Foreign Influence in Research
Utah State University deeply values our international research collaborations and the contributions of our students and scholars from around the world. These global partnerships enrich our culture and are critical to advancing our research endeavors.
Several federal agencies have issued information and guidance concerning undue foreign influence on federally funded research. In particular, agency communications have centered around the following issues:
- Disclosure of research support
- Disclosure of foreign appointments
- Diversion of intellectual property
- Sharing of confidential information by application peer reviewers
- Participation in foreign talent recruitment programs
With the heightened sensitivity on these issues nationally, the USU Office of Research wants to remind you of your disclosure obligations. Related faculty responsibilities under Utah State University policies and sponsor regulations are outlined below, and will be updated as additional information becomes available.
Disclosing Foreign Support, Interests, Collaboration
- DISCLOSE foreign appointments, research support, and financial interests, including travel, in the USU Kuali COI module, as required by the USU’s Conflict of Interest Policy #307 and federal industries.
- REPORT all research support, including foreign support, in accordance with sponsor requirements at the proposal stage, and in progress reports.
Any payment, research support (e.g. lab supplies, support of students), reimbursement, travel support or other compensation, of any amount, that you have received or will receive, from a foreign entity must be disclosed as an Other Support and Appointments in your COI disclosure.
- DISCLOSE other professional activities, including affiliations, as required by the USU’s Consulting Service Policy #377.
- FOLLOW the sponsor’s prior approval requirements for a foreign collaboration/component, and engage Sponsored Programs Office for assistance.
CONTACT USU’s Export Control Program for guidance about export control regulations, international travel, and shipping or taking items outside the United States.
REVIEW guidance and register your international travel with the Office of Global Engagement, at least 30 days prior to departure.
- FOLLOW your department/college on requirements for visiting scholars and university guests.
- CONTACT the Export Control office to conduct a Restricted Party Screening of visitors and guests prior to any agreement to visit the USU.
- REPORT inventions and any intellectual property created, in accordance with NIH requirements. NIH Grants Policy Statement Section 8.2.4. Contact Technology Transfer Services for assistance.
- University intellectual property (e.g., materials, research results, databases/sets, potentially patentable inventions, copyrights, etc.) may not be shared with any institution or entity without an official agreement between the University and that entity authorizing such transfer approved by the IP Official or their designee. For outgoing transfers, contact Technology Transfer Services. For questions about data use agreements, contact the Research Integrity & Compliance Director. For Incoming transfers, confidentiality agreements, and data use agreements, contact Sponsored Program Office or Technology Transfer Services.
Training on Undue Foreign Influence is available and free of charge to all USU personnel online via CITI. Researchers and administrators should take the Undue Foreign Influence course if any of the following situations apply to them:
- Working with foreign collaborators
- Hosting and/or mentoring foreign students and visiting scholars
- Involvement in foreign talent programs
- Offered or receiving foreign resources for research (e.g., foreign appointments or employment, grant support, office/lab space, equipment)
- Plans to travel to a foreign country to conduct research
- Go to the CITI website.
- Click “Register” in the upper right corner of the page.
- Select “Utah State University” as your organizational affiliation.
- Continue to step 7 on the CITI website.
- Select “Undue Foreign Influence: Risks and Mitigation” and go to the next page.
- Click “Finalize Registration.”
- Go to the CITI website and log in.
- Under “Main Menu/My Courses“, scroll down to the bottom.
- Under “My Learner Tools for Utah State University”, click Add a Course.
- Select “Undue Foreign Influence: Risks and Mitigation” and click next.
- Select “Yes, enroll me in the Undue Foreign Influence course” and click “Next”.
- You should now be enrolled.
- The DRIC will be notified when you pass all required course modules.
National Institutes of Health (NIH)
NIH Director Dr. Francis S. Collins issued a "Foreign Influence Letter to Grantees" on August 20, 2018. In this letter, Dr. Collins reminds the research community to "disclose all forms of other support and financial interests, including support coming from foreign governments or other foreign entities....in accordance with the NIH Grants Policy Statement, [on [all applications and progress reports."
- NOT-OD-21-073: Upcoming Changes to the Biographical Sketch and Other Support Format for Due Dates on or After May 25, 2021
- NOT-OD-19-114: Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
- FAQs on Other Support and Foreign Components
- NOT-OD-18-160: Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests
- NIH Grants Policy Statement Section 2.5.1
- NIH Grants Policy Statement Section 8.1.2
National Science Foundation (NSF)
The National Science Foundation issued a statement on "Security and Science" dated October 23, 2018. This statement indicated that U.S. universities must "embrace transparency and rigorously adhere to conflict of interest and conflict of commitment policies."
- JASON Report 2019
- July 2019 Dear Colleague Letter
- NSF Proposal, Award, Policies & Procedures Guide (PAPPG) (current & pending support requirements, 2020 version)
Department of Defense (DoD)
DoD issued a memo on March 20, 2019 directing that all new DoD Notices of Funding Opportunities pertaining to research and research-related educational activities include a requirement that proposers provide additional information on the other support and commitments of all key personnel, regardless of whether the proposal is funded.
Department of Energy (DoE)
The Department of Energy issued a directive dated June 7, 2019, mandating that "federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs" on new DOE contracts and subcontracts.