Institution of Higher Education is not required to be disclosed

DOE Current and Pending Support and Biosketches

The instructions for the content of DOE current and pending support and biosketches are specified in the DOE Office of Science FY22 Continuation of Solicitation for the Office of Science Financial Assistance Program at Section VIII (Sections 9 and 11), and briefly summarized below.

Biosketch:

DOE Office of Science requires the use of the format approved by the National Science Foundation (NSF), which may be generated by the Science Experts Network Curriculum Vita (SciENcv), available at https://nsf.gov/bfa/dias/policy/nsfapprovedformats/biosketch.pdf.
Be sure to list all current academic, professional or institutional appointments, foreign or domestic, at the applicant institution or elsewhere, whether or not remuneration is received, and, whether full-time, part-time, or voluntary.

Current and Pending Support:

Current and Pending support is intended to allow the identification of potential duplication, overcommitment, potential conflicts of interest or commitment, and all other sources of support.
The PI and each senior/key person at the prime applicant and any proposed subaward must provide a list of all sponsored activities, awards, and appointments directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses, whether
- paid or unpaid;
- provided as a gift with terms or conditions or provided as a gift without terms or conditions;
- fulltime, part-time, or voluntary;
- faculty, visiting, adjunct, or honorary;
- cash or in-kind;
- foreign or domestic;
- governmental or private-sector;
All foreign government-sponsored talent recruitment programs must be identified in current and pending support.
Details of any obligations, contractual or otherwise, to any program, entity, or organization sponsored by a foreign government must be provided on request to DOE.

Special Note re: Foreign Government Talent Recruitment Programs

Per DOE’s Office of Science FY22 Continuation of Solicitation for the Office of Science Financial Assistance Program, all foreign government sponsored talent recruitment programs must be identified in current and pending support. In addition, Department of Energy Directive 486.1A prohibits DOE employees and DOE contractor personnel (which is defined to include joint appointees, subcontractors and individuals performing R&D work within the scope of a prime DOE contract at a DOE site or facility) participation in foreign government talent recruitment programs of countries designated by DOE as a foreign country of risk.

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