Foreign Influence in Research

At this time, the best course of action is to disclose any and all activities that involve a foreign entity, including foreign sponsors and/or collaborators, in grant and contract proposals to federal agencies.

If your research is supported by federal funding, you should update and maintain your documentation listing sources of funding support for research (current and pending support, other support, etc.). Include support you secured through NIU and as an individual.

Here are some key ways you should disclose foreign components in your applications:

• Identifying a foreign component in an application.
• Listing a non-U.S. performance site.
• Identifying foreign relationships and activities in a biosketch.
• Answering yes to the following question on the federal grant application form: Does this project involve activities outside of the United States or partnerships with international collaborators?

Inform yourself of all sponsor requirements and follow all directions for content and format.

If you identify an omission or error in a previously submitted proposal, contact SPA for assistance.

Please review the following agency requirements on including appropriate sources of support and affiliation. We expect the agencies to continue to update the requirements.

National Science Foundation (NSF)

NSF has issued FAQs to clarify Current and Pending Support reporting requirements.

Investigators should disclose all forms of support as directed in these FAQs.  

• Current and Pending Support is a required component for NSF proposals. Include all sources of support regardless of whether salary is requested.
• Biosketch.
• Collaborations and other affiliations.

Foreign Components

• The NSF rarely provides direct funding support for foreign organizations and will only consider cooperative projects involving U.S. and foreign organizations when certain criteria are met.
• If the proposal includes funding for a foreign organization, the box for “Funding of a Foreign Organization, including through the use of subaward or consultant arrangement” must be checked on the cover sheet.
• Proposals that describe an international activity must list the primary countries on the cover sheet. NSF defines international activity as research, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the U.S. using virtual technologies.

National Institutes of Health (NIH)

In summer 2019, NIH issued Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components, which clarified reporting requirements.

• Other Support: For NIH, collection of Other Support is done at the "Just in Time" phase before an award is made. It is also required in progress reports, when key personnel are added, or if there are changes in support from the original Other Support submission.
• Biosketch.

Foreign Components

Prior approval is required before adding a foreign component to an NIH project. NIH defines foreign component as the performance of any significant scientific element or segment of a project outside of the United States either by the recipient or a researcher employed by a foreign organization, whether or not grant funds are expended.

Examples of foreign components:

• Involvement of humans or animals at a foreign site.
• Extensive foreign travel by grantee project staff for activities that support the project, such as collecting data, surveys, samples or similar activities.
• Any activity of the grantee or foreign researcher affiliated with the project that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.
• 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.

The following are not considered foreign components:

• Foreign travel for consultation.
• A visiting scholar working in a U.S. lab/site on the NIH project.

Department of Energy (DOE)

In 2019, DOE issued Order 486.1 regarding disclosures and prohibitions on foreign funding.

• Refer to the specific DOE Funding Announcement instructions on Current and Pending Support
• See DOE guidance under foreign talent programs below. This guidance applies to joint appointments and contracts with the national laboratories. It does not currently apply to DOE grants.

Department of Defense (DOD)

In 2019, DOD issued a memorandum (PDF) directing actions to protect intellectual property, controlled information, key personnel and critical technologies.

• Refer to the specific Notice of Funding Opportunity (NFO) for details on requirements for current support documentation from all key personnel at the proposal stage.
• This information will be required for all key personnel whether or not they are being paid from the DOD project award/budget.
• See DOD guidance under foreign talent programs below.

National Aeronautics and Space Administration (NASA)

Federal law restricts NASA from providing funding to participate, collaborate or coordinate bilaterally in any way with China or any Chinese-owned company at the prime (NIU) level or at any subrecipient level. This restriction does not apply to NIU faculty, staff or students who may be Chinese foreign nationals.

The Department of Energy (DOE) has published a directive providing detailed guidance on participation by DOE-funded researchers in foreign talent programs.

Effective June 7, 2019, DOE does not allow participation in foreign talent programs by its employees as well as contractor personnel. DOE defines such programs as “any foreign-state-sponsored attempt to acquire US scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.”

DOE will maintain a list of foreign talent programs that fall under this ban.

This policy applies to those receiving DOE contract funding and national lab joint appointments. While the policy does not specify grant recipients or individuals funded under cooperative agreements at this time, we can anticipate further policy development at a later date.

A researcher wishing to seek DOE funding who is in such a talent program must remove their association with the talent program before receiving DOE funding. Please see:

• DOE current requirements and guidance on this ban (PDF).
• Specific DOE Funding Opportunity Announcements (FOA) for current and pending support requirements.

DOD is also developing policies to limit or prohibit funding provided by the Department of Defense for institutions or individual researchers who knowingly participate in foreign talent programs.

If you are, or have ever been part of, a foreign talent program you must disclose this information to the Office of Research Compliance, Integrity and Safety right away.

In accordance with NIU policy and federal regulations, investigators must promptly report all inventions to:

• The university’s Office of Innovation.
• Federal sponsors as part of progress reporting.

Researchers must take reasonable efforts to protect the university’s interest (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their NIU research.

Intellectual property developed under a sponsored research agreement is subject to the university’s Intellectual Property Policy.

Grant Proposals

Director, SPA Pre-award

Investigators are responsible for including information about any foreign support consistent with the funding agency requirements in their sponsored projects documents.

Conflict of Interest

Director, Research Compliance, Integrity and Safety

Conflicts of interest in research are situations in which financial or other personal considerations may compromise, or have the appearance of compromising, an investigator's judgment in conducting or reporting research.

International Travel

Director, Research Compliance, Integrity and Safety

When traveling abroad there are three basic questions to consider when determining if export controls apply:

• Where are you going?
• What are you taking with you?
• What are you doing and who will you be interacting with?

In general, travel to most countries is not a problem.

If you have questions about the security of your technology please review the Information Security Guidelines for Travel.

Foreign Collaborations and Export Controls

Director, Research Compliance, Integrity and Safety

In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export-controlled or restricted research or involve scholars in sanctioned countries. Export licenses are prior approvals from the government that allow participation of foreign national faculty, staff or students to be involved in research.

Before engaging in an international collaboration, the Office of Research Compliance, Integrity and Safety will determine if export licenses are required and verify that the foreign individual and/or organization are not blocked or sanctioned entities.

Invention Disclosures

Assistant Director, Office of Innovation

Researchers must make reasonable efforts to protect the university’s interest (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their NIU research. The Office of Innovation works with researchers to make sure intellectual property is properly protected and managed according to the university’s Intellectual Property Policy.