The National Institutes of Health (NIH) recognize 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.
UAMS Guidance on Disclosure of Foreign Influences – Transparent/full disclosure protects the researcher, collaborators, federal government, and UAMS.
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 2 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 (MUSE) 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 need to terminate a foreign talent program affiliation.
3. Any financial interests received from a foreign entity, including governments and universities, must be disclosed per UAMS Administrative Guide policies 4.4.10, 4.4.12 and Office of Research Compliance. If you question 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 policies 4.4.10, 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. The UA System’s board policy on intellectual property was revised in August 2019 with extensive changes. One of the new items affects consulting agreements (2019 UA System Patent & Copyright Policy updates).
6. Anyone with a concern about any aspect of UAMS’ research and/or ethics can call the Compliance Hotline confidentially at 1-888-511-3969.
8. Contact the CIS Officer and Director of IT Security regarding any compromised accounts or other IT threats.
Federal Reports and Communications
Foreign Interference in NIH Funding and Grant Processes: Summary of Findings (2016 to 2021) – July 30, 2021
President Biden’s Academic Security Letter – April 9, 2021
NIH Announces Changes to Biographical Sketch and Other Support – March 12, 2021
Beat China: Targeted Decoupling and the Economic Long War – Rpt. from the office of Senator Tom Cotton (Arkansas) – February 24, 2021
Biden Announces New Pentagon-run China Task Force – February 11, 2021
Mike Lauer, MD, NIH Deputy Director for Extramural Research, Cyber Safety and NIH-Funded Research – October 1, 2020
Global Engagement: Rethinking Risk in the Research Enterprise – September 30, 2020
If You Want to Keep Talent Out of China, Invest at Home – September 17, 2020
NIH Office of the Director, Findings of Research Misconduct – August 28, 2020
Addressing Foreign Interference and Associated Risks to the Integrity of Biomedical Research, and How You Can Help – Michael Lauer, MD, NIH Deputy Director for Extramural Research and advisor to the NIH Director – July 8, 2020
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