Emerging Federal Guidance on Foreign Influence

Recently, the issue of foreign influence and academic research has received considerable attention by federal agencies that support research in academic institutions. The federal regulatory landscape is evolving as federal agencies update their policies and regulations. It is imperative that the CSU research community stays abreast of these changes and that everyone understands what actions to take to remain compliant.

CSU supports academic freedom and is committed to maintaining an open and transparent research environment that welcomes the participation of researchers from around the world. It is equally important that we support the research enterprise by complying with regulatory requirements. The Office of Research and the Office of University Compliance will continue to follow these developments and update you on changes in federal regulations and policies as they happen.

Federal agencies have issued statements expressing growing concerns over the potential for foreign influence in the following areas:

1. Failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments;
2. Diversion of intellectual property to foreign entities;
3. Sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.

The Office of Research wants to emphasize to colleagues at all levels that full and timely disclosure regarding research support and conflicts of interest is essential to the transparency the government requires and Cleveland State expects. All investigators on sponsored projects should check the sponsor’s current disclosure requirements carefully and, if in doubt, contact SPRS at 216-687-3675 for disclosure assistance or further guidance.  In addition, investigators should take the following actions:

• Complete a Conflict of Interest disclosure at the time a new grant proposal is submitted, and at least annually;
• Ensure appropriate disclosure of foreign components for NIH-supported projects;
• Fully and accurately complete all funding agency questions regarding any current and pending requests for financial support;
• Report all reimbursed or sponsored foreign travel related to federally-supported projects;
• With the assistance of the Technology Transfer Office, enter into a material transfer agreement or nondisclosure agreement when sharing or exchanging materials or information.

Emerging Federal Guidelines

The Office of Research has created this web page to help Cleveland State faculty and staff to stay current with emerging federal guidelines. Cleveland State University values its international collaborators and inter-institutional affiliations. Preservation of important international relationships will be facilitated by our careful attention to federal requirements of transparency in research and related activity.

Disclosure of Involvement

• Letter to U.S. Research Community from Office of Science and Technology Policy - September 16, 2019
• NSF Dear Colleagues Letter: Research Protection - July 11, 2019
• Department of Defense Memo - Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies - March 20, 2019
• Science article on DOE policies - February 8, 2019
• NIH Dear Colleagues Letter - August 20, 2018

Disclosure of Funding Support

• Science article on NIH investigation – July 5, 2019
• Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components NOT-OD-19-114 - July 10, 2019
• Advisory Committee to the NIH Director Working Group on Foreign Influences on Research Integrity
• NIH Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests - March 30, 2018

Funding Agency Positions

• DOE Order on Foreign Government Talent Recruitment Programs - June 7, 2019
• NSF Rotators must be U.S. citizens or have applied for citizenship

Contact Information

For questions related to proposal and award requirements, please contact the appropriate group below:

• If you are developing a proposal, please contact SPRS
• If you have a question related to an award that has already been funded, please email sprscontracts@csuohio.edu.
• All inventions should be promptly disclosed to the CSU Technology Transfer Office, and to the sponsor when required.

For questions related to Export Control, please email j.kraszewski@csuohio.edu.