Page Updated: September 21, 2021
UW-Madison values the contributions of and collaborations with researchers from around the world. Our campus’ diverse research community and the openness of our research enterprise has enabled our institution to make discoveries that create a better nation and world.
University leaders make clear in their blog post that UW-Madison is committed to scientific collaboration and openness. They also acknowledge the importance of being transparent about foreign relationships and activities.
These relationships and activities are being paid increased scrutiny. The campus community should be aware that disclosures of relationships and activities are receiving national attention and impacting institutions of higher education around the country. Members of Congress and several federal sponsors have expressed significant concerns about perceived undue foreign influence on the U.S. research enterprise.
It is clear that all federal agencies take this issue very seriously. The best advice at this point is to be sure to disclose any and all activities that involve a foreign entity.
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:
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.
Federal funding agencies have an expectation that investigators are open and transparent about all outside appointments with foreign entities. It does not matter if these appointments are compensated or not. They must be disclosed on Other Support/Current and Pending Support, progress reports, or by other means as required by the sponsor.
If you have or are planning to apply for federal funding, there are several important things to remember. Federal agencies are especially concerned about outside appointments with foreign entities, and it is critical you take the actions described below. Federal agencies’ guidance continues to evolve, so please pay close attention to individual agency instructions.
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:
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:
Federal agencies have made clear that they expect researchers to disclose all research support, including from foreign sources.
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).
Federal agencies have expressed concerns about ensuring that individuals maintain confidentiality on all proposal review panels. Specific agency guidance includes: