Several federal agencies have started to issue 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
- Diversion of intellectual property
- Sharing of confidential information by application peer reviewers
- Participation in foreign talent recruitment programs
This issue continues to evolve. Related faculty responsibilities under Utah State University policies and sponsor regulations are outlined below, and will be updated as additional information becomes available.
- REPORT all research support, including foreign support, in accordance with sponsor requirements at the proposal stage, and in progress reports.
- DISCLOSE financial interests, including travel, in the USU Kuali COI module, as required by the USU’s Conflict of Interest Policy #307.
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 Outside Interest in your COI disclosure.
- DISCLOSE other professional activities, including affiliations, as required by the USU’s Consulting Service Policy #377.
You should submit a outside employment form to your department head and dean for approval of all collaborations with a foreign entity. All collaborations related to your professional expertise that are outside of recognized institutional activities or agreements (e.g., personal consulting, unauthorized or unofficial collaborations, etc.) require an approved outside employment form.
- 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 share 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.
- 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
- July 2019 Dear Colleague Letter
- NSF Proposal, Award, Policies & Procedures Guide (PAPPG)(current & pending support requirements, 2019 version)
- NSF PAPPG Foreign Organizations