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 confidental information by application peer reviewers
- Participation in foreign talent recruitment programs
This issue continues to evolve. Related faculty responsibilities under University of Arizona policies and sponsor regulations are outlined below, and will be updated as additional information becomes available.
Disclosing Foreign Support, Interests, Collaboration
- 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 UA COI system, as required by the UA’s Individual Conflict of Interest in Research policy.
Any payment, 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 UA’s Conflict of Commitment policy.
You must submit a Conflict of Commitment 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 Conflict of Commitment form.
- FOLLOW the sponsor’s prior approval requirements for a foreign collaboration/components, and engage Sponsored Projects & Contracting Services for assistance.
- CONTACT the UA’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 at https://ua-risk.terradotta.com, at least 30 days prior to departure.
- FOLLOW your department/college on requirements for visiting scholars and university guests.
- CONACT your college’s Export Control Liaison or the Export Control Program to conduct a Restricted Party Screening of visitors and guests prior to any agreement to visit the UA.
- REPORT inventions and any intellectual property created, in accordance with NIH requirements. NIH Grants Policy Statement Section 8.2.4. Contact Tech Launch Arizona for assistance.
- University intellectual property (e.g., materials, reserach results, databases/sets, potentially pantentable 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 Tech Launch Arizona. For questions about data use agreements, contact the HIPAA Privacy Officer. For Incoming transfers, confidentiality agrements, and data use agreements, contact Sponsored Projects & Contracting Services or UAHS Contracting.
Other Relevant Policies/Procedures
- August 2018 Letter to grantees
- 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)
- July 2019 Dear Colleague Letter
- NSF Proposal, Award, Policies & Procedures Guide (PAPPG) (current & pending support requirements, 2019 version)
- NSF PAPPG Foreign Organizations
Department of Energy (DOE)