August 31, 2018
Foreign Influence on Federally Sponsored Research – Guidance
Update 04.03.2020: NSF policy link updates
Update 6.06.19: Review compliance guidance on Foreign Interests in Sponsored Programs
Update 4.23.2019: related guidance: Disclosing Foreign Interests in Sponsored Programs
As many of you are aware, there has been recent press and activities around national security with higher education and research organizations. We want to ensure these matters are brought to your attention in light of correspondence and guidance that has been shared by NIH and NSF.
NIH has voiced serious concern about threats to the integrity of U. S. biomedical research and announced they are working with other government agencies and U.S. universities to mitigate these concerns, specifically:
- Diversion of intellectual property (IP) in grant applications or produced by NIH supported biomedical research to other entities, including other countries;
- Sharing of confidential information on grant applications by NIH peer reviewers with others, including foreign entities, or otherwise attempting to influence funding decisions; and
- Failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.
Focus will be on improved compliance with respect to mandatory reporting of all sources of research support, financial interests and relevant affiliations as well as steps to reduce risk to IP security. To begin with, NIH has reminded the research community to disclose all forms of support and financial interests via other and pending support in proposals and SFI disclosure process.
In addition, NSF shares the above serious concerns with respect to NSF supported basic and applied research. NSF expects that PIs and senior personnel will list any activity that provides funding to their work and/or a commitment of time by the individual in the same manner as listed above for NIH.
What does this mean for proposals, progress reports, and SFI disclosure at the UW?
UW researchers whose research is supported with federal funding should update their other support documentation, including NIH Other Support, if it will be or is currently NIH funded. For NSF current and pending support, include all sources of support and commitments of time, even if not receiving salary support.
Biosketches should be current and thorough.
For key personnel, progress reports should indicate any change in support that occurred over the last budget year.
In addition, SFI disclosures need to occur prior to an application being submitted, annually thereafter, and whenever SFI changes. Approval for relationships with outside entities, including foreign entities and governments must be requested in advance as described in Executive Order 57: Outside Professional Work for Compensation.
Inventions must be promptly reported:
- To CoMotion, the University’s technology transfer office.
- To federal research sponsors as part of progress reporting.
Researchers must take reasonable efforts to protect the University’s interest (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their UW research.
Intellectual property developed under a sponsored research agreement is subject to the University’s policy on UW IP Disposition in Sponsored Program Agreements.
Individuals serving on NIH, NSF or other federal agency scientific peer review panels should note and comply with all requirements to maintain the confidentiality of the information in research grant applications.
Guidance and Resources
We expect further guidance on inclusion of appropriate sources of support and affiliations will be provided by NIH and NSF but, in the meantime, please take a look at current NIH and NSF requirements, as well as relevant UW policies:
- NIH: Other Support
- NIH: Biosketch Format, Instructions and Samples
- PHS: Promoting Objectivity in Research
- GIM 10: Financial Conflict of Interest Policy
- NSF: Policy Updates
- NSF: Collaborations and Other Affiliations
- GIM 40: UW Intellectual Property Disposition in Sponsored Program Agreements
- Executive Order 36: Patent, Invention and Copyright Policy
- Executive Order 57: Outside Professional Work for Compensation
Other federal agency sponsors may have different requirements. Please check the specific funding opportunity announcement and relevant agency grant policies for individual applications.
Questions about the policies cited above should be directed to the responsible UW central administrative unit. Other questions may be submitted to the Office of Research firstname.lastname@example.org.
Thank you for assisting in this important effort.