Research Security & Foreign Influence

Introduction

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.

Disclosure of Foreign Relationships and Activities & Other Investigator Responsibilities

Transparency in disclosure

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.
- NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization – 9/1/2022
- 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 (UMS Labor Relations)

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:

Export controls

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).

Security of materials, data and confidential information

Practice good cyber hygiene – review the policy & guidance available from UMaine ARCSIM and 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.