International Relationships & Research Activities

National Institutes of Health (NIH)

• The National Institutes of Health (NIH) requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards. This includes support coming from foreign governments or other foreign entities (see NIH Grants Policy Statement Section 2.5.1).
• NIH requires in grant applications to indicate whether or not the project includes a “foreign component,” and if so, to provide a justification. A foreign component is defined in the NIH Grants Policy Statement, Section 1.2, as “[t]he performance of any significant element or segment of the project outside the United States either by the recipient or by a researcher employed by or affiliated with a foreign organization, whether or not grant funds are expended. Examples include collaboration with investigators at a foreign site; use of facilities or instrumentation at a foreign site; or financial support or resources from a foreign entity. Foreign travel for consultation is not considered a foreign component.”
• NIH Director Francis Collins memo on August 20, 2018 
• FAQs Other Support and Foreign Components (updated 7/19/19) NIH has not substantially changed its expectations of what should be reported but is working to clarify its guidance to respond to recent cases in the realm of undue foreign influence in which activities or resources that should have been reported to NIH and to institutions had not been disclosed. 
• Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (Notice Number NOT-OD-19-114; 7/10/19).

National Science Foundation (NSF)

• National Science Board Statement on Security and Science
• Dear Colleague Letter: Research Protection (NSF 19-200; 7/11/19)
• Request for Comment; National Science Foundation Proposal/Award Information-NSF Proposal and Award Policies and Procedures Guide (84 FR 24827; 5/29/19) Proposed revisions to the PAPP Guide include clarifications to the Current and Pending Support section (see Chapter II.C.2.h).
• Personnel Policy on Foreign Government Talent Recruitment Programs (7/11/19)

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 (DOE)

• 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 (DOD)

• In March 2019, the U.S. Department of Defense (DOD) issued a memorandum stating that proposers for all non-procurement transactions must submit detailed information on other current and pending support for all “key personnel.”
• 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.

NASA

Since 2011, NASA is prohibited "from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no exchange of funds arrangement. Proposals involving bilateral participation, collaboration, or coordination in any way with China or any Chinese-owned company, whether funded or performed under a no exchange of funds arrangement, may be ineligible for award."

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