Undue Foreign Influence
Undue Foreign Influence in Federally Funded Research:
Applicants for federal grants must disclose all “foreign components” in their biosketch and “other support” in grant applications and are required to identify any changes in each annual progress report.
Any support from a foreign entity (whether financial or non-financial) or foreign engagement that you would acknowledge in public presentations or publications is something that you should also disclose in grant applications, annual reports and closeout summaries and in university-related COI and COC disclosure forms (as required).
- Failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments
- Diversion of intellectual property to foreign entities
- Sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions
Conflict of Interest (COI):
- All investigators who are conducting Public Health Service (PHS) funded research and all principal investigators conducting research funded by private sponsors and entities such as National Science Foundation (NSF) and Department of Defense (DOD) must disclose certain financial interests, whether domestic or foreign
- Investigators must disclose financial interests received from a foreign institution of higher education, and from the government of another country. NIH recently reminded the community of this requirement in NOT-OD-18-160
Conflict of Commitment (COC):
- Faculty must report time and earnings from certain outside professional activities involving foreign entities (e.g., consulting for a foreign entity that is outside the scope of their professional responsibilities) on an annual basis, and certain categories of outside activities require prior approval.
Collaboration Agreements: Any materials or information shared with a foreign entity must be covered under a formal agreement (sponsored research, material transfer, data use, confidentiality, collaboration, etc.).
Visitors: Disclose any foreign visitors to your departmental leadership & the Export Control Official (firstname.lastname@example.org); steps must be taken to ensure compliance.