Undue Foreign Influence on Research
The US Government has implemented procedures designed to detect undue foreign involvement in federally funded research. Investigators pursuing federal funding are required to disclose a broader range of collaboration with foreign entities – beyond what has previously been required in Biosketches and Current and Pending Support. In some circumstances, failure to disclose may involve civil and/or criminal penalties for the investigator. There is also new guidance on budget preparation and related proposal elements.
ECU is also responsible for providing faculty and staff with sufficient information and training to ensure appropriate reporting. ECU would also be subject to audit and possible sanctions if it fails to provide appropriate training and subsequent monitoring.
Please refer to the links below for specific details on NIH and NSF requirements.
Changes Relevant to Faculty
The concept of Biosketch and Other Current and Pending Support has expanded significantly. The government is requiring disclosure of collaborations and arrangements which previously were not subject to disclosure. This disclosure may be required during proposal submission, at award acceptance, and/or in narrative reports (both progress reports and final reports). Though there are efforts underway to have agencies use consistent processes and forms, as of May 2022, there remain significant distinctions among federal agencies regarding disclosures. Therefore, the regulations are in flux and we will update the campus community as they coalesce.
The NIH and NSF have published tables depicting specific requirements (see the links below). See also the updated definitions and guidance as to information that must be included.
Beginning June 1, 2022, training in Foreign Influence is required for all PIs, coPIs and Key Personnel submitting proposals to NSF, NIH and DOD. REDE has made available a new training program on this topic through CITI. Unless it changes substantively, training needs to be completed once.
In 2021, the White House released a Presidential Memorandum on United States Government-Supported Research and Development National Security Policy (NSPM-33) which directed federal research agencies to “strengthen protections of United States Government-supported Research and Development (R&D) against foreign government interference and exploitation”.
In January 2022 the government issued additional guidance related to NSPM-33 which establishes a timeline of 120 days for all federal agencies to reach consensus in format, information required, and definition of terminology. In the interim, NIH and NSF have issued guidance of their own that are required for submissions, Just-in-Time responses, and related material as of January 25, 2022.
It is critical that ECU faculty are aware of the new requirements and follow the guidance provided.