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    Research Security and Foreign Interference at U.S. Academic Institutions

    Over the past decade, Congress, federal science agencies, and the media have highlighted concerns about the impact of undue foreign influence on federally funded research in the United States. For institutions, this means an increased focus on research security and the need to update internal policies and processes, while maintaining a focus on the value of a global workforce and international scientific collaborations. This page provides background information, the latest updates on relevant federal government policies and activities, and considerations and resources for institutional leadership, administrators, and researchers as they address this issue on their campus.

    Latest Federal Policy Updates

    Updates on NIH Activity and Policies for the Grantee Community

    The National Institutes of Health (NIH) has been actively involved in the issue of foreign influence since an August 2018 letter sent out to grantee institutions on agency concerns. Since that time, NIH staff have contacted institutions regarding 255 cases where there were likely foreign interference concerns with scientific or budgetary overlap, overcommitment, or undisclosed financial conflicts of interest.

    The NIH posts the latest updates on how the agency is handling this issue on its Foreign Interference page. Details about these agency policies and activities are below.

    September 2022. The NIH issued a notice to remind the extramural community about existing policies and regulations around financial conflicts of interest and other support.

    June 2022. The NIH updated a table which extensively details the required pre- and post-award disclosures relating to the Biographical Sketch and Other Support.

    December 2021. The NIH issued a guide notice, “Maintaining Security and Confidentiality in NIH Peer Review: Rules, Responsibilities and Possible Consequences,” to remind all participants and invested parties in the NIH peer review process of federal statutes, regulations, and NIH policies regarding peer review security and confidentiality; their responsibilities for abiding by those rules; and possible actions that the NIH (in coordination with other offices) may take and consequences that may ensue from a violation of those rules.

    July 2021. The NIH published a summary of findings on foreign research interference from 2016 to 2021, highlighting the major issue areas and sharing four scenarios based on real cases, outlining the situation and the consequences/corrective actions taken.

    December 2019. During an update at the Dec. 13 meeting of the NIH Advisory Committee to the Director (ACD), NIH Deputy Director for Extramural Research Mike Lauer, MD, listed several updates the agency had taken to carry out recommendations from the ACD report (see December 2018, below), including clarifying other support, working with the National Science Foundation (NSF), and implementing peer review training and systems controls.

    September 2019. The Department of Health and Human Services (HHS) Office of Inspector General released three reports related to financial conflicts of interest (FCOI), foreign influence, and the steps the NIH is taking to protect research integrity.

    July 2019. The NIH released a guide notice and FAQs noting that institutions receiving extramural funding from the NIH are subject to several relevant policies and regulations:

    • The NIH Grants Policy Statement (NIHGPS) requires grant applicants to disclose Other Support to ensure no scientific, budgetary or commitment overlap, including “all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual's research endeavors.” (Section 2.5.1).

    • The NIHGPS also requires recipients to determine whether activities it supports include a foreign component, which may or may not involve the direct use of NIH grant funds (e.g., performance of work by a researcher or recipient in a foreign location or a collaborator outside of the United States who performs experiments in support of an NIH-funded project or with an expected co-authorship).

    • Federal conflict of interest regulations (42 CFR Part 50, Subpart F) include a requirement for researchers to disclose to their intuitions significant financial interests (SFIs) in addition to any reporting required by NIH policy (learn more on the AAMC's Conflicts of Interest and Transparency Initiatives page).

    • The NIH clarified in 2018 that while these regulations do not require disclosure of certain SFIs from “an Institution of higher education,” this is only for U.S. institutions, and remuneration from foreign institutions is a disclosable SFI.

    • A related FAQ updated July 11, 2019, confirms that these policies and regulations are already in place and that the guide notice serves as a reminder to the community, not an expansion of the Other Support policy.

    • A blog post from the NIH Office of Extramural Research (OER), provides additional context for the timing of the guide notice and states that “depending on the severity and duration of the noncompliance … [the office] may contact the affected institutions, impose specific award conditions, disallow costs, withhold future awards for the project or program, suspend the award activities, make a referral for investigator suspension or debarment, or terminate the award.”

    December 2018. An NIH Advisory Committee to the Director released a report on foreign influences and research integrity, containing recommendations for recipient organizations related to:

    • Communicating with investigators (education campaigns on disclosure requirements and guidelines for visitors).

    • Mitigating risk (assessment of internal controls, proactively notifying the NIH about breaches).

    • Ongoing monitoring (developing flags for audit, considering post-travel questionnaires for select countries, and working with federal security agencies on best practices).

    August 2018. NIH Director Francis Collins, MD, PhD, issued a statement and sent a letter (PDF) to over 10,000 grantee institutions, outlining three areas of concern for the agency:

    • Diversion of intellectual property to other entities, including other countries.

    • Sharing of confidential information on grant applications by NIH peer reviewers with others.

    • Failure by researchers working at NIH-funded institutions to disclose substantial resources from other organizations.

    The letter also noted that the NIH OER would reach out to specific institutions “regarding grant administration or oversight questions or requests about specific applications, progress reports, policies, or personnel.”

    White House OSTP and Government-Wide Coordination

    The National Science and Technology Council (NSTC), overseen by the White House Office of Science and Technology Policy (OSTP), launched the Joint Committee on Research Environments (JCORE) in May 2019. A subcommittee focused on research security, comprised of 17 agencies from across the government, is working on coordinating federal outreach to research institutions, developing guidance and best practices, and standardizing conflict of interest and commitment disclosure requirements and enforcement. The National Science Foundation is a key agency partner in this effort and maintains a collection of resources on this topic. As of early 2024, we are waiting on the release of a final requirement for a research security program and will update this page when it is released.

    February 2024. The OSTP released updated guidance on two key topics:

    January 2024. The NSF released four interactive online research security training modules covering (1) an introduction to research security, (2) the importance of disclosure, (3) managing and mitigating risk, and (4) the importance of international collaboration.

    June 2023. The AAMC responded to a request for information from the OSTP regarding a draft National Security Presidential Memorandum 33 (NSPM-33) research security programs standard requirement. This requirement is described in the memorandum’s implementation guidance (PDF) released last year, which expands on the provision that “research institutions receiving Federal science and engineering support in excess of 50 million dollars per year certify to the funding agency that the institution has established and operates a research security program. Institutional research security programs should include elements of cyber security, foreign travel security, insider threat awareness and identification, and, as appropriate, export control training.”

    October 2022. The AAMC submitted comments to the NSF requesting feedback on behalf of the NSTC subcommittee on proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of a research application, intended to clarify what is expected of senior personnel applying for research funding from federal agencies. The association additionally submitted a joint letter (PDF) with partner higher education organizations, highlighting the importance of clarifying definitions, ensuring a transparent and uniform process for updating the common forms, and limiting agency variation in required disclosure data elements and instructions.

    January 2022. The NSTC JCORE research security subcommittee released a report (PDF) containing guidance for federal departments and agencies regarding their implementation of NSPM-33. The five key areas covered in the document are: disclosure requirements and standardization, digital persistent identifiers, consequences for violation of disclosure requirements, information sharing, and research security programs.

    September 2021. The AAMC sent a joint letter on Sept. 30 in response to a request for feedback from the White House OSTP on implementing the research security guidelines in the NSPM-33. The comments emphasized building on existing policies created by institutions to address research security; recognizing that the vast majority of university research is open and unrestricted and should not be subject to research standards from the commercial sector; and incorporating the use of pilot programs and continued community engagement as any new policies are implemented.

    January 2021. The White House issued NSPM-33, which “directs action to strengthen protections of United States Government-supported Research and Development (R&D) against foreign government interference and exploitation.”

    At the same time, the NSTC JCORE subcommittee on research security released recommended practices for research organizations to strengthen the security and integrity of the research enterprise.

    January 2020. The AAMC sent a letter to the OSTP in response to a request for information on actions that federal agencies can take, working in partnership with private industry, academic institutions, and nonprofit/philanthropic organizations, to maximize the quality and effectiveness of the research environment, including protecting the security and integrity of the research enterprise.

    November 2019. the AAMC participated in the JCORE summit to discuss research security and other issues, a summary of which is available online (PDF).

    September 2019. White House OSTP Director Kelvin Droegemeier, PhD, sent an open letter (PDF) to the research community, reaffirming the importance of using a risk-based framework to evaluate research security concerns and highlighting the progress of the OSTP in coordinating federal efforts.

    The AAMC previously joined over 60 organizations on a Sept 4 letter (PDF) to the OSTP and federal research funding agencies (the NIH, the NSF, the departments of defense and energy) stressing the importance of balancing “an openly collaborative scientific environment and protecting our economic and national security.”

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