Foreign Influence in Federally Sponsored Research – Guidance
Government agencies have identified foreign interests and activities that require disclosure to federal agencies when proposing to or participating in federally sponsored research.
The Office of Science and Technology Policy (OSTP) provided guidance regarding government-wide foreign interest and activity disclosure requirements in accordance with National Security Presidential Memorandum (NSPM) 33: Presidential Memorandum on United States Government-Supported Research and National Security.
Virginia Tech remains committed to meeting regulatory compliance in all areas of education and research activities so that stakeholders are responsible stewards of public and private funding. Federal sponsors issue requirements for researchers to disclose their foreign and domestic affiliations, interests, and activities; therefore, researchers must promptly disclose to federal sponsors all relevant activities and information that bear on potential conflicts of interest and commitment. Disclosure remains part of the broader set of researchers’ responsibilities to ensure objectivity, honesty, transparency, fairness, accountability, and stewardship.
Important Notices and Forms
- OSTP Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs
- NSPM 33 Implementation Guidance (January 2022)
- National Security Presidential Memorandum-33 :Presidential Memorandum on United States Government-Sponsored Research and Development National Security Policy (January 14, 2021)
- National Science & Technology Council: Recommended Practices for Strengthening the Security and Integrity of America's Science and Technology Research Enterprise (January 2021)
- Important Notice from Office of Science and Technology Policy
- Foreign Influence Memo to Virginia Tech campus from the Office of Research and Innovation
- DoE Order 486.1A and Contractor Requirement Document (Attachment 1)
- DoE Order 142.3B and Contractor Requirement Document (Attachment 1)
Updates
- National Institutes of Health Issues New Requirements for SBIR/ STTR SBC's Disclosure of Foreign Ties
- Department of Defense Strengthening Efforts to Counter Unwanted Foreign Influence on Department of Defense-Funded Research at Institutions of Higher Education
- Department of Defense Issues Policy Memorandum/ Guidance For Risk-Based Security Reviews of Fundamental Research
- National Science Foundation Suspends 18 Awards, Receives Repayments Related to Foreign Ties, Research Misconduct
- New JASON Report: Research Program on Research Security
- National Science Foundation Enhancements to the Biographical Sketch and Current and Pending (other) Support Fillable PDF Form
- GAO: Export Controls:Enforcement Agencies Should Better Leverage Information to Target Efforts Involving U.S. Universities
- Department of Energy issues FAL 2022-04 Current and Pending Support
Faculty and Staff Foreign Interest Disclosure Responsibilities
Employees must disclose additional work commitments and financial interests in accordance with Virginia Tech’s Individual Conflicts of Interest and Commitment Policy (No. 13010). Foreign interests and participation in foreign talent and government recruitment programs should be disclosed in the university's Disclosure and Management System. Visit the disclosure guidelines and requirements page for more information. Contact the Virginia Tech Research Conflict of Interest program at coi@vt.edu if you have questions regarding disclosure requirements under this policy.
Note that disclosing your interests in the Disclosure and Management System does not alleviate your obligation to notify the Office of Sponsored Programs of any disclosure requirements to individual sponsors.
Contact foreigninfl@vt.edu regarding questions on individual grant or contract disclosure requirements.
How to Get Assistance:
Faculty members should be encouraged to contact their associate dean for research for an initial discussion regarding any foreign affiliations related to their research efforts. Questions regarding individual grants and contracts can be directed to foreigninfl@vt.edu.