In this Section

Foreign Influence in University Research

The U.S. Government and federal sponsors, such as NIH and NSF, have expressed concerns about improper foreign influence in U.S. academic research. Examples of this include a letter sent by Francis Collins, director of the NIH, alerting the research community to “threats” from foreign entities, another letter sent by France Cordova, director of NSF, as well as the FY19 National Defense Authorization Act, which includes a provision alluding to the restriction of federal funding to institutions doing business with certain Chinese telecommunications companies.  DOD has also expressed concerns and issued a letter that calls upon the academic community to develop and implement best practices to protect American innovation while maintaining the free and open exchange of ideas.

The U.S. Government is also concerned about the active recruitment of foreign scholars into “foreign talent programs” by governments overseas, and their apparent attempts to influence foreign nationals to misappropriate intellectual property and federally funded research results from U.S. research institutions. One example of a “foreign talent program” or “foreign talent recruitment program” is China’s “Thousand Talents Plan”.  Not only should participation in a foreign talent program be disclosed to federal sponsors, researchers should also reach out to their ADR and the Office of Research Integrity and Protections (ORIP) to discuss such 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.

Due to these governmental and sponsor concerns, U.S. research institutions have a heightened awareness and interest in understanding the relationships federally-funded faculty may have with foreign governments or entities. As Syracuse University continues to strengthen existing international collaborations and pursue new opportunities that align with our research objectives and benefit our faculty and students, we ask that faculty and all principal investigators remain mindful of the following requirements:

Required Disclosure of Foreign Research Relationships, Collaborations, Support, or Interests

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” [emphasis added].
    • Activities that meet this definition include (but are not limited to):
      • Extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities
      • Any activity of the recipient 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
      • Receipt of financial support or resources from a foreign entity
  • There are multiple ways in which foreign components can be disclosed, e.g.,
    • 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 Cover Page Supplement Form asking, “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 9-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.
  • Principal Investigators (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 Sponsored Programs to have the error corrected.

For any additional questions or concerns regarding disclosure of foreign research relationships, collaborations, support, or interests on proposals, progress reports, or final technical reports please contact the Office of Sponsored Programs at 315-443-2807.

 

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.
    • Such support should be disclosed on an “Other Support” or “Current & Pending” form.
  • Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through Syracuse University, through another institution, or provided directly to the researcher himself or herself.
  • 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.
  • PIs should review all pending proposals and active awards to ensure that all Other Support has been disclosed.
    • If a PI identifies an omission or error in a previously submitted proposal or progress report, he or she should contact the Office of Sponsored Programs to have the error corrected.

For any additional questions or concerns regarding disclosure of foreign research relationships, collaborations, support, or interests on “Other Support” please contact the Office of Sponsored Programs at 315-443-2807.

 

Intellectual Property

  • To ensure that intellectual property (defined by the Syracuse University Intellectual Property Policy) is protected and reported to sponsors, promptly disclose inventions (technologies) or other intellectual property to the Office of Technology Transfer.
  • If you are active with a company (examples may including serving on a Scientific Advisory Board, holding the title of Chief Technology Officer, CEO, Founder, Board Member, Researcher), given your affiliation to Syracuse University, report your knowledge of foreign investment* held in said company to Syracuse University Office of Technology Transfer.
    • *Foreign investment may include foreign financial investments, foreign nationals as principals and/or substantial equity holders, and corporate partnerships (for example a joint venture) with a foreign company or entity.

For any additional questions or concerns regarding disclosure of foreign research relationships, collaborations, support, or interests related to intellectual property please contact the Office of Technology Transfer at 315-443-5196.

 

Materials, Data, and Confidential Information

  • If materials, data, and/or confidential information will be shared between Syracuse University and another organization, a material transfer agreement (MTA), data use agreement (DUA), or confidentiality agreement may be necessary. Remember that all agreements must be reviewed and signed by institutional officials with appropriate signature authority.

 

Significant Financial Interests

  • Any significant financial interests received from any foreign entity, including companies, governments, and universities, must be disclosed through the Financial Conflict of Interest disclosure system, per Syracuse University Financial Conflict of Interests policy.
    • A few common examples of outside business activities include
      • Foreign consulting
      • Teaching courses at outside organizations
      • Foreign entrepreneurial ventures related to your area of research
  • For any additional questions or concerns regarding disclosure of foreign research relationships, collaborations, support, or interests on a Financial Conflict of Interest disclosure, please contact the Office of Research Integrity and Protections at 315-443-2066.

 

For any general questions or concerns regarding foreign influence, please contact the Office of Research Integrity and Protections at foreigninfluence@syr.edu.