Rising concern

The U.S. Government has expressed concerns about the failure of researchers to disclose their relationships and activities with foreign institutions and foreign funding agencies to their research sponsors and/or to their own institutions. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize an investigator’s or an institution’s eligibility for future funding.

  1. National Institutes of Health (NIH) 

    The NIH has issued communications to the research community at large and to its grantee institutions (including MU) to convey the NIH's pride in supporting researchers from all over the world who have made “seminal biomedical discoveries” at U.S. institutions and universities. However, the NIH also noted in these communications their concerns about the integrity of the biomedical research it funds and the risk that foreign influence poses to that integrity. Among the issues identified, the NIH is troubled by the 
    • Diversion of intellectual property (IP) in grant applications or produced by NIH-supported biomedical research to other entities, including other countries; [and the] 
    • Failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds. 
  2. Department of Defense (DoD)

    The DoD continues to affirm its support for the “free exchange of ideas, transparency, and collaboration across research communities” because those values are critical to the success of the research partnerships between the DoD and U.S. universities. However, the DoD is also requesting that universities continue to identify and take appropriate action(s) to protect the integrity of the research it funds and the intellectual capital that results from that research. 

    The FY 2019 National Defense Authorization Act (NDAA) directs the DoD to work with academic institutions to limit the undue influence of foreign talent programs and support protection of intellectual property. It further calls for the DoD to develop regulations in this area and limit or prohibit funding for institutions or individual researchers who violate them. Additionally, the NDAA directs the DoD to prioritize funding of academic institutions that have a record of excellence in industrial security. 

    One step the DoD has taken is to implement a requirement that key personnel supported by DoD sponsored research and research-related educational activities must disclose information about all sources of their research support, regardless of whether those individuals’ efforts are to be funded by the DoD. The memo specifies that the information to be collected will be “used to support protection of intellectual property…[and]limit undue influence, including foreign talent programs, by countries that desire to exploit United States' technology.” 

The requirement to disclose all sources of research support has always been a part of the sponsored research enterprise; requests for full and open disclosures are not new mandates being implemented by research sponsors. Instead, sponsors are looking to reduce the discrepancies they have noted in some researchers’ disclosures of affiliations and funding.


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Email: exportcontrols@missouri.edu Phone: 573-884-9954