The U.S. Government (including federal funding agencies, intelligence agencies and Congress) has expressed increasing concerns about foreign threats to federally funded research activities, including diversion of intellectual property, sharing of confidential information and other breaches of research ethics.
As recipients and stewards of federal funds for research and education, we share a responsibility to acknowledge these threats and ensure that we are protecting the United States' interests by following federal and state laws, as well as University policies, when we engage in international collaboration and research. It is important to note that this applies to all international collaborations, no matter the country involved.
Here are three quick reminders to help ensure compliance with your international collaboration and research:
Denied Party Screening.
At a minimum, if you are participating in an international collaboration, regardless of whether your project is funded, you should be working with the Export Control Office to ensure that you are not working with a denied party, whether that is an entity or person. The Export Control Office may ask additional questions based on the scope of the collaboration.
Disclosure of Conflicts of Interest or Commitment.
Individuals are reminded that the University and some federal funding agencies have a requirement to disclose all financial conflicts of interest and other conflicts of commitment, including receipt of resources and appointments at foreign institutions with or without pay. In the last two years, the National Institutes of Health, Department of Defense, Department of Energy and National Science Foundation have each issued new guidance or a directive on the importance of disclosing these types of potential conflicts during the proposal phase and continuously throughout the project. Links to that guidance are provided below. If you have not already done so, it is imperative that you fully disclose any such arrangements to the Conflict of Interest Office immediately.
Personal Agreements with International Entities.
If you are signing a personal agreement with an international party, be aware that the terms must comply with the West Virginia State Ethics Act and WVU Board of Governors Intellectual Property and Conflict of Interest Rules. You should work with your Supervisor and/or Dean to ensure that any conflict is disclosed and approved prior to signing such agreement. If you have not already fully disclosed such arrangements to your Supervisor/Dean, please use the Outside Consulting Arrangement Approval Form to do so.
Please be aware that issues with undue foreign interference are serious and prevalent at universities across the nation right now. Federal agencies, including the DoJ, FBI and the HHS Inspector General, have identified more than 100 instances of undue foreign interference in extramural research. West Virginia University is committed to continuing our international collaborations with transparency and disclosure.
If you have questions or concerns about your international collaborations, we encourage you to contact Abigail Wolfe as soon as possible. Additionally, the Research Office is scheduling Q&A sessions on this topic that will be hosted at different locations around campus.
National Institutes of Health
- March 30, 2018 Notice regarding Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests
- August 20, 2018 Dear Colleagues Letter reminding applicants and awardees to disclose all forms of support and financial interests in all applications and progress reports
- July 10, 2019 Notice regarding Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
- July 19, 2019 FAQs on Other Support and Foreign Components
Department of Defense
- March 20, 2019 Memorandum detailing disclosure requirements for all Key Personnel
- October 10, 2019 Dear Colleagues Letter discussing the challenge of protecting the integrity of our research enterprise
Department of Energy
- February 1, 2019 Announcement of an internal policy change regarding a prohibition on the ability to participate in a foreign talent recruitment program while receiving DoE funding
- June 7, 2019 DOE Order regarding Foreign Government Talent Recruitment Programs
National Science Foundation
- July 11, 2019 Dear Colleagues Letter reminding Senior Project Personnel to disclose all sources of support and announcing plans to change disclosure requirements