The University of Arizona

NIH Foreign Influence in Research

Background 

In August 2018, NIH Director Francis Collins distributed a letter to the university research community raising concerns about foreign influence on NIH researchers and members of NIH peer review panels.

The letter addresses three concerns:

  1. Diversion of intellectual property (IP) in grant applications or produced by NIH- supported biomedical research to other entities, including other countries; 
  2. Sharing of confidential information on grant applications by NIH peer reviewers with others, including foreign entities, or otherwise attempting to influence funding decisions; and 
  3. Failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds. 

Faculty responsibilities under University of Arizona policies and NIH regulations related to the concerns addressed in the letter are outlined below.  

 Disclosing Foreign Support, Interests, Collaboration 

  1. Report all research support, including foreign support, in accordance with sponsor requirements at the proposal stage, and in progress reports. NIH Grants Policy Statement Section 2.5.1 
  2. Disclose financial interests, including travel, in the UA COI system, as required by the UA’s Individual Conflict of Interest in Research policy.  
  3. Disclose other professional activities, including affiliations, as required by the UA’s Conflict of Commitment policy.  
  4. Understand the NIH’s prior approval requirements for a foreign component on an NIH award, and engage Sponsored Projects & Contracting Services for assistance.  NIH Grants Policy Statement Section 8.1.2 

Export Controls 

Contact the UA’s Export Control Program for guidance about export control regulations, international travel, and shipping or taking items outside the United States.  

International Travel 

Review guidance and register your international travel at https://ua-risk.terradotta.com, at least 30 days prior to departure.  

Visiting Scholars 

  1. Work with your department and college on requirements for visiting scholars and university guests.  
  2. Contact 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.   

Materials, data, and confidential information 

If materials, data, and/or confidential information will be shared between the UA and another organization, a material transfer agreement (MTA), data use agreement (DUA), or confidentiality agreement may be necessary.  For Incoming MTAs, confidentiality agrements, and data use agreements, contact Sponsored Projects & Contracting Services or UAHS Contracting.  For outgoing MTAs, contact Tech Launch Arizona.  For questions about data use agreements, contact the HIPAA Privacy Officer for guidance. 

Intellectual Property

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.