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International Relationships & Research Activities

U.S. Federal Agency Specific Requirements


U.S. Federal Agencies
National Institutes of Health

 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. 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.

Foreign travel for consultation is not considered a foreign component. 

 National Science Foundation:

In a Dear Colleague Letter dated 11 July 2019, the National Science Foundation’s Director highlighted the challenges of balancing openness and international cooperation with the growing concerns of foreign influence and risks to research integrity. NSF has made certain changes to the PAPPG that will go into effect in January 2020. In a concurrent statement, the NSF produced a personnel policy restricting participation in foreign talent recruitment programs, which it characterized as attempts by foreign governments to acquire US funded research rather than reciprocal exchange of scholarship.

 Department of Energy
  • December 14, 2018, Deputy Secretary of Energy memo that creates a list of emerging “research areas and technologies that are in the U.S. national interest to limit sensitive country foreign nationals (SCFN) access,” referred to as the Science & Technology (S&T) Risk Matrix; sets enhanced vetting requirements for all foreign nationals visiting or assigned to DOE labs; prohibits SCFNs from certain activities; and generally prohibits travel to sensitive countries. Neither the list of sensitive countries nor the list of emerging research areas and technologies comprising the S&T Risk Matrix have been publicly released.
  • January 31, 2019, Deputy Secretary of Energy memo detailing plans to further limit risks of inappropriate foreign influence by subjecting DOE personnel to limitations, including prohibitions on their ability currently or in the future to participate in foreign talent recruitment programs of countries determined sensitive by DOE while employed by DOE, or performing work within the scope of a DOE contract. Notably, these limitations will also apply to recipients of financial assistance (e.g., grants or cooperative agreements).” 
  • June 7, 2019 DoE issued a directive to prohibit DoE employees and contractors from participating in foreign talent recruitment programs and provided distinguishing features of the same:
    • ”Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring their 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 consideration.
    • Recruitment in this context 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 US, or in the foreign state. Recruitment would not necessarily include any invitation for engagement extended by the foreign state, for example, an invitation to attend or present work at an international conference.
    • Many, but not all, program aim to incentivize the targeted individual to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at US research facilities or receipt of DOE research funds while concurrently receiving compensation from the foreign state.”
  • The June 7, 2019 directive also establishes a requirement for quarterly reports on talent program participation and parameters for flowdown provisions for qualifying lower-tier recipients.
Department of Defense 

House bill 5515:

  • Section 1260 “Modification of Annual Report on Military and Security Developments Involving The People’s Republic of China” updated language pertaining to reporting of potential threats by inserting “by espionage and technology transfers through investment, industrial espionage, cybertheft, academia, and other means.”
  • Section 1286, entitled “Initiative to support protection of national security academic research from undue influence and other security threats,” sets out the expectations surrounding limiting foreign influence in national security research. It establishes a pilot program for assessing foreign talent and/or expert recruitment programs.
 Agency-Specific FAQ's:

How do I accomplish "X" if my funding source is "Y"?