Improper Foreign Government Influence

Foreign Influence

This information is to assist researchers in satisfying certain reporting and disclosure obligations. Specifically, UCSF faculty and other researchers are obligated to completely and accurately disclose all financial and non-financial interests and support, affiliations, activities and relationships with foreign entities. Federal agencies such as National Institutes of Health (NIH) and Department of Defense (DOD) have issued statements expressing growing concerns over the potential for foreign influence in the following areas:

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.

Specific guidance will be communicated to the UCSF community in the coming months, but all faculty and researchers should continue to comply with existing obligations, which include:

Federal Funding: 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. Additional detail can be found below, and you may consult with your Research Services Coordinator for further guidance.

Conflict of Interest (COI):
1. 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.
2. Although PHS regulations exclude United States institutions of higher education and US government agencies from certain financial disclosure requirements, 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.
3. Contact [email protected] for further guidance.

Conflict of Commitment (COC): University of California 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. Contact your department chair for further guidance.

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.). Contact your contracting officer or [email protected] for further guidance.

Visitors: Disclose any foreign visitors to your departmental leadership and the Export Control Officer ([email protected]) prior to the visit, as on-boarding steps must be taken to ensure compliance.

Best Practice: 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 application systems, annual reports and closeout summaries and in university-related COI and COC disclosure forms (as required).

Content adapted with permission from University of California San Diego Office of Research Affairs.

Funding Details for Foreign Influence Matters

According to the NIH Grants Policy Statement, Foreign Component includes “The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended [emphasis added].

Activities that would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. Examples of other grant-related activities that may be significant are:

collaborations with investigators at a foreign site anticipated to result in co-authorship;
use of facilities or instrumentation at a foreign site; or
receipt of financial support or resources from a foreign entity [or other funded or un-funded resources from a foreign entity, including materials].

Foreign travel for consultation is not considered a foreign component.

Other Support according to NIH includes all financial resources, whether Federal, non-Federal, commercial or organizational, available in direct support of an individual's research endeavors, including, but not limited to, research grants, cooperative agreements, contracts, or organizational awards. Other support does not include training awards, prizes, or gifts. More information can be found at NIH's GPS 2.5.1. Just-in-Time Procedures, and the UCSF Office of Sponsored Research website.

Tips for Federal Grantees:

List all foreign components present in your proposal and in each annual progress report. This applies to all agreement types, including research contracts and grants, cooperative agreements and organizational awards, including any from foreign governments or entities. Unfunded and service agreements are included.
Consult with your Research Services Coordinator (RSC) prior to adding a foreign component to a federally funded project. Prior NIH approval is required, as outlined in the NIH Grants Policy Statement .
For Department of Defense (DOD) proposals, disclose key personnel information as outlined in the DOD memo dated March 20, 2019.
At the time of proposal, the National Science Foundation (NSF) requires disclosure of a foreign organization's involvement in a project via a check box and justification as to why that organization's participation is essential (see Chapter I.E.6 of NSF's Grant Proposal Guidelines).
Consult with the Export Control Officer ([email protected]) prior to participating in foreign “Talent Programs,” and disclose any participation (Department of Energy grantees may be prohibited from participating in foreign talent programs).

Content adapted with permission from University of California San Diego Office of Research Affairs.

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Improper Foreign Government Influence

Foreign Influence

Foreign Influence Resources from UCOP Ethics, Compliance and Audit Services