The National Institutes of Health and other federal agencies have recently identified concerns about research protection and undue foreign influence in academia. These concerns have created an increased interest by federal agencies in understanding the affiliations and dealings of university faculty. The Office of Research understands that faculty may feel uncertain about how best to meet the expectations of federal agencies when engaging in international activities and research partnerships. The Office of Research is here to answer your questions and to assist you in making all of the required disclosures. Our goal is to help ensure that you are aware of our existing disclosure, reporting and oversight mechanisms and can continue to engage with the global research community. We fully appreciate the value of foreign partnerships and exchanges, and we expect these activities to continue to grow.
Federal agencies have issued statements expressing growing concerns over the potential for undue 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 confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.
Disclosure and Reporting Mechanisms
- Register international travel per the UGA travel policy in the Office of Global Engagement (OGE) Travel Registry for all international travel on UGA business. Travel to areas under a Department of State Level 3 or 4 travel warning, or a CDC Level 3 warning, is governed by the OGE Risk Management Policy.
- Disclose all significant financial interests, external support and personal affiliations per the UGA Policy on Conflicts of Interest in Sponsored Programs and as required by external research funding sponsors. For example, NIH and NSF have both strongly emphasized accurate reporting of research support and financial interests.
- Disclose and obtain prior approval for all outside professional activities per the UGA Academic Affairs Policy 1.07-9.0 and by submitting the Notice of Intent to Complete Outside Work for Pay form.
- Follow international travel guidelines related to protection of electronic devices and data, the temporary export of electronic devices, and/or access of UGA information abroad.
- Comply with Export Control regulations in sponsored research and all international activities.
- Comply with the Visiting Researcher and Scholar procedures on hosting and onboarding these researchers.
- Comply with the Foreign Corrupt Practices Act, which prohibits providing, offering, authorizing or promising anything of value to a foreign government official with the intent to corruptly influence or gain an unfair advantage. Report Gifts and Grants per UGA Foundation Policy 4.2.
- Combat intellectual property theft by avoiding disclosure of new technologies without first contacting UGA Innovation Gateway per the UGA Intellectual Property Policy.
Specific Federal Agency Guidance
- National Institutes of Health “Dear Colleagues” letter
- National Institutes of Health “Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components”
- National Institutes of Health “Frequently Asked Questions: Other Support and Foreign Components”
- National Science Foundation “Dear Colleagues” letter
- Department of Energy “Foreign Government Talent Recruitment Programs” Directive
- Department of Defense Memorandum on “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies”