The National Institutes of Health (NIH) recognizes research risks regarding peer review integrity, intellectual property and failure to disclose interests. UAMS is committed to full transparency with external sponsors, industry and foreign entities.

1. Foreign components must be disclosed on proposals, progress reports, and final reports of federally funded research (e.g., NIH Grants Policy Statement). Other sponsors (e.g., NSF ; DOD) have disclosure requirements as well.

Foreign component disclosure can take many forms:

  • 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 “Does this project involve activities outside of the United States or partnerships with international collaborators?” on the Cover Page Supplement form.
  • Financial resources must be disclosed even if  work is performed outside a researcher’s appointment period (e.g., if a researcher with a 9-month appt. spends two summer months at a foreign university doing research under a foreign award, that work must be disclosed).
  • Principal Investigators (PIs) must review all pending proposals/active awards for all foreign component disclosures. If a PI identifies an omission or error in a submitted proposal, the PI must contact the Office of Research and Sponsored Programs to correct the error.

2. UAMS researchers must disclose all applicable “Other Support” as required by federal sponsors. UAMS systems (TRACKS, nTRACTS) record proposals, grants, or contracts processed through UAMS, but do capture other activity (i.e., outside UAMS research). Sponsors require all support sources be disclosed, regardless of whether they are awarded to UAMS, another institution, or directly to the researcher. (See NIH’s most recent guidance NOT-OD-19-114; NIH Other Support FAQs).

Participation in any foreign talent program must be disclosed to federal sponsors. UAMS researchers must contact the Office of Research to discuss such activity. Depending on a PIs research, he/she may be advised to terminate affiliation with a foreign talent program.

3. Any financial interests received from a foreign entity, including governments and universities, must be disclosed per UAMS Administrative Guide 4.4.13 and Office of Research Compliance. If you question if a particular interest or remuneration meets the definition, please contact the Research Compliance Officer.

4. Required disclosure of all industry interaction/consulting is found in policy 4.4.12 (e.g.,  foreign consulting, teaching at outside organizations, or entrepreneurial ventures related to your research). UA outside employment requirements are in Board Policy 450.1.

5. Detailed guidance regarding foreign travel. UAMS Visa FAQs and U.S. Dept. of State Visa processing has additional information.

6. Contact the CIS Officer and Director of IT Security regarding any compromised accounts or other IT threats.

Federal Reports and Communications

Dept. of Defense Letter to Universities – October 10, 2019

Federation of American Scientists and leading science, engineering and international education organizations send letter to federal agencies regarding foreign influence policies – September 4, 2019

NSF Director, Dr. France Córdova, Dear Colleague Letter on Research Protection – July 11, 2019

NIH, Office of the Director, 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

NIH Advisory Group to the Director, Working Group on Foreign Influences on Research Integrity Update – June 19, 2019

Memo from the Under Secretary of Defense on Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel, and Critical Technologies – March 20, 2019

NIH released slides outlining 3 key areas of concern — undisclosed foreign financial conflicts, undisclosed conflicts of commitment and peer review violations — from the 117th Meeting of the Advisory Committee to the NIH Director – December 13, 2018

NIH Director Francis Collins’ letter to awardee institutions, with 3 areas of concern (IP handling, peer review violations, failure to disclose interests) – August 20, 2018

Foreign Corrupt Practices Act – February 3, 2017

Foreign Influences – In the News

Founder UC San Diego Institute for Genomic Medicine Resigns
Clarifying Long-Standing NIH Policies on Disclosing Other Support
NIH Probe of Foreign Ties
Balancing science and security
Breaches of Peer Review Integrity
NIH Peer Review – NIH Ctr. for Scientific Review
AAAS – U.S. universities reassess collaborations with foreign scientists in wake of NIH letters
Closing Confucius Institutes