This plan outlines the steps that the University of Rhode Island and the RI-INBRE program (P20GM103430) will take to ensure compliance with NIH policies regarding foreign components and publications involving foreign co-authors under IDeA-funded awards—to prevent unallowable foreign components and align programmatic activities with current NIH priorities.

PRIOR APPROVAL PROCESS AND PREVENTION MECHANISMS – FY2027

1. Instructions for RI-INBRE investigators and core facility users will be distributed through RI-INBRE mailing lists, core user mailing lists, and posted on the RI-INBRE website.  Language will be added to all future award acceptance letters indicating that the investigator agrees to all federal compliance policies.  Documentation will be posted in the core facilities indicating that external core users are required to follow these policies.
2. RI-INBRE investigators and external core facility users who intend to publish with a foreign co-author are required to contact the RI-INBRE Program Director (PD) prior to submission with information, including:
   • Name of collaborator, their position and institution, and contact information
   • Brief description of the collaboration
   • Why the collaboration is essential to the work
   • If work was performed at a foreign location on human or animal subjects
   • If the investigator worked at the foreign facility or used equipment there
   • If the investigator received any financial resources from a foreign entity
   • If any data was transferred between the investigator and the collaborator
3. The RI-INBRE PD will consult with the NIGMS on each query to determine prior approval, and all prior approval requests will be submitted by the URI signing officer (SO).
4. Publications citing this award’s support will not include foreign co-authors without documented NIH prior approval on file. No IDeA funds will support any foreign component without documented prior approval.
5. The PieStar reporting system currently used by RI-INBRE will be used to flag any publication with foreign co-authors to identify any manuscripts that have not received prior approval.  Such instances will be evaluated on a case-by-case basis.
6. As with existing NIH public access requirements, continued RI-INBRE funding to investigators and/or access to RI-INBRE core facilities will be contingent on compliance with these policies.
7. Annual training on all compliance policies will be offered to investigators.
8. This policy will be periodically updated in consultation with university administration and NIH.

CONSEQUENCES FOR NON-COMPLIANCE

Investigators and core facility users operating under this award are on written notice that failure to adhere to these requirements—including failure to obtain prior approval before submitting a manuscript with a foreign-affiliated co-author—may result in enforcement actions consistent with NIH’s grant management authority. Such actions may include: removal of award funding attribution from the affected publication; suspension of access to program core facilities; or termination of the subaward or pilot award. Reported violations will be referred to the institution’s SO and to the assigned GMS and PO as appropriate.