In response to concerns over foreign influence in federally funded research, U.S. funding agencies including NIH and NSF recently have issued statements and updated policies clarifying applicant and grantee requirements to disclose ‘financial conflicts of interest’, ‘other support’ and ‘foreign components’ when applying for or receiving federal grants and contracts. Agencies also are reminding peer reviewers of their obligation to maintain confidentiality.
As highlighted in the Vice Provost for Research's April 6, 2020 letter to the ETSU community regarding foreign influence in research, failure to disclose foreign affiliations and activities precludes funding agencies from fully evaluating the application for scientific, budgetary, and commitment overlap, and represents a potential conflict of interest that could affect the objectivity of the research and peer review process. Failure to disclose also violates federal regulations, and sponsor and ETSU policy.
ORSPA has created a list of resources to assist the ETSU research community in understanding its obligations, and the concerns raised about foreign influence in U.S. funded research. The website will be updated as new information becomes available.
Questions and concerns on federal, sponsor and ETSU disclosure requirements should be directed to research@etsu.edu.
Federal Resources
Department of Defense Guidance
- Actions for the Protection of intellectual Property, Controlled Information, Key Personnel and Critical Technologies. Michael Griffin memorandum, sent March 20, 2019.
Department of Energy Guidance
- DOE Order No. O 486-1: Department of Energy Foreign Government Talent Recruitment Programs. Prohibits DOE employees and contractors participating in foreign talent recruitment programs from certain countries from receiving DOE funding. The extent and reach of this requirement to recipients and subrecipients of DOE funding is not yet known as the requirement is being first implemented within DOE national labs.
National Institutes of Health
- Guide Notice NOT-OD-19-114
- NIH FAQS - Other Support and Foreign Components
- Specific Requirements
- At time of competitive proposal: NIH Grants Policy Statement 2.5.1 Just in Time Procedures
- At time of progress report: RPPR Instruction Guide (Page 86) - See D.2.c. Changes in other support.
- Foreign Component (Work to be performed outside of the US)
- At time of competitive proposal: Research Instructions for NIH and Other PHS Agencies (Page R-39) - See Question 6: Does this project involve activities outside of the United States or partnerships with international collaborators?
- At time of progress report: RPPR Instruction Guide (Page 99) - See G.9. Foreign component.
- During the life of the project:
- NIH Grants Policy Statement 8.2.1.10 Foreign Component Added to a Grant to a Domestic or Foreign Organization: Prior approval is required to add a foreign component.
- NIH Grants Policy Statement 16.7.2 Change in Scope: Prior approval is required to change a performance site within a foreign country or to add a performance site in a new country.
- Biosketch Instructions
- At time of competitive proposal: Biosketch Format Pages, Instructions and Samples - See section B.
- At time of RPPR:
- NIH and Other PHS Agency RPPR (Page 84) - Question: Is the individual’s primary affiliation with a foreign organization?
- NIH and Other PHS Agency RPPR (Page 86) - Biosketches are required only for new senior/key personnel.
- During the life of the project: Not required unless involving a change of PI or senior/key personnel named in the Notice of Award.
NSF Guidance
- NSF Memorandum 19-20: Research Protections. Sent from Director France Cordova, July 11, 2019.
- Proposal Preparation Instructions. See section (f) Biographical Sketch; and (h) Current and Pending Support; and (i) Facilities, Equipment and Other Resources.
- NSF Research Performance Progress Report. RPPR Screenshots and Instructions.
- Information about NSF Proposed 2020 Changes. Not yet finalized. Effective January 2020. See pages 1-2.