Memo: Foreign Influence in Academic Research

Over the past year there has been increased attention on the potential for foreign influence in academic research by all of the major federal agencies that sponsor research at Boston University. Open science and international collaboration are essential components of the research enterprise that are highly valued by Boston University. However, it is important that we all understand the current regulatory landscape and that Boston University complies with U.S. laws and the agency regulations outlined below, which govern how international engagements are managed and reported.

I. Proposals for Research Support

Faculty are reminded that all proposals for external research support must be submitted through Sponsored Programs and awards must be made to the “Trustees of Boston University.”

NIH Guidelines

• Principal investigators and research administrators should be mindful that the NIH requires prior approval  foreign components, so they should be disclosed at the time of application submission.
• NIH grants policy requires the disclosure of your involvement in all ongoing and proposed research projects.

NIH defines “Foreign Component” as:

The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.

Activities that would meet this definition include, but are not limited to:

1. the involvement of human subjects or animals;
2. extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities; or
3. any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.

Examples of other grant-related activities that may be significant are:

• collaborations with investigators at a foreign site anticipated to result in co-authorship;
• use of facilities or instrumentation at a foreign site; or
• receipt of financial support or resources from a foreign entity.

Foreign travel for consultation is not considered a foreign component.

How to Disclose

There are several sections of the NIH application and Research Performance Progress Report (RPPR) in which foreign collaboration must be disclosed. These include:

• NIH Application Other Project Information page (Question 6) requires you to indicate if this project involves activities outside of the US or partnerships with foreign collaborators. If you check “Yes” to Question 6, you must upload a “foreign justification” document in Field 12, Other Attachments.  On this form, you must describe the special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting.
• NIH RPPR Participants (Section D1) requires you to list who has worked on the project at least one-person month per year and identify if the individuals’ primary affiliation is with a foreign organization.
• NIH RPPR Personnel updates (Section D2) requires you to report if there are will be new/senior key personnel or if there has been a change in other support of senior/key personnel since the last reporting period.
• NIH RPPR Impact (Section E4) requires you to report the dollar amount from the budget that is being spent in foreign countries.
• NIH RPPR Project Performance Site(s) (Section G8) requires you to report changes to the project/performance site(s) including any new sites where either human subjects or vertebrate animals will be involved.
• NIH RPPR Foreign Component (Section G9) requires you to report on Foreign Components (note — Foreign Components require prior approval).
• Biosketch: Investigators should list the foreign affiliations (e.g., positions, honors) they hold in their Biosketches. NIH currently is recommending that any foreign affiliation be disclosed as “relevant” to the proposal.
• Other Support: Other support includes all financial resources, whether Federal, non-Federal, commercial, or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts are not included.

All financial resources, including support from foreign entities and talent programs, must be included in the Current and Pending Support/Other Support section of research proposals. This includes any direct research support provided to you, even if it is not administered by BU.

NSF Guidelines

NSF has similar requirements to those of the NIH for reporting “Current and Pending Support.”

• “Current and Pending Support” is defined by the NSF as the support requested or available from all sources of project funding.
• All current and pending support from whatever source (e.g., federal, state, local or foreign government agencies, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects) must be listed. The proposed project and all other projects or activities requiring a portion of time of the PI and other senior personnel must be included, even if they receive no salary support from the project(s).

II. Gifts and Donations

Only designated University personnel are authorized to accept gifts from any source.

III. Disclosure of Financial Interests

Under BU’s Investigator Financial Conflicts of Interest Policy, principal investigators and others who share responsibility for the design, conduct, and reporting of research must disclose all personal financial interests related to the breadth of their institutional responsibilities. Required disclosures include income and travel reimbursement from foreign governments and academic institutions.

IV. Other Obligations

• You may not enter into informal or unofficial agreements to restrict publication or sharing of research results. Publication restrictions in research can only be negotiated by University officials who have delegated authority to accept contracts and grants.
• You must comply with U.S. export control regulations when doing any of the following: traveling internationally and attending conferences, participating in international collaborations, using proprietary information, working with international staff and students, hosting international visitors, shipping materials internationally, or engaging in any international transactions.
• All employees are expected to promptly disclose all intellectual property and any improvements to existing intellectual property to BU Technology Development.

If you have questions please contact Sponsored Programs at ospera@bu.edu or 617-353-4365.