Academic Integrity and Undue Foreign Interference
Find NIH Guidance for Foreign Components and Other Foreign Interactions on the SOM, Research Management Group (RMG) website
Many researchers have asked how to ensure that they are complying with all current policies and processes. This page provides links and contacts for relevant policies and practices.
May 8, 2019. Federal agencies that support research, federal intelligence agencies, federal security agencies, and Members of Congress have all expressed concern about systematic programs of foreign interference at U.S. research universities. In light of these concerns, federal agencies that support research are reviewing their policies and strengthening their attention to disclosure. The Association of American Universities (AAU) has urged all U.S. universities to do the same. Stanford joins the AAU in our commitment to national security, economic prosperity, openness in research, freedom of expression, the free exchange of scholarly ideas and fundamental research, and appropriate international collaboration. We design our policies to balance these values and interests and to comply with all federal requirements.
Two Stanford committees are conducting further review of the University’s policies related to foreign research engagements. The Foreign Influence Policies and Practices Advisory Committee, convened by the Vice Provost and Dean of Research, is broadly reviewing our policies and procedures related to international agreements and funding, researcher disclosures, training and awareness regarding regulations, and related issues. A subcommittee of the Committee on Research (C-Res), a Faculty Senate committee, convened by the C-Res Chair, is considering the interaction between these issues and our cherished policies on academic freedom, openness in research, and nondiscrimination in research agreements.
Quick Reference on Policies and Practices
Disclosures to Sponsors
Disclose collaborations with foreign or domestic entities in compliance with sponsor requirements in your proposals and reporting. These collaborations may include exchanges of personnel, materials, or data, or other significant activity likely to result in co-authorship.
When you apply for research funding, disclose all ongoing or proposed research projects and sources of support in your Current and Pending Support, Other Support, or Just-in-Time response, per instructions in NIH’s Other Support, NSF’s Current and Pending Support, and similar documentation from other sponsors.
If you are employed or otherwise funded by SLAC in whole or in part, follow additional SLAC procedures prior to entering into collaborations.
Check your sponsor’s current disclosure requirements carefully: if in doubt, disclose.
If you have questions about preparing sponsored research documents, contact:
Disclosures to the Public
Disclose financial interests related to your research in all public sharing of your Stanford research results - presentations, publications or otherwise. Journals and professional organizations (where results are presented) have different, often broader standards for disclosure than the University. Review those standards for each relevant journal or organization. Remind your group members and coauthors to review those standards.
Disclosures to Stanford
Disclose your outside professional activities and financial relationships, whether compensated or uncompensated, through the Outside Professional Activities Certification System (OPACS). Such disclosures must include all work for or financial interests received from a foreign institution of higher education or the government or quasi-governmental organization of another country.
Disclose reimbursed or sponsored travel related to your institutional responsibilities if you are a PHS-funded investigator unless the travel is reimbursed or sponsored by a U.S. government agency (federal, state, or local) or U.S. university or its affiliated medical center, hospital, or research institute. There is a travel disclosure tab in the Outside Professional Activities Certification System (OPACS) dashboard (left menu).
If you are funded or employed by SLAC, you must follow additional SLAC procedures.
If you have questions about disclosure of your outside activities, contact:
When collaborating with international partners, making financial transactions, shipping materials, transferring technology, traveling abroad, or using restricted materials for research, comply with US export control regulations.
If you have questions about export control,
- Agencies and other entities that fund your work may require advance approval and/or disclosure of foreign travel or domestic travel sponsored by foreign entities. Check the requirements associated with your specific funding sources.
- When traveling to high risk countries, follow recommendations including the use of clean loaner devices to protect information. If you are funded or employed by SLAC and intend to travel abroad on SLAC business, you must follow additional SLAC procedures.
- If you have questions about foreign travel, contact:
- Brendan Walsh, Director of the Office of International Affairs.
- Sign and adhere to Stanford’s SU-18 and SU-18a agreements. In particular, disclose to Stanford all potentially patentable inventions conceived or first reduced to practice in whole or in part in the course of your University responsibilities or with more than incidental use of University resources. Remind your group members and collaborators to do the same.
- If you are a director or an affiliated researcher of an Industrial Affiliates or related membership-supported program, review the policies, principles, and procedures for the establishment and operation of such programs.
- If you have questions about intellectual property, industrial contracts, or affiliates programs, contact:
- Never share information gained through peer review processes, whether reviewing grant applications or publications. This information is confidential.
- Declare all competing or conflicting interests when agreeing to serve as a reviewer.
- Check the requirements of the relevant agency or journal. If in doubt, disclose or ask.
Stanford Communication and Guidance
SoM Guidance for Responding to Recently Emphasized NIH/PHS Requirements for Disclosure of Foreign Relationships and Interactions (e.g. "Foreign Component" and Other Foreign Interactions) - February 21, 2020. Please note that this information applies to all schools with NIH/PHS funding.
Stanford Disclosure Workshop: A Guide to NIH and NSF Requirements Related to Foreign Influence (Slides only) - February 10, 2020
Stanford Disclosure Workshop: A Guide to NIH and NSF Requirements Related to Foreign Influence Video (Slides + Video) -February 10, 2020
Memo From Kathryn A. Moler, Professor of Applied Physics and Physics, Vice Provost and Dean of Research - October 31, 2019
In Support of Our Community - Notes From the Quad - March 7, 2019
Your Responsibilities Regarding Foreign Influence in Stanford Research - Memo to Stanford Faculty from Kam Moler, Vice Provost and Dean of Research - October 25, 2018
Research Policy Handbook and Administrative Guide Links to Relevant Sections
Research Policy Handbook 1.3. Academic Freedom
Research Policy Handbook 1.4 Openness in Research
Research Policy Handbook 1.8 Nondiscrimination in Research Agreements
Research Policy Handbook 4. Conflicts of Commitment and Interest
Research Policy Handbook 8. Export Controls
Research Policy Handbook 9. Intellectual Property
Administrative Guide 1.1.1 University Code of Conduct
Administrative Guide 12.1 Anti-Bribery
Links to Background Information
NIH Protecting U.S. Biomedical Intellectual Innovation, NIH and the biomedical research enterprise have a long history of International collaborations with rules of engagement that allow science to advance while also protecting intellectual capital and proprietary information of the participating countries. These rules of engagement also are designed to limit bias in the design, conduct, and reporting of NIH-supported research. This page describes actions that NIH, institutions, and researchers can take to protect U.S. biomedical intellectual innovation. The principles described here align with those announced by the White House's Office and Science and Technology Policy in June 2020.
U.S. Senators’ Letter to American Hospital Association, emphasizing disclosure requirements to NIH and seeking information about foreign influence measures taken by institutions - January 22, 2020
Science article on Moffitt Cancer Center resignations as a result of failures to disclose foreign relationships, January 19, 2020, and publicly released report of an internal investigation - January 17, 2020
COGR Email on Travel Warnings and Risks when Exporting Research Materials - December 20, 2019
Science and Security Concerts Continue to Grow, NIH - December 16, 2019
NSF Director, Dr. France Córdova, Dear Colleague Letter on Research Protection - July 11, 2019
NIH, Office of the Director, Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114) - July 10, 2019
NSF Response to Senator Charles Grassley's Letter - April 26, 2019
Survey by AAU and APLU of Actions Taken by Universities to Address Growing Concerns about Security Threats and Undue Foreign Influence on Campus – April 22, 2019.
Memo from the Under Secretary of Defense on Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel, and Critical Technologies - March 20, 2019New DOE policies would block many foreign research collaborations, Science Magazine – February 8, 2019
Letter from Senator Charles Grassley to the HHS Inspector General - January 17, 2019
NIH Response to Senator Charles Grassley's Letter - December 21, 2018
Foreign Influence on Research Integrity - 117th Meeting of the Advisory Committee to the Director of the NIH - December 13, 2108Statement by the Association of American Universities - October 23, 2018
Senator Charles Grassley Letter to Dr Francis Collins, Director, NIH - Inquiring about the agency's vetting process for foreign nationals - October 23, 2018
Foreign Influence Letter to Grantees - Dr Francis Collins, Director, NIH -August 20, 2018
The FY19 National Defense Authorization Act includes a provision alluding to the restriction of federal funding to institutions doing business with certain Chinese telecommunications companies - August 13, 2018
DOE P 485.1, Foreign Engagements with DOE National Laboratories – DOE Office of Science - January 19, 2017