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Issue 57: Friday Updates, 2/5/21

New Question on the Adding Sponsors Request Form

On the evening of Friday, February 5th, the Adding Sponsors request form for KC will be updated to add the following question:

To the best of your knowledge, is the requested sponsor a non-U.S. entity or a subsidiary, affiliate, or agent of a non-U.S. entity? If Yes, please include a brief explanation in the Notes below.

This question will be added as a Yes/No dropdown and a response will be required for submission.

To answer this question, we ask that you consider the information you have available and recommend that if the information available does not indicate the response should be “yes”, an internet search should be conducted to determine whether the entity is a subsidiary, affiliate, or agent of a non-U.S. entity before responding “no”.  If after performing the search, you are still not sure how to answer the question, please send an email providing known information to the KC Helpdesk (

Additional information to add context for the new question:

As you are likely aware, undisclosed relationships between U.S. researchers and non-domestic entities (e.g., universities, companies, and governments) have increasingly been of concern to American science agencies. Recently, the Department of Education has opened investigations into several universities for failure to adequately report under Section 117 of the Higher Education Act of 1965.  In light of these investigations and audit implementation in this area, we carefully examined SPA/OSP/CGA’s data collection and reporting processes to ensure continued compliance with the reporting requirement.  Section 117 requires reporting of contracts with and gifts from a “foreign source” that, alone or combined, are valued at $250,000 or more in a calendar year.  The term “foreign source” is defined under 20 U.S.C. 1011f(h)(2) as:

  1. “a foreign government, including an agency of a foreign government;
  2. a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states;
  3. an individual who is not a citizen or a national of the United States or a trust territory or protectorate thereof; and
  4. an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.”

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