In August 2018, Dr. Francis Collins issued a letter to grantees and published a Statement on Protecting the Integrity of U.S. Biomedical Research. In these documents, NIH highlighted the following areas of concern:

1. Diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries;
2. Sharing of confidential information by peer reviewers with others, including with foreign entities, or otherwise attempting to influence funding decisions; and
3. Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.

In July 2019, NIH issued Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components and accompanying FAQs on Other Support and Foreign Components. The NIH’s Advisory Committee to the Director Working Group on Foreign Influences on Research Integrity continues to work to address concerns.

In July 2020, NIH released a website on Protecting U.S. Biomedical Intellectual Innovation. The site describes NIH concerns and requirements for disclosures, as well as explains responsibilities of institutions and the NIH.

The National Science Board, in October 2018, issued a Statement of the National Science Board on Security and Science, which emphasizes that “U.S. universities and colleges must help promote scientific openness and integrity and safeguard information that impacts national security and economic competitiveness.” The Director of the NSF released a Dear Colleague Letter on Research Protection in July 2019. NSF also issued a policy that their agency personnel and IPAs may not participate in foreign government talent recruitment programs. NSF commissioned a study and report from JASON on Fundamental Research Security, which proposed steps that NSF can take to improve the security of fundamental research.

The Department of Energy (DOE) released a Memorandum in January 2019 that contains a policy prohibiting DOE personnel from participating in foreign talent recruitment programs. DOE provided further guidance to their employees and contractors in Order 486.1A and clarifications in the FAQs for DOE O 486.1A. The FAQs indicate that working at a DOE site requires compliance with the prohibition on participating in a foreign government-sponsored talent recruitment program. DOE also released Order 142.3B which relates to their agency’s unclassified foreign national access program. Inclusion of Order 142.3B in a contract may necessitate additional procedures. Please contact RSP should you have questions about these orders. Also see the RSP webpage DOE Research Security Overview for further information about these orders and other requirements.

The Department of Defense (DoD) issued a Memorandum in March 2019 that delineated information to be provided for senior/key personnel as part of a proposal and that the information would be used for purposes including protection of intellectual property and limiting undue influence. DoD also issued, in October 2019, a letter to universities and research centers describing their efforts to protect the integrity of the U.S. research enterprise and asking for support in doing so.

In June 2020, OSTP released a presentation on Enhancing the Security and Integrity of America’s Research Enterprise. This presentation highlights some specific cases and areas of ongoing concern. OSTP is working on additional guidance for academic research institutions.

In September 2019, the Director of the Office of Science and Technology Policy sent a Letter to the United States Research Community in which he emphasizes the importance of protecting the integrity of our nation’s research enterprise.

Faculty and staff participate in sponsored research projects that necessitate either funded or non-funded agreements to be negotiated with outside entities. Offices such as Research and Sponsored Programs review and negotiate these agreements to ensure that the interests of the PI, the University, and the State are all adequately protected and that the legal obligations of the agreement do not conflict with the University’s research mission or its policies. When researchers engage in sponsored projects with any entities, including foreign entities, they should be sure to:

• Initiate appropriate agreements between UW – Madison and the outside institution. See Agreement Negotiation
• Properly attribute UW – Madison and outside institution in publications resulting from sponsored projects.

Sponsors generally expect to be informed at the time of proposal if research activities will take place outside of the United States. If not anticipated at the time of proposal, sponsors may require prior approval for such activities. Researchers may need to:

• Disclose and request permission for activities outside the United States, for example:
  • NIH research application instructions: see instructions related to international collaborators or foreign component)
  • NIH prior approval requirement for foreign component or foreign subaward
  • NSF proposal instructions on foreign organizations
  • NSF prior approval requirement for all subawards, including those to foreign entities
• Report on activities that occur outside the United States, for example:
  • NIH RPPR instructions; (see instructions related to participants affiliated with a foreign organization; award budget being spent in a foreign country; or foreign component)
  • NSF RPPR instructions (see instructions related to participants or partner organizations)

Federal agencies have made clear that they expect researchers to disclose all research support, including from foreign sources.

• Disclose your outside appointment on all Other Support/Current & Pending Support documents or progress reports
• Disclose and equipment or other resources provided to you as part of this appointment in the appropriate sections of your grant proposal or progress reports
• Disclose any foreign graduate students, post-docs, or other personnel working on your federally funded projects
• Specific agency guidance includes:
  • NIH: NOT-OD-19-114; Just-in-Time Procedures
  • NSF: NSF-Approved Formats for Current and Pending Support; Current and Pending Support
  • Dept. of Defense: Memorandum

See also the Other Support Information page.

Researchers must be transparent in their biographical sketches about any outside academic, professional, or institutional appointments, whether paid or not, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

• Disclose your outside appointment as part of your biographical sketch
• Properly attribute UW – Madison and outside institution in publications
• Specific agency guidance includes:
  • NIH: Biosketch Format Pages, Instructions and Samples
  • NSF: Biographical Sketch(es)

Researchers must disclose any inventions resulting from work performed as part of their University of Wisconsin-Madison duties, using University funding, or using University premises, supplies, or equipment.

• UW Research - Intellectual Property
• UW Research - Disclosing an Invention

Federal agencies have expressed concerns about ensuring that individuals maintain confidentiality on all proposal review panels. Specific agency guidance includes:

• NIH: Integrity and Confidentiality in NIH Peer Review
• Conflict-of-Interests and Confidentiality Statement for NSF Panelists