Federal Agency Guidance & Commentary

Federal Agency Guidance

Issues surrounding foreign influence and international activities in federally funded research is an evolving topic in which the U.S. Government is showing growing concern

National Institutes of Health (NIH)

  • The Director of NIH, Francis Collins, issued a “Foreign Influence Letter to Grantees,” and testified to the Senate Health, Education, Labor and Pensions Committee regarding concerns about systematic programs of foreign influence in U.S. research. Dr. Collins reminded the research community that they are required to “disclose all forms of other support and financial interest, including support coming from foreign governments or other foreign entities…in accordance with the NIH Grants Policy Statement, [on] all applications and progress reports (NOT-OD-18-160)” and indicated that NIH’s Office of Extramural Research (OER) will be providing additional information in the future.
  • In July 2019, NIH issued the NOT-OD-19-114 along with related FAQs. This notice is to remind the extramural community about the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap. NIH has long required full transparency for all research activities both domestic and foreign and does not consider these clarifications to be changes in policy. 

National Science Foundation (NSF)

  • The NSF Dear Colleague Research Protection Letter 7.11.19. outlines a few steps it is taking to mitigate the risks in concert with other agencies and stakeholders.
  • The NSF Commissioned the JASON Report to enhance the agency’s understanding of the threats to basic research posed by foreign governments that have taken actions that violate the principles of scientific ethics and research integrity. With the official receipt of the report, NSF is analyzing its findings and recommendations.

Department of Defense (DOD)

  • The U.S. Department of Defense (DOD) issued a memo on March 20, 2019 outlining disclosure requirements for all key personnel listed on research and research-related educational activities supported by DOD grants and contracts.
  • In addition, on October 10, 2019, the DOD issued an Academic Letter to Universities. The letter addresses the importance of international collaborations and the need for universities and their faculty to continue to work to protect the integrity of U.S. research. It also reiterates the need for research personnel to fully disclose conflicts of interest and commitment: “all research and research- related educational activities conducted through DOD research grants, cooperative agreements, Technology Investment Agreements, and other non-procurement transactions require key-personnel to disclose all current and pending projects, time commitments to other projects, and funding sources at the time of application.”

Department of Energy (DOE)

  • DOE issued a memo on January 31, 2019 stating that they would ban scientists from participating in foreign-talent recruitment programs. Specifically, scientists and grant recipients would be restricted from participating in programs sponsored by China or other countries suspected of using them for sensitive research. DOE also stated they would require scientists and grant recipients to disclose connections of this nature. Those disclosing these types of connections will be required by DOE to sever ties in order to obtain or maintain sponsored funding with the Department.
  • On June 7th, 2019, the DOE issued a directive regarding foreign influence and talent recruitment programs. The directive states that the DOE is prohibiting those working under a DOE contract from participating in a foreign talent recruitment program: “DOE will take appropriate actions to prohibit DOE employees and DOE contractor employees, while employed by DOE or performing work under a contract, from the unauthorized transfer of scientific and technical information to foreign government entities through their participation in foreign government talent recruitment programs of countries designated by DOE as a foreign country of risk.”

National Aeronautics and Space Administration (NASA)