As has been communicated, the U.S. Government has raised concerns about foreign threats to the integrity and security of research conducted by universities, amongst other institutions. There are three areas of particular concern:

  • Failure of researchers to disclose research resources and support provided by other organizations, including foreign entities
  • Diversion of intellectual property to foreign entities
  • Disclosing confidential grant application information by NIH peer reviewers to third parties

Federal funding agencies are working with associations and universities to address these concerns by advising on best practices and through implementation of enhancements to professional profile documentation by which individual disclosures are made.

Our goal in this and every communication is to recognize that while most international collaborations are encouraged, we urge NYU faculty and researchers to err on the side of transparency. International relationships and resources disclosed and vetted to determine if there are any potential conflicts of commitment, duplications of research, and/or diversion of intellectual property in the performance of federally funded research protects everyone’s interests – the Federal government, NYU, individual researchers, and your international collaborators.

In order to meet the standards set by our federal partners and to comply with NYU policies and best practice guidance on full disclosure of activities, please take the following steps for all proposals and sponsored awards (and repeat these steps any time there is a change in your activities or research resources):

Nancy Daneau
Associate Vice Provost for Research

Jason St. Germain
Senior Director, Office of Sponsored Programs

Erik Schneebeck
Director, Office of Conflict of Interest
 

Step 1

Update CV/biographical sketch and other support/current and pending support documentation using agency approved formats.

Step 2

Review your sponsored research proposal and award portfolio with particular focus on identifying and disclosing foreign components and foreign collaborations.

Step 3

Review your COI disclosures and update when there is any change in your activities or research resources.

Step 4

Preparing and submitting progress reports.

Other Sponsor Updates

Department of Energy

The DOE has taken an aggressive position that restricts its employees, contractors, and grant-supported researchers from engaging with talent recruitment programs supported by non-U.S. governments, and potentially to limit collaboration on certain DOE-funded projects with researchers from designated countries. The DoE has indicated that current or future participation in such programs would jeopardize funding eligibility.

Additional NYU Resources

OSP’s Research and Foreign Engagement Webpage resources which walk Investigators through:
Policies and Guidance
Tasks to Complete
Federal Initiatives around Fundamental Research Security

Advisors on Foreign Activities and Research (AFAR)
As part of its proposal review process, OSP will continue to utilize its Advisors on Foreign Activities and Research (AFAR) working group to support emerging concerns around the disclosure of foreign support and affiliations. During the AFAR review, if a proposal is identified that has a foreign component or is being submitted to a foreign sponsor, the OSP project officer and OCOI will review the funding portfolio of the PI and all Senior/Key personnel to confirm if any federal funding is active or has been recently submitted. In such cases, OCOI will review the biosketches, other support documents and COI disclosures, and confirm that all relevant funding and positions have been disclosed to the sponsor and the University.

Collaborative Institutional Training Initiative (CITI Module): Undue Foreign Influence: Risks and Mitigations

This course provides university faculty, students, and others involved in international engagement with a concise overview of the risks and mitigations associated with undue foreign influence.

Learners will begin by reviewing the key concepts related to claims of undue foreign influence on the U.S. academic and research environment, including the publicly voiced concerns of federal funding agencies, federal law enforcement, and Congress. They will then learn about how undue foreign influence conflicts with the principles of research integrity, as well as the reporting requirements, U.S. government actions, and effective university practices that address undue foreign influence.

As a critical component of mitigating the risks associated with undue foreign influence, learners will further explore key cybersecurity practices, federal security and control regulations, and data privacy laws applicable to federally funded research activities. The course will close by providing learners with potential strategies to ensure that compliance with certain technology control and security requirements does not create unexpected conflicts with nondiscrimination laws.