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Department of Defense letter to universities

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Updated: Letter from Department of Defense to Universities

 


International Relationships and Activities

Introduction

The U.S. Government has expressed serious growing concerns regarding inappropriate influence by foreign entities over federally funded research. One issue that has moved to the forefront is the failure of federally-funded researchers at U.S. institutions to disclose their relationships and activities with foreign institutions and funding agencies. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding. Federal agencies such as the National Institutes of Health have issued "Dear Colleagues" letters calling on universities to be vigilant in watching for potential foreign influence, including intellectual property theft, sharing of confidential information and failure of researchers to disclose resources provided by other organizations.

As a Carnegie Tier One research university, the University of North Texas takes great pride in the partnerships and research collaborations we have built with universities and organizations worldwide. UNT is a place where people from every culture and background bring creativity to advance global knowledge. We are committed to fostering international collaborative partnerships while promoting full transparency about our relationships.

While UNT encourages international collaborations, it is important for our investigators to be transparent about their foreign relationships and activities. UNT wants to raise awareness within the UNT campus community regarding issues of improper foreign influence in scholarship. UNT has in place prudent policies to protect against potential influence. We want to remind all of our UNT employees who conduct research that you must disclose foreign relationships and activities.

Best Practices for Disclosing Foreign Relationships and Activities

While most international collaborations are encouraged, UNT urges researchers to be transparent on all of their foreign relationships and activities. VPRI will work closely with Office of Research Integrity and Compliance to support advising for each scenario.

The items below contain guidance regarding the types of relationships and activities that UNT researchers are expected to disclose:

  1. Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports. Under the NIH Grants Policy Statement, a Foreign Component is defined as “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." The definition of “foreign component” may include a large number of collaborative activities, including “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.” Other sponsors have similar requirements to disclose foreign components.

    There are multiple ways in which foreign components can be disclosed:

    • Identifying a “foreign component” in an NIH grant application;
    • Listing a “non-U.S. performance site;"
    • Identifying foreign relationships and activities in a biosketch;
    • Checking “yes” to the question on the OGCA pre-award proposal form, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
    • Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a nine-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

    PIs should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Integrity and Compliance or OGCA to correct the omission or error.

  2. UNT researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors. “Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through UNT, through another institution, or provided directly to the researcher himself or herself.

    An issue that is garnering a great deal of scrutiny by the federal government is participation in foreign talent programs, such as China’s Thousand Talents Program. Not only should participation in a foreign talent program be disclosed to federal sponsors, UNT researchers should also reach out to the Office of Research Integrity and Compliance to discuss the activity, even if they’ve previously disclosed their participation to other university officials. Depending on an individual’s research portfolio, he or she may be advised to terminate his or her affiliation with the foreign talent program.

    Most federal sponsors will have their own guidance on how to complete “Other Support” forms. It is ultimately the responsibility of the individual researcher to ensure that the report of "Other Support" is complete and accurate to the best of his or her knowledge, so PIs should review all pending proposals and active awards to ensure that all other support has been disclosed.

  3. Significant financial interests received from any foreign entity, including governments and universities, must be disclosed, per UNT’s Conflict of Interest Program (https://unt.az1.qualtrics.com/jfe/form/SV_38HHP7zKw5Xqj09). This requires disclosure of remuneration from foreign entities greater than $5K including “Sponsored Travel” greater than $5K received in a 12-month period. If you are unsure whether an interest or remuneration meets this definition, please contact the Office of Research Integrity and Compliance at untcoi@unt.edu.
  4. Disclose all foreign consulting and other outside business activities as required per Conflict of Interest Policy. A few common examples of outside business activities include consulting, teaching courses at outside organizations, or entrepreneurial ventures related to your area of research.
  5. Contact IT Shared Services (ITSS) at security@untsystem.edu or regarding any compromised accounts or other IT threats.
  6. Report inventions or intellectual property to Michael Rondelli, (michael.rondelli@unt.edu) in the Office of Innovation and Commercialization.
  7. Export compliance concerns, including foreign travel, and shipping or taking items outside the United States should be reported to Office of Research Integrity and Compliance Jamie Peno (jamie.peno@unt.edu) or Justin Cook (justin.cook@unt.edu).