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Undue Foreign Influence

Federal funding agencies are issuing new policies, guidance, and rules to address concerns relating to the unreported disclosures of support from foreign organizations, unlawful transfer of intellectual property or research materials, and agreements imposing obligations on researchers contrary to policy or law.

Current & Pending/Other Support Requirements

Many federal agencies have a requirement to provide other sources of support during the proposal submission, award negotiation, and/or in the progress report. This disclosure assures the funding agency that:

  1. It is not providing overlapping funds for work that is supported by another source;
  2. That all resources available in support of the individual’s research are being reported regardless of whether it is received directly by the individual or through the institution; and
  3. The participating personnel have sufficient time available to conduct the work that the agency will be funding.

Any activity conducted within the scope of an Investigator’s appointment that provides funding or requires a commitment of time must be reported. Commitments are regular obligations of time regardless of whether the Investigator receives salary support.

Federal Resources on International Engagements

National Science Foundation (NSF)

NSF’s Proposal & Award Policies and Procedures Guide (PAPPG), includes a table entitled NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support.

NSF-approved formats are required for biographical sketch and current and pending support. Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value, and regardless of whether they are completed in the investigator’s ISU or private role.

National Institutes of Health (NIH)

NIH has compiled guidance on its “Protecting U.S. Biomedical Intellectual Innovation” website.

NIH expects investigators and institutions to use its updated biosketch and other support format for applications, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs).

Department of Energy (DOE)

DOE O 486-1a:  Foreign Government Sponsored or Affiliated Activities
Prohibits DOE employees and contractors from participating in foreign talent recruitment programs from a Foreign Country of Risk  and “from participation in Other Foreign Government Sponsored or Affiliated activities of a Foreign Country of Risk”.  FAQs regarding this order are available here.

Additionally, DOE O 142.3B Chg 1 (LtdChg) requires DOE approval for foreign national access to DOE sites, information, or technologies. Previously, U.S. institutions of higher education were exempt, but that is no longer the case. When this Order is included in the terms and conditions of a DOE-sponsored award, ISU must disclose and seek approval for foreign nationals to participate in activities funded by this award. FAQs regarding this order are available here.

Department of Defense (DOD)

DOD informed the academic community of threats to the U.S. research environment by foreign governments in this letter.

Proposers must now submit the following information for all key personnel whether or not the individual’s efforts under the project are to be funded by DOD:

  • A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
  • Title and objectives of the other research projects.
  • The percentage per year to be devoted to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

National Aeronautics and Space Administration (NASA)

Since 2011, NASA has prohibited collaborating with, or subcontracting to, the Chinese government, a government-owned company, or a company incorporated under Chinese law. This includes using NASA funds for the U.S. side of a collaboration with an unfunded collaborator.

United States Department of Agriculture (USDA)

UDSA NIFA – Current and Pending Support Template

Foreign Influence Cases in the News