International Research & Collaborations

The UWL Export Controls Screening Survey must be completed by UWL faculty, staff, and students planning to travel internationally. This enables the UWL Export Controls Officer and other offices to assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Traveling with Technology: Using laptops, email, and other technology outside the US can entail elevated risks of data compromise or loss. For best practices to mitigate these risks, refer to the International Cybersecurity KB article for guidance on securing your data and devices while traveling abroad.

Health Concerns: It is recommended that employees check with their health provider well in advance of any international travel to ensure all necessary vaccines are up to date. Be aware if specific vaccines are required/recommended for your destinations these often must be given a month or more before travel.

Students: UWL International Education & Engagement (IEE) provides resources and support for university-sponsored student travel. It is important that student travelers understand university requirements before planning travel. Additionally, it must be remembered that UW System policy requires all students who travel abroad under university sponsorship to enroll in CISI, the university’s medical, health and evacuation insurance. Contact IEE for additional information.

Refer to the International Education & Engagement (IEE) international travel resources for additional guidance.

US export control regulations can include restrictions or prohibitions with whom US researchers can collaborate, share data, exchange research materials, etc. These restrictions can apply to particular international individuals, organizations, and/or countries as well as particular data, information, research materials, technology, equipment, and/or components.

Before work or activities take place with international collaborators, either domestically or abroad, the UWL Export Controls Screening Survey must be completed by UWL faculty, staff, and students planning to perform the work. This includes all planned work with international individual collaborators (faculty, staff, students, or others) or organizations. In addition to research collaborations, this includes planning to share, exchange, transport, or ship data, information, supplies, research materials, or equipment with international individuals or organizations (domestically or abroad, virtually or in-person). Federal export controls regulations include limits on what can be shipped out of the country and to whom it can be shipped, limits on information access for certain foreign nationals and/or organizations, and license requirements for shipping/sharing some items or information abroad. After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Activities or collaboration with individuals or organizations associated with foreign countries of concern (FCOC), as defined by the US Department of State, are subject to additional requirements and scrutiny at the university, UW System, state, and federal levels. Examples of current FCOCs (as of October 31, 2025) include Burma, China, Cuba, Eritrea, Iran, North Korea, Nicaragua, Nigeria, Pakistan, Russia, Saudi Arabia, Tajikistan, and Turkmenistan. Federally designated FCOCs change over time, and the US Department of State should be consulted for the most up-to-date list.

Per UWSA policy, proposed agreements with individuals or entities associated with FCOCs are subject to a risk assessment and review process conducted by the campus FCOC Committee, Chancellor, UWSA Office of General Counsel, UWSA FCOC Review Group, and UWSA President. All FCOC agreements require the approval of the UWSA President. University personnel should plan well in advance to allow sufficient time for the review process, which should be initiated through the applicable form below:

• Plans to travel internationally, work with international collaborators, or exchange data, equipment, or research materials with international collaborators: Submit a UWL Export Controls Screening Survey.
• Software purchases: Submit a UWL Software Request Form.

For additional information, see Export Controls & Foreign Countries of Concern Overview and FAQs.

The Fulbright Scholar Program offers opportunities to pursue international teaching and research as well as to bring global expertise to campus. The Fulbright US Scholar Program offers more than 380 awards in over 120 countries for US citizens to conduct research, teach, and carry out professional projects around the world. Through the Fulbright opportunities for non-US scholars, US institutions can engage scholars from more than 100 countries through the Visiting Scholars Program, Scholar-in-Residence Program, and Outreach Lecturing Fund.

If interested in any Fulbright program, contact the UWL Fulbright Scholar Liaison in International Education & Engagement. Faculty interested in applying for the Fulbright US Scholar Program should also meet with their chair, dean, and HR prior to applying; faculty are encouraged to seek a sabbatical if applying for a Fulbright to avoid any interruption of benefits. Refer to the UWL sabbatical guidance for more information.

Before traveling internationally or any activities take place with international collaborators (domestically or abroad), the UWL Export Controls Screening Survey must be completed by UWL faculty, staff, and students planning to travel or perform the work. This enables the UWL Export Controls Officer and other offices to assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Some cooperative research projects may require a dual/joint review between UWL’s Institutional Review Board (IRB) and the other institution’s IRB or appropriate human subjects research authority. One such scenario is human subjects research conducted internationally. It is the responsibility of UWL researchers to know what ethical considerations and legal requirements apply when conducting research abroad. Refer to the federal Office for Human Research Protections’ (OHRP) international resources for general information regarding the country or countries in which you intend to conduct research.

It is strongly recommended that researchers contact the relevant Foreign Embassy or Consulate located in the US to discuss their research plan prior to traveling. They may be able to assist you in obtaining the appropriate type of visa. Some foreign governments will not allow researchers to obtain these visas at customs and may subsequently bar the researcher from entering the country.

• If your research involves an international collaborator(s) or participants in another country, you must contact the International Office of any university sponsoring you, your collaborator(s), and/or your participants (e.g., their student population). For research involving an international co-PI(s), UWL and the international institution must enter into a joint review arrangement OR the UWL-affiliated researcher must provide proof (e.g., email correspondence with a designated official, such as a member of their research office or university leadership) of the international institution’s willingness to rely on UWL’s Institutional Review Board (IRB) for oversight as part of the protocol materials submitted to UWL’s IRB. The UWL Export Control Screening Survey MUST also be completed by you, as the researcher, on behalf of your international collaborators.
• If you have no international collaborators and participants are members of the general public, it is still advisable to contact a local university or organization (e.g., NGOs) that is familiar with the desired participant population so that they can help you identify the ethical regulations that must be observed for your research. NOTE: If university/organization support is required in the location where you intend to conduct research, you must include documentation of their support in your IRB proposal.
• If your research involves indigenous populations in other countries, you must also obtain written permission from their Tribe’s/Nation’s local representatives in ways that are accessible to them (e.g., in their own language, either verbally or written). See the UWL IRB Researcher’s Guide for the Submission of Protocols, Research Involving Indigenous Tribes/First Nations section for more guidance on working with Tribes/Nations, both international and sovereign.

Do not assume that no ethical considerations or legal requirements apply for research in other countries, regardless of their socioeconomic status. Even if your research is not intrusive or clinical in nature, it is always advisable to contact a university/higher educational institution in the relevant country. Best practice may include working with a co-PI from a local university or organization.

Refer to the UWL IRB Researcher’s Guide for the Submission of Protocols and IRB website for more information. Contact the IRB (irb@uwlax.edu, 608.785.8044) with questions.

Laboratories that plan to import or export biological-source research materials should first contact the UWL Institutional Biosafety Committee (IBC). Permits from federal agencies in the US are often required for import or export of such materials. Specific language is often required on shipping documentation for incoming items that don’t require an import permit. If laboratories are exporting biological materials, the recipient should verify that they are in compliance with the destination country’s applicable import regulations. In addition, individuals that are shipping biological materials may be required to have a current biological Hazardous Material Shipping certification. Sending or receiving biological research materials also requires a material transfer agreement (MTA) to be established between the institution sending the material and the institution receiving the material. The process for establishing an MTA is outlined on the Assistance with Contracts webpage.

The  Export Controls Screening Survey must be completed by any UWL faculty, staff, and students planning to share, exchange, transport, or ship information, supplies, research materials, or equipment to/from foreign individuals or organizations (domestically or abroad, virtually or in person). After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

The FBI and other federal law enforcement agencies have increased their surveillance efforts to identify transport of research materials and verify that those exports comply with federal laws. We’re told that these efforts are part of a nation-wide enforcement action to control the transport of biological materials that may present a threat to our national security, or reduce the theft of intellectual property developed in the US, much of it with federal funds.

When sending tangible research materials outside the US, researchers must ensure that the materials are sent out under a material transfer agreement (MTA) between the institution sending the material and the institution receiving the material. Related research compliance requirements (e.g., approved IBC/IACUC/IRB protocols, IP considerations) must be fulfilled before an MTA can be finalized. The process for establishing an MTA is outlined on the Assistance with Contracts webpage.

The  Export Controls Screening Survey must be completed by any UWL faculty, staff, and students planning to share, exchange, transport, or ship information, supplies, research materials, or equipment to/from foreign individuals or organizations (domestically or abroad, virtually or in person). After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Generally, laptops, smartphones, and other common devices can be transported or traveled with internationally without restrictions. Individuals should, however, be mindful that using laptops, email, and other technology outside the US can entail elevated risks of data compromise or loss. For best practices to protect sensitive data and mitigate these risks, refer to the International Cybersecurity KB article for guidance on securing your data and devices while traveling abroad.

Specialized research equipment may require special federal licenses or permits. It may also be restricted or prohibited to transport to or travel with in certain countries due to US export control regulations.

The UWL Export Controls Screening Survey must be completed by UWL faculty, staff, and students planning to share, exchange, transport, or ship data, information, supplies, research materials, or equipment with international individuals or organizations (domestically or abroad, virtually or in-person) well in advance of planned activities. Federal export controls regulations include limits on what can be shipped out of the country and to whom it can be shipped, limits on information access for certain foreign nationals and/or organizations, and license requirements for shipping some items or information abroad. After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations.

If a license or permit is required for transporting equipment, it can take several months to apply for and acquire it from the appropriate federal agency. There are often additional costs for acquiring such licenses or permits that should be accounted for when planning research and travel expenses. Individuals should account for this in their research and travel plans and begin the process as early as possible. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Under UW System and university policy, all inventions discovered by faculty, staff, or students on appointment while pursuing their university duties, or on university premises, or with university supplies or equipment must be disclosed to the WiSys Technology Foundation. See UWL Intellectual Property, Inventions, and Patents guidance and UW System Administrative (UWSA) Policy 346: Patents and Inventions. Once an invention is disclosed, UWL's WiSys Regional Associate will conduct an equity review to ensure that the proprietary rights and responsibilities of the university, our personnel, and outside parties are honored. To address IP considerations when working with international collaborators, consult early with ORSP and the WiSys Regional Associate.

University personnel may participate in sponsored research projects that necessitate either funded or non-funded agreements to be negotiated with outside entities. Offices such as ORSP, International Education & Engagement, and Business Services review and negotiate this agreements to ensure that the interests of the PI, university, and state are all adequately protected and that the legal obligations of the agreement do not conflict with the university's mission or policies. When researchers engage in sponsored projects with any entities, including foreign entities, they should be sure to:

• Work with the appropriate university offices to initiate agreements between UWL and the outside institution. See the Assistance with Contracts webpage for guidance.
• Properly attribute UWL and the outside institution in publications resulting from sponsored projects.

Export Controls: Before work or activities take place with international collaborators, either domestically or abroad, the UWL Export Controls Screening Survey must be completed by UWL faculty, staff, and students planning to perform the work. This includes all planned work with international individual collaborators (faculty, staff, students, or others) or organizations. In addition to research collaborations, this includes planning to share, exchange, transport, or ship data, information, supplies, research materials, or equipment with international individuals or organizations (domestically or abroad, virtually or in-person). Federal export controls regulations include limits on what can be shipped out of the country and to whom it can be shipped, limits on information access for certain foreign nationals and/or organizations, and license requirements for shipping/sharing some items or information abroad. After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

Foreign Countries of Concern: Agreements with individuals or organizations associated with foreign countries of concern (FCOC), as defined by the US Department of State, are subject to additional requirements and scrutiny at the university, UW System, state, and federal levels. Examples of current FCOCs (as of October 31, 2025) include Burma, China, Cuba, Eritrea, Iran, North Korea, Nicaragua, Nigeria, Pakistan, Russia, Saudi Arabia, Tajikistan, and Turkmenistan. Federally designated FCOCs change over time, and the US Department of State should be consulted for the most up-to-date list.

Per UWSA policy, proposed agreements with individuals or entities associated with FCOCs are subject to a risk assessment and review process conducted by the campus FCOC Committee, Chancellor, UWSA Office of General Counsel, UWSA FCOC Review Group, and UWSA President. All FCOC agreements require the approval of the UWSA President. University personnel should plan well in advance to allow sufficient time for the review process, which should be initiated through the applicable form below:

• Plans to travel internationally, work with international collaborators, or exchange data, equipment, or research materials with international collaborators: Submit a UWL Export Controls Screening Survey.
• Software purchases: Submit a UWL Software Request Form.

For additional information, see Export Controls & Foreign Countries of Concern Overview and FAQs.

Additional Compliance Requirements: Agreements with international entities are subject to additional reporting and disclosure requirements, including but not limited to the following:

• Disclosures of current, pending, and other support to sponsors
  • Depending on sponsor guidelines, this may be required at the time of proposal or immediately prior to award notification (e.g., just in time).
  • Refer to the UWL Disclosures of Other Support policy and procedures for more information.
• ED Section 117 reporting
• NSF Foreign Financial Disclosure Reporting

Foreign scientists and scholars are a welcome addition to our campus, and the university supports such collaborations. Departments are responsible for verifying the employment eligibility and/or proper US immigration status of their visiting scientists and scholars. Please contact Human Resources and International Education & Engagement  for assistance with any immigration or visa-related issues.

UWL personnel planning to invite international visiting scholars must first complete the UWL Export Controls Screening Survey. After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article. 

Faculty and staff developing non-research-related international agreements, which typically are non-monetary, non-binding documents that formalize an institution-to-institution partnership with a foreign entity (e.g. Memorandum of Understanding), should work closely with the UWL Office of International Education & Engagement (IEE) and Contract Administrator. These partners will help ensure international agreements generate mutual benefit, set realistic expectations, manage risks, adhere to campus, state, and federal policies, and are signed by someone with authority to sign on behalf of the university.

Also note the additional review requirements for agreements with individuals or organizations associated with foreign countries of concern (FCOC) outlined on this webpage.

All gifts and gift solicitations with foreign organizations or entities must be disclosed, accepted, and reported in compliance with the UW-La Crosse Foundation's Gift Acceptance and Reporting Guidelines. Foreign gifts are also subject to federal reporting and disclosure requirements, including but not limited to the following:

• Disclosures of current, pending, and other support to sponsors
  • Depending on sponsor guidelines, this may be required at the time of proposal or immediately prior to award notification (e.g., just in time).
  • Refer to the UWL Disclosures of Other Support policy and procedures for more information.
• ED Section 117 reporting
• NSF Foreign Financial Disclosure Reporting

Federal funding agencies have an expectation that investigators are open and transparent about all outside appointments with foreign entities. It does not matter if these appointments are compensated or not. They must be disclosed on Other Support/Current and Pending Support, progress reports, or by other means as required by the sponsor.

If you have or are planning to apply for federal funding, there are several important things to remember. Federal agencies are especially concerned about outside appointments with foreign entities, and it is critical you follow the guidance outlined on this page and within sponsor guidelines. Federal agencies’ guidance continues to evolve, so please pay close attention to individual agency instructions.

What are university requirements related to export controls?

The Export Controls Screening Survey must be completed by any UWL faculty, staff, and students planning to carry out activities that involve:

• International travel
• Work with foreign collaborators (faculty, staff, students, or others) or organizations (domestically or abroad)
• Sharing, exchanging, transporting, or shipping information, supplies, research materials, or equipment with foreign individuals or organizations (domestically or abroad, virtually or in person)

After the survey is completed, the UWL Export Controls Officer and other offices assess related export controls risks and requirements, conduct further screening, and provide guidance to ensure compliance with federal regulations. For additional information, see the UWL Export Controls Overview & FAQs KB article.

What are export controls? 

Export controls are federal laws that govern the export of certain items and information out of, into, and within the US in the interests of US national security, economic competitiveness, and foreign policy.  Examples of such controls include limits on what can be shipped out of the country and to whom it can be shipped, limits on information access for certain foreign nationals and/or organizations, and license requirements for shipping some items or information abroad. Export controls can affect: 

• What type of research we do 
• Who we hire 
• Who we can share information with 
• Who we can work with (collaborators/sponsors) 
• Where we ship items 
• What items we ship 
• Level of security for projects/labs

What is defined as an “export?” 

An export is the transfer or disclosure of items, materials, information, software, technology, or other unclassified but restricted data to any person outside the US, including a US citizen abroad.  “Export” means not only the physical shipment of items but also the release of technology to foreign persons within the US by way of visual inspection, oral transmission, or training (“deemed export”). 

What is the definition of a foreign person/organization? 

For the purposes of export control laws, a foreign person/organization is any person/entity who is not a: 

• US citizen
• US permanent resident alien ("green card" holder)
• Protected political asylee/refugee
• US government agency or state/local government
• US business
• US university

What are some red flags signaling export controls could be involved in an activity? 

• A contract, grant, or agreement contains one or more of the following: 
  • Publication restrictions 
  • Personnel restrictions 
  • Export control language 
• Technical information is received under a non-disclosure agreement 
• Shipping items or information abroad 
• Working with foreign collaborators here or abroad 
• International travel 

Which export control regulations are most applicable to university activities? 

Are there exceptions to export control laws for institutions of higher education? 

There are no exceptions to OFAC regulations.  However, generally speaking, the following exclusions to ITAR and/or EAR export control laws can be used by institutions of higher education.  

What are the potential outcomes if an item is determined to be possibly subject to export controls? 

• No additional action may be needed
• Classification of item/technology/information in the USML (ITAR) or CCL (EAR), which determines whether (and how) it is controlled under the regulations
• Development of technology control plan, which describes how it will be managed from a security standpoint and may or may not prevent the need for a license
• Obtaining license from appropriate federal agency if item is determined to be subject to export controls
• Prohibition of activity if it is determined to be prohibited by federal regulations

National Institutes of Health

In August 2018, Dr. Francis Collins issued a letter to grantees and published a Statement on Protecting the Integrity of U.S. Biomedical Research. In these documents, NIH highlighted the following areas of concern:

1. Diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries;
2. Sharing of confidential information by peer reviewers with others, including with foreign entities, or otherwise attempting to influence funding decisions; and
3. Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.

In July 2019, NIH issued Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components and accompanying FAQs on Other Support and Foreign Components. The NIH’s Advisory Committee to the Director Working Group on Foreign Influences on Research Integrity continues to work to address concerns.

In July 2020, NIH released a website on Protecting U.S. Biomedical Intellectual Innovation. The site describes NIH concerns and requirements for disclosures, as well as explains responsibilities of institutions and the NIH.

National Science Foundation

The National Science Board, in October 2018, issued a Statement of the National Science Board on Security and Science, which emphasizes that “U.S. universities and colleges must help promote scientific openness and integrity and safeguard information that impacts national security and economic competitiveness.” The Director of the NSF released a Dear Colleague Letter on Research Protection in July 2019. NSF also issued a policy that their agency personnel and IPAs may not participate in foreign government talent recruitment programs. NSF commissioned a study and report from JASON on Fundamental Research Security, which proposed steps that NSF can take to improve the security of fundamental research.

Department of Energy

The Department of Energy (DOE) released a Memorandum in January 2019 that contains a policy prohibiting DOE personnel from participating in foreign talent recruitment programs. DOE provided further guidance in Order 486.1 to their employees and contractors.

Department of Defense

The Department of Defense (DoD) issued a Memorandum in March 2019 that delineated information to be provided for senior/key personnel as part of a proposal and that the information would be used for purposes including protection of intellectual property and limiting undue influence. DoD also issued, in October 2019, a letter to universities and research centers describing their efforts to protect the integrity of the U.S. research enterprise and asking for support in doing so.

Office of Science and Technology Policy

In June 2020, OSTP released a presentation on Enhancing the Security and Integrity of America’s Research Enterprise. This presentation highlights some specific cases and areas of ongoing concern. OSTP is working on additional guidance for academic research institutions.

In September 2019, the Director of the Office of Science and Technology Policy sent a Letter to the United States Research Community in which he emphasizes the importance of protecting the integrity of our nation’s research enterprise.

We expect federal agencies to release further guidance over the coming months, so be aware that information and requirements might change at any time. In the meantime, we encourage faculty and staff to reacquaint themselves with existing policies and procedures. Select information (not a comprehensive list) is included below.

Sponsors generally expect to be informed at the time of proposal if research activities will take place outside of the United States. If not anticipated at the time of proposal, sponsors may require prior approval for such activities. Researchers may need to:

• Disclose and request permission for activities outside the United States, for example:
  • NIH research application instructions: see instructions related to international collaborators or foreign component)
  • NIH prior approval requirement for foreign component or foreign subaward
  • NSF proposal instructions on foreign organizations
  • NSF prior approval requirement for all subawards, including those to foreign entities
• Report on activities that occur outside the United States, for example:
  • NIH RPPR instructions; (see instructions related to participants affiliated with a foreign organization; award budget being spent in a foreign country; or foreign component)
  • NSF RPPR instructions (see instructions related to participants or partner organizations)

Federal agencies have made clear that they expect researchers to disclose all research support, including from foreign sources.

• Disclose your outside appointment on all Other Support/Current & Pending Support documents or progress reports.
• Disclose any equipment or other resources provided to you as part of this appointment in the appropriate sections of your grant proposal or progress reports.
• Disclose any foreign graduate students, post-docs, or other personnel working on your federally funded projects
• Specific agency guidance includes:
  • NIH: NOT-OD-19-114; Just-in-Time Procedures
  • NSF: NSF-Approved Formats for Current and Pending Support; Current and Pending Support
  • Dept. of Defense: Memorandum

Also refer to the UWL Disclosures of Other Support policy and procedures.

Investigators are personally responsible for including in their Current & Pending (Other) Support (or other relevant) sponsored project documents all sources of foreign support consistent with the funding agency's requirements. NIH, in particular, currently states: “Other Support includes all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts do not need to be included.” As noted in NIH director Collins’ letter, there have been instances reported nationally of investigators failing to properly report sources of foreign support for their research. NSF and other agencies have also voiced concern. Failing to report other sources of domestic or foreign support increases the likelihood that the same or closely related research could be funded more than once, and increases the potential for allegations of fraud, as well as overlap in intellectual property obligations to employers and the government. Careful attention to the specific requirements of an individual Funding Opportunity Announcement/FOA is warranted.

Researchers must be transparent in their biographical sketches about any outside academic, professional, or institutional appointments, whether paid or not, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

• Disclose your outside appointment as part of your biographical sketch.
• Properly attribute UWL and outside institution in publications.
• Specific agency guidance includes:
  • NIH: Biosketch Format Pages, Instructions and Samples
  • NSF: Biographical Sketch(es)

Also refer to the UWL Disclosures of Other Support policy and procedures.

To ensure that any potential conflicts of interest - foreign or domestic - are identified and managed appropriately, university personnel applying for federal funding must accurately disclose covered financial and business interests, activities, and support through the Significant Financial Interest (SFI) Disclosure Form in accordance with the Financial Conflicts of Interest (FCOI) policy. For example, faculty/staff must disclose the following interests from any foreign entity in any amount:

• Compensation
• Honoraria
• Paid authorship
• Consulting fees
• Ownership interests
• Investments
• Intellectual property rights and interests
• Royalties
• Reimbursements
• Sponsorships

All university personnel must also comply with annual UW System Outside Activities Reporting requirements.

For sponsor-required disclosures of other support, university personnel applying for extramural funding must report all collaborations and affiliations, whether foreign or domestic, that provide funding or require a commitment of time.

Federal agencies have expressed concerns about ensuring that individuals maintain confidentiality on all proposal review panels. Specific agency guidance includes:

• NIH: Integrity and Confidentiality in NIH Peer Review
• Conflict-of-Interests and Confidentiality Statement for NSF Panelists

Investigators involved in the peer review process are expected to follow the stringent confidentiality requirements of proposals undergoing review. NIH director Collins also reported instances (nationally) of study section reviewers inappropriately sharing proposals undergoing peer review with domestic and foreign collaborators.