Foreign Influence and Federal Grants

Foreign Influence

Over the last several years, there has been an increasing concern at the federal level regarding foreign influence in scientific research. Dr. Kevin Droegemeier, former Director of the Office of Science and Technology Policy, wrote a Dear Colleague letter on September 16, 2019 to all U.S. researchers which established four areas of effort to increase research security including:

  • Coordinating outreach and engagement
  • Establishing and coordinating disclosure requirements
  • Developing best practices for academic research institutions
  • Developing methods for identification, assessment, and management of risk

The research being conducted at NDSU and similar institutions across the world have led to ground-breaking scientific advancements and dramatically improved the lives of individuals across the world.  Over the last several years, many federal agencies have reiterated their commitment to a diverse research community funded through a merit-based system which is transparent, collaborative, and free from political or other influences.  The governments of the United States, the European Union, Australia, Japan and others have expressed concern and are calling for stricter policies to mitigate the risk that not all countries share the same principles of scientific integrity.  

NDSU’s core values include the beliefs that we derive strength and vitality from each other and from the diverse communities we serve and as a land-grant university we are welcoming and respectful of differences in people and ideas. We are a diverse population with over 80 countries represented by our graduate students alone. Our commitment to these values is evident in our educational, research, and outreach efforts locally, in our region, our country, and the world. 

In light of the ongoing concerns related to research security and transparency, the White House released a Presidential Memorandum on US Government Supported Research and Development National Security Policy (NSPM-33) and the Joint Committee on the Research Environment (J-CORE) published Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise in 2021.  For additional information on the J-CORE report and the Presidential Memorandum including guidance documents, please visit Research Security and Integrity.

Transparency and Disclosure

While foreign influence is a broad topic, federal funding agencies are focusing on two key elements: transparency and adherence to the fundamental principles of scientific integrity. Each agency is developing its own guidance for reporting financial support and affiliations with foreign institutions so be sure to review the requirements before submitting grant applications.  

At the 2021 NIH Virtual Conference, Michelle Bulls and Kristin Ta, from the NIH Office of Policy for Extramural Research Administrators, spoke on NIH's commitment to transparency.  As part of that presentation, the presenters outlined how NIH defines this commitment.

What is commitment transparency?
Transparency and reporting of all research activities, domestic and foreign
  • Openness and transparency enables productive collaboration and helps ensure appropriate disclosure of potential conflicts of interest and commitment.
  • Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, threatens to distort decisions about the appropriate use of NIH funds.

What can I do?

Disclosure to Sponsors
  • Ensure Biosketches, Current and Pending Support, and Collaborators and Other Affiliations information is updated to reflect the requirements of the funding agency prior to submitting grant applications

As funding agencies are publishing information on how they are meeting the requirements outlined in the J-CORE report and NSPM-33, you can review foreign influence-related information specific to individual Funding Agencies.

Disclosure to the University 
  • Disclose the following in your Annual COI Disclosure in Novelution:
    • outside appointments or positions (foreign and domestic)
    • financial and in-kind contributions.
Foreign Talent Recruitment Programs

Research and Creative Activity has recently been made aware of emails directed to NDSU faculty members which are recruiting involvement in a foreign talent program.  Because this specific foreign talent program in based in China, it is considered by the CHIPS and Science Act of 2022 to be a malign foreign talent recruitment program.NDSU’s research successes have made its faculty targets for recruitment into such programs.

If you have received this email or similar offers, please forward the email/offer to the Export Control Office (ndsuexportcontrols@ndsu.edu).

Questions about foreign talent programs can be directed to the Export Control Administrator Sharon.May@ndsu.edu

REMEMBER YOUR OBLIGATIONS AS A RESEARCHER
If you participate in a foreign talent recruitment program you must disclose such participation or foreign appointment, including any compensation, in-kind or funded research support, or resource provided by the foreign entity. This required disclosure would be made both as an external professional activity and included on appropriate federal forms -typically Current and Pending/Other Support, and/or on a Biosketch.NOTE: as early as 2024, you will not be able to receive or apply for federal funding if you are engaged with a malign foreign talent recruitment program.

  • The US Federal Government has placed restritions on researcher participating in Malign Foreign Talent Recruitment Programs. The Chips and Science Act defines a Malign Foreign Talent Recruitment Program as "any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis." 
  • If you have been asked to do any of the following in connection with a foreign entity, discuss the invitation with your department chair/head, dean, or VP.
    • Engage in the unauthorized transfer of intellectual property, materials, data, or other nonpublic information;
    • Recruitment trainees or researchers to enroll in program or activity or accept a position with a foreign entity;
    • Establish a lab;
    • Form a company;
    • Accept a faculty position or other employment;
    • Sign a contract or agreement which you are unable to terminate except in extraordinary circumstances;
    • Commit a specified amount of time to work for the foreign institution;
    • Engage in work which would overlap with your NDSU research;
    • Apply for or receive funding from a foreign government that would be awarded to the foreign institution;
    • Omit acknowledgement of a foreign institution, or any US federal research sponsor;
    • To not disclose to NDSU or the federal government, your affiliation with the foreign institution.
Other Tips:

    RCA Contacts

    If you have questions about federal agency responses to foreign influence specific to the areas below, contact the following individuals:

    Grant Proposals
    Contact: Val Kettner 
    Sponsored Programs Administration

    Conflict of Interest
    Contact: Kristy Shirley
    Research Integrity & Compliance

    International Travel
    Contact: Sharon May 
    Export Controls

    International Collaborations
    Contact: Sharon May 
    Export Controls
    Export Controls
    Contact: Sharon May 
    Export Controls
    Invention Disclosures
    Contact: Joycelyn Lucke
    Industry Engagement & Intellectual Property
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