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Agency-Specific Disclosure Guidance

Documents Required for Virginia Tech Personnel

Disclosure to federal agencies is required when proposing for or receiving funding. Transparency and disclosure are needed in order for sponsors to properly assess the capacity of the individual to carry out the proposed research and any potential overlap or duplication with other projects.

Federal agencies request similar, though not uniform, information and might require that the information be provided following their own format. It is recommended that the investigator/department pay close attention to the sponsor’s instructions in the request for proposal, policy guide, etc. on how to prepare these documents.

Principal investigators are responsible to ensure the accuracy and consistency of their disclosures and those of all team members where this is required. Disclosing in the university's disclosure system does not alleviate investigators of their obligation to disclose activities and other support to the federal sponsor in the proposal.

At this time, this requirement should be limited to senior/key personnel; however, individual agencies may require additional personnel to adhere to these requirements. Consult with your Office of Sponsored Programs pre-award administrator or foreigninfl@vt.edu for additional guidance.

Additional Information  

Find helpful information on the NIH Foreign Interference site.

  • Overview of the Current and Pending Support Disclosure Requirements for Financial Assistance
  • Researchers must disclose team members (including students) participating (paid or unpaid) on a DoE award who are also participating in a Foreign Government-Sponsored Talent Recruitment Program (FGTRP) of a Foreign Country of Risk (currently China, Russia, Iran, and North Korea).
  • Senior/key personnel must report updates within 30 days of the change via FedConnect.
  • DOE Order 486.1A prohibits participation in foreign government-sponsored talent recruitment programs and restricts other foreign government-sponsored or affiliated activities. View the FAQs for DOE Order 486.1A for more information.
  • DOE Order 142.3B requires protection for emerging and critical technologies as specified by the Science and Technology (S&T) Matrix. This Order also specifies Indices Checks for individuals funded under applicable awards. View the FAQs for DOE Order 142.3B for more information. Foreign nationals from countries of risk are subject to enhanced vetting by DOE and may be restricted from accessing technology or information. According to DOE, a foreign national is defined as a person who is not a U.S. citizen either by birth or naturalization.
  • NASA’s February 2023 Proposer's Guide includes current and pending other support requirements at Section 2.16.
  • Pre-Award Disclosure
    • When submitting a proposal, Viginia Tech is required to make the following assertion in the contract:

"By submission of its proposal, the proposer represents that the proposer is not China or a Chinese-owned company, and that the proposer will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement."

  • Prohibited versus Allowable Participants and Activities:
    • According to federal law, researchers may be ineligible for funding if their on-going or proposed work involves bilateral activity with the People’s Republic of China (PRC) or PRC-owned companies or entities. PRC-owned company indicates any company owned by the PRC or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are considered to be incorporated under the laws of the PRC; therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration, or coordination with Chinese universities. See NASA funding FAQs for more information.
    • Prohibited Participants
      • PRC students and student interns from PRC institutions of higher education on a J-1 visa
      • Visiting scholars from PRC institutions of higher education
      • Adjunct faculty from PRC institutions of higher education
      • Viginia Tech faculty, staff, post doctoral candidates, and students (regardless of nationality) having bilateral participation, collaboration, or coordination with businesses and entities of the PRC. Note: NASA considers  all Chinese institutions of higher learning to be entities of the PRC.
    • Allowed Participants
      • So long as they do not engage in bilateral participation, collaboration, or coordination with institutions of the PRC (e.g., universities) or Chinese-owned companies, whether funded or performed under a no exchange of funds arrangement, the following Virginia Tech PRC citizens are not prohibited from receiving NASA funding or participating in NASA-sponsored projects:
      • Students with PRC citizenship in the US on an F-1 visa
      • Postdoctoral candidates and research faculty with PRC citizenship in the US on an H1-B visa
      • Faculty, staff, and students with PRC citizenship who are also US resident aliens
    • Prohibited Bilateral Activities
      • Attending conferences in PRC
      • Publishing papers that include authors from only the USA and PRC
      • Data sharing agreements with PRC organizations
      • Reviewing manuscripts from PRC journals
    • Allowed Activities
      • General scientific discussions with PRC researchers
      • Participating in research funded by non-NASA sponsors that involve scientists affiliated with PRC institutions
      • Attending multilateral, widely-attended conferences in PRC
      • Publishing papers that include authors from USA, PRC, and other countries
      • Reviewing journal manuscripts not from PRC, even if they include authors from PRC
      • Using PRC data that is publicly available

Questions?

Contact foreigninfl@vt.edu.