Research Security & Foreign Influence
There is growing concern by the U.S. government regarding inappropriate influence by foreign entities to federally funded research. The Office of Science and Technology Policy (OSTP) and federal sponsors such as the National Science Foundation (NSF), the National Institutes of Health (NIH), Department of Defense (DoD), and the Department of Energy (DoE) have issued communications with the research community about research security and have expressed concerns for the potential for foreign influence in research due to (1) failure by some investigators to disclose financial support from other organizations, including foreign governments, (2) diversion of intellectual property to foreign entities, and (3) sharing of confidential information by peer reviewers with others, including some instances with foreign entities.
While the University of Maine thrives on, and encourages international collaboration, investigators must be transparent about their foreign relationships and activities, and take steps to protect their research. Failure to mitigate foreign influence in research jeopardizes the research enterprise at UMaine and the U.S. at large.
This webpage serves as a resource for guidance regarding foreign influence in research and research security, including steps the University is taking to address and mitigate these concerns, sponsor-specific guidance, and investigator responsibilities.
All foreign components of federally funded research should be disclosed during proposals, progress reports, and final technical reports. Investigators with external funding should carefully review the sponsor’s current disclosure requirements and contact the Office of Research Administration for assistance or further guidance. In addition, investigators should:
- Review and update ‘Current and Pending Support’ information and ‘Other support’ information in pending proposals and active awards per sponsor-specific guidance.
- NSF Pre-award & Post-Award Disclosures relating to the Biographical Sketch and Current & Pending Support (PDF) – 9/1/2021
- NSF Current and Pending Support (see also NSF Guidance & FAQ on C&P Support)
- NIH Other Support (Updated 3/12/2021 in response to NOT-OD-21-073)
- DoD Memorandum “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies (PDF)”
- Review and update biosketches and ensure all professional appointments and collaborations, both foreign and domestic, are disclosed according to sponsor requirements in proposals and reports.
- Ensure appropriate disclosure of foreign components for NIH-supported projects (see NIH Other Support and Foreign Components FAQ).
Faculty and staff should also familiarize themselves with the UMS and UMaine policies applicable to Conflict of Interest and outside employment and be fully transparent in disclosing outside interests and commitments. These policies include:
- The University of Maine System Conflict of Interest Policy
- UMaine Policies and Procedures for Financial Disclosures and Conflicts of Interest in Extramurally Sponsored Activities (PDF)
- Outside Employment Article(s) in your applicable bargaining unit contract
The federal government has directed the university community to exercise extreme caution related to involvement with foreign talent recruitment programs due to the concern they may be used by foreign governments to acquire U.S. government-funded scientific research and valuable intellectual property.
- Participation in any foreign recruitment or talent program should be disclosed to your Dean or Unit Director so that it can be reviewed by the University.
Note: Some federal sponsor definitions of ‘Talent Program’ can be found below:
- Review UMaine’s guidance regarding export control regulations, and contact the Office of Research Compliance for Restricted Party Screening and other export compliance assistance before engaging with foreign partners/entities (including sponsoring visiting scholars and researchers).
- Practice good cyber hygiene – review the policy & guidance available from the UMS Information Security Office
- Utilize a Material Transfer Agreement (MTA) or Non-Disclosure Agreement (NDA) when sharing or exchanging materials
- Note that all agreements must be reviewed and signed by institutional officials with the appropriate signature authority
- Accepting controlled information or restrictions under research agreements may require the use of Technology Control Plans (TCP) or heightened cybersecurity. Typically, this would be identified through review of an agreement through either the Office of Research Administration (ORA) or Department of Industrial Cooperation (DIC), however – if you accept or anticipate accepting controlled information and are not already working with ORA or DIC (such as through a conference or loose collaboration), contact the Office of Research Compliance to request a review and establish a TCP.
- Review the UMS Intellectual Property (IP) policy and ensure all University IP is appropriately disclosed and protected.
- NSPM-33: Presidential Memorandum on United States Government-Supported Research and Development National Security Policy – Jan. 19, 2021
- JCORE: Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise (PDF) – Jan. 15, 2021
- OSTP Regional Webinar on Research Security, “Enhancing the Security and Integrity of America’s Research Enterprise (PDF)” – June 2020
- OSTP Letter to the United States Research Community (PDF) – Sept. 16, 2019
- NCSC Fact Sheet – Protecting Critical and Emerging U.S. Technologies from Foreign Threats – October 22, 2021
- NSF News Release 19-023 ‘Open international research collaboration essential, must have safeguards, independent report finds‘ & report, “Fundamental research Security (PDF)”- Dec. 11, 2019
- NSF Dear Colleague Letter on Research Protection (PDF) – July 11, 2019
- NSF- Statement of The National Science Board on Security and Science October 23, 2018 NSB-2018-42
- NOT-OD-21-073 Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 – March 12, 2021
- Protecting U.S. Biomedical Intellectual Innovation – July 16, 2020
- NIH Dear Colleague Letter on Foreign Influence (PDF) – Aug. 20, 2018
- NIH Guidance on Investigator Disclosures of Foreign Financial Interest
- DOE Directive O 486.1A, Foreign Government Sponsored or Affiliated Activities – Sept. 4, 2020
- DoD Under Secretary Letter to Research Community on Science & Security (PDF) – Oct. 10, 2019
- Memo from the Under Secretary of Defense on Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel, and Critical Technologies (PDF) – March 20, 2019
- Prohibition on Procurement of Foreign-Made Unmanned Aircraft Systems [DARS Tracking Number: 2020-O0015] -May 29, 2020
- FBI accuses former Jackson Lab researcher of failing to disclose China connections – March 3, 2021
- MIT Professor Arrested for Grant Fraud: Defendant allegedly failed to disclose his work for the People’s Republic of China to U.S. Department of Energy – Jan 14, 2021
- Harvard Chemistry Chair Placed on Leave After Federal Gov. Charges He Hid Chinese Funding – Jan 29, 2020