Foreign Interests in Academic Research - General Guidance

The federal government has expressed concerns about foreign threats to and exploitation of federally funded research. Federal sponsors are now developing guidance to address these issues. The Office of Research Assurances has included below general guidance for your consideration. For specific questions, you may contact ORA or sign up for a live undue foreign influence course.

Foreign Government Talent Recruitment Programs

According to the National Science Foundation, these include:

Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring knowledge and expertise to the foreign country. The compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or other consideration.

Recruitment refers to the foreign state sponsor’s active engagement in attracting the targeted individual to join the foreign-sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the United States, or in the foreign state. Note that, generally, an invitation by a foreign state to simply attend or present work at an international conference would not constitute recruitment.

Some federal sponsors may altogether prohibit participation in a foreign government talent recruitment program. Even if participation is not prohibited, federal sponsors require that researchers disclose participation in such programs in Current and Pending Support or Other Support.

Current and Pending or Other Support

Federal sponsors require that researchers maintain documentation. This documentation must include all support, including foreign support. Foreign support includes fellowships and scholarships. “Other Support” also includes visiting scholars, even if unpaid, who participate in project research. And all project personnel, even unpaid visiting scholars, must be reported on project progress reports. Moreover, if a visiting scholar qualifies as “Senior/Key Personnel,” that scholar must comply with related federal requirements, such as submitting a bio-sketch and identifying other support.

Financial Interests from Foreign Entities

Any financial interest received from a foreign institution of higher education or the government of another country must be disclosed in Veras as a significant financial interest, per NSF and NIH policy.

Professional Consulting and Additional Workload

Approval for consulting and additional workload, including that offered by foreign institutions and other foreign entities must be approved as directed in FSH 3260. Any conflicts that may arise therefrom must be managed as provided in FSH 6240, FSH 5600, and FSH 5650.

Anonymous Compliance Hotline

Reportable activities of special concern are fraud, conflicts of interest, waste and misuse of university resources, as well as harassment and bias incidents that impact the well-being of individuals within our community and our stewardship responsibilities. One can make an anonymous report online or by phone. Visit our Anonymous Compliance Hotline page to find out more about when and how to make a report.