The document provides detailed responses from the National Science Foundation (NSF) to queries raised during a COGR (Council on Governmental Relations) presentation regarding Foreign Financial Disclosure Requirements (FFDR) and the TRUST framework. Clarifications include that only institutions meeting the Higher Education Act’s definition of an institution of higher education (IHE)—typically degree-awarding colleges and universities—need to submit annual FFDR reports, excluding most independent research institutions or affiliated medical centers. For multi-year gifts or contracts from foreign sources in countries of concern, only amounts received within the reporting period are to be disclosed, not pledges. Technology license agreements are treated as contracts, and direct payments to faculty must be reported if known by the IHE and if the financial threshold is met. Additional guidance covers the handling of clinical trial funding, contracts with uncertain terms, and the distribution of reporting responsibility within university systems. Tuition grants or scholarships from foreign sources are also subject to disclosure once the reporting threshold is met, whereas purchases from foreign vendors are not, unless the foreign entity is purchasing from the IHE.
On the TRUST framework, which addresses research security and nondisclosures, NSF clarifies that undisclosed appointments or research support will be flagged through data analytics and typically addressed with the institution before potential referral to oversight bodies. NSF does not consider delaying research dissemination as a mitigation strategy and does not use co-authorship as a risk factor in assessing research security. The SECURE Center will serve as a resource for risk assessment frameworks, aiding in compliance and best practices. Throughout, NSF emphasizes a tailored approach to risk—distinguishable from other agencies—asserting that the TRUST framework seeks to protect both research integrity and the benefits of international collaboration, rather than adopting the most restrictive policies across the federal landscape.
