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Members of the Texas A&M research community:

Texas A&M University continues to support academic freedom and the ability of researchers and scholars to communicate, exchange ideas and collaborate with the brightest minds in the world to advance knowledge and the application of that knowledge to benefit the nation and the world. 

This guidance further updates the email dated June 10, 2019 from Dr. Carol A. Fierke, Provost and Executive Vice President, and Dr. Mark A. Barteau, Vice President for Research, which included updates as of June 10, 2019, as well as reminders regarding external employment, intellectual property, export controls, conflicts of interest, hosting visiting scholars, and the peer review process.  Below are further updates and reminders regarding the growing foreign influence concerns expressed by federal agencies:

  1. NIH

    NIH issued Guide Notice NOT-OD-19-114 on July 10, 2019 to remind investigators about the need to report foreign and domestic activities relevant to their sponsored projects through careful documentation of other support, foreign components, and adherence to financial conflict of interest reporting processes.

    NIH requires this information to prevent scientific, budgetary, or commitment overlap, and to ensure proper oversight of financial conflicts of interest before and while NIH funds are being expended. NIH views these updated instructions as “clarifications” rather than policy changes, although in practice there do seem to be some significant revisions, including:

    1. Other Support:  Expanded List of Reportable Items

      The updated definition includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”  It should be noted that in their FAQs, NIH indicates that foreign collaborations that “directly benefit” an investigator’s research must be reported even if the investigator is not involved and the project is not funded with NIH dollars. 

       

    2. Foreign Component:  Slightly Expanded Definition

      The updated definition now states that the prior approval requirement to designate a foreign component of a grant would be triggered if a separately-funded collaborator outside of the U.S. performs experiments in support of the investigator’s project, even if no NIH funding is involved.  It should be noted that NIH is currently considering whether this definition will include work that is done in a foreign location (e.g. postdoc working on the NIH grant decides to return to home country and wants to continue working on the grant). 

       

    3. Other Support/Biosketch:  Appointment Listings

      The Biosketch appointment definitions have been slightly updated to include “all positions and scientific appointments held by senior/key personnel that are relevant to an application.”  This includes paid and unpaid appointments at foreign institutions that do not involve explicit time commitments. 


      Please ensure that you are properly reporting to NIH.  Please review this Guide Notice and its accompanying FAQs carefully so that your NIH proposals, just-in-time submissions, and continuation progress reports are fully accurate and complete. As a PI/PD or as senior/key personnel, note that you remain personally responsible for the completeness and accuracy of your documents, even if departmental research administrative staff have assisted you in document preparation.

       

  2. NSF

    NSF issued a Dear Colleague Letter: Research Protection on July 11, 2019 clarifying multiple steps NSF is taking to mitigate risks from “activities threatening our research community, such as certain foreign-government-sponsored talent recruitment programs.” NSF has proposed clarification of the proposal disclosure requirements and reporting requirements for both current and pending support and professional appointments. Those clarifications are included in the draft Proposal and Award Policies and Procedures Guide (NSF 20-1). Effective January 2020, NSF also proposes to use an electronic format for submission of biographical sketches, including disclosure of all appointments, and disclosure of current and pending support information.

     

  3. DOE

    DOE issued a directive dated June 7, 2019 prohibiting their employees and contractors from participating in foreign talent recruitment programs from certain countries.  The extent and reach of this requirement to recipients and subrecipients of DOE funding is not yet known as the requirement is being first implemented within DOE national labs, which are requiring a certification regarding involvement with foreign talent programs.

    A separate policy covering university-based grantees is expected to follow.  It should be noted that DOE views participation in a foreign talent program a conflict of interest that needs to be reported.

     

  4. DOD

    DOD released a letter on October 10, 2019 addressed to the academic community describing threats to our collaborative research environment by foreign governments and outlining steps taken by DOD and other federal agencies to protect the integrity of the research enterprise.  Specifically, DOD reiterates the need for research personnel to fully disclose conflicts of interest and commitment as follows:  “all research and research-related educational activities conducted through DOD research grants, cooperative agreements, technology investment agreements, and other non-procurement transactions require key-personnel to disclose all current and pending projects, time commitments to other projects, and funding sources at the time of application.”

     

  5. OSTP

    The Office of Science and Technology Policy issued a letter to the research community on September 16, 2019 regarding efforts to ensure openness, transparency, reciprocity, and security in international scientific collaborations.  OSTP is working on: (i) coordinating outreach and engagement with Federal agencies, academic research institutions, companies, non-governmental organizations, researchers, and students; (ii) establishing and coordinating disclosure requirements for participation in federally funded projects; (iii) developing best practices for academic research institutions; and (iv) developing methods for identification, assessment, and management of risk.

     

  6. NASA

    As a reminder, NASA has long-standing restrictions on using NASA funds to enter into agreements “to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.”  This prohibits TAMU from collaborating with (even if unfunded) or issuing a subaward to China or a Chinese-owned company as part of a NASA project. 

     

In addition, as a general reminder, please remember to limit acknowledgments in published work (e.g., peer reviewed journal articles) to only those projects that actually supported the work discussed in the paper.

Please contact the Division of Research with any questions at 979.862.6419 or coi@tamu.edu.