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Introduction

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. 

Based on their recommendations, our research policies balance these values and interests to comply with all federal requirements. Two Stanford committees conducted a thorough 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, reviewed our policies and procedures related to international agreements and funding, researcher disclosures, training and awareness regarding regulations, and related issues. Working concurrently, a subcommittee of the Committee on Research (C-Res), a Faculty Senate committee, convened by the C-Res Chair,  considered the interaction between these issues and our cherished policies on academic freedom, openness in research, and nondiscrimination in research agreements.

Global Engagement Review Program

GERP is a centralized advisory process created to evaluate potential undue foreign influence risks in the context of maintaining our open and welcoming community. The program coordinates input from multiple offices that advise on various aspects of foreign engagements to assess risks related to undue foreign influence, research security and integrity.

Faculty or administrators may recommend or request GERP review by contacting the GERP Director. When an engagement presents an elevated risk, the director will work with the GERP Staff Committee of subject matter experts to assess risk and develop recommendations that support academic and research goals. On rare occasions the GERP Staff Committee may determine that the risks associated with an engagement are exceptionally high. When this happens, the GERP Staff Committee will refer the matter to the GERP Faculty Committee who will review the engagement and provide advice and recommendations to university leadership. Contact GERP Director Jessa Albertson at jalbertson@stanford.edu for more information.

Foreign Government Talent Recruitment Programs

Foreign Government Talent Recruitment Programs “FGTRPs” are programs sponsored by foreign governments to recruit faculty, researchers or students to support the sponsoring county’s interests. Sponsors may include national, regional or local governments as well as non-U.S. universities. Many governments sponsor FGTRPs for legitimate and mutually beneficial purposes. However, some FGTRPs may require or incentivize activities that are contrary to regulations, policies, and core research values. The U.S. government has expressed serious concerns about FGTRPs sponsored by China, Russia, Iran and North Korea. While not prohibited if the participant complies with all applicable regulations, requirements and policies, participating in a FGTRP sponsored by China, Russia, Iran and North Korea can preclude an individual from receiving certain types of federal funding. Participation in these programs should always be approved by your School Dean, disclosed to Stanford and federal funding agencies. 

Identifying Foreign Government Talent Recruitment Programs

There are several descriptions of what constitutes a “Foreign Government Talent Recruitment Program”.

  • National Security Presidential Memorandum (NSPM-33) Presidential Memorandum on United States Government-Supported Research and Development National Security Policy
    • Sec.2.(e) the term “foreign government-sponsored talent recruitment program” or “foreign government-sponsored talent recruitment programs” means an effort directly or indirectly organized, managed, or funded by a foreign government or institution to recruit S&T professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position).  Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government.  Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose.  Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities.  Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation
  • Department of Energy Order 486.1A Foreign Government Sponsored or Affiliated Activities   
    • Foreign Countries of Risk are currently China, Russia, Iran or North Korea.
    • Foreign Government-Sponsored Talent Recruitment Program. An effort directly or indirectly organized, managed, or funded by a foreign government to recruit science and technology professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state for the above purpose. Some programs allow for or encourage continued employment at U.S. research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to U.S. entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. 
    • Other Foreign Government Sponsored or Affiliated Activity. Includes the following activities directly or indirectly involving a foreign country of risk entity, as defined below:
      • (1) Employment. 
      • (2) Other support, contractual or otherwise, direct and indirect, including current and pending private and public sources of funding or income, both foreign and domestic. For researchers, other support includes all foreign country of risk entity resources made available, directly or indirectly, to a researcher in support of and/or related to all of their professional R&D efforts, including resources provided directly to the individual rather than through the research institution, and regardless of whether or not they have monetary value (e.g., even if the support received is only in-kind, such as office/laboratory space, equipment, supplies, or employees). This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, gifts, financial support for laboratory personnel, and participation of student and visiting researchers supported by other sources of funding. This further includes compensation, for example, current or promises of future: grants, awards, funding, scholarship, appointment, sabbatical, travel, university directed funding, and honoraria. 
      • (3) Current or pending participation in, or applications to programs, e.g., grant programs, sponsored by foreign governments, instrumentalities, or entities, if not a Foreign Government-Sponsored Talent Recruitment Program, as defined. Associated contracts, upon request by DOE, must be disclosed, in addition to the fact of participation.
      • (4) Positions and appointments, both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
      • (5) The following, considered alone, are not included in this definition:
        • (a) In-kind support under a fundamental research collaboration for the sole purpose of co-authorship to be made publicly available; and
        • (b) Support related specifically to implementing a DOE program-sponsored international collaboration project and within the scope of a DOE-level or U.S. Government-level bilateral or multilateral international agreement. These programs are often part of broader whole-of-government strategies to reduce costs associated with basic research while focusing investment on military development or dominance in emerging technology sectors. 
  • National Science Foundation Personnel Policy on Foreign Government Talent Recruitment Programs
    • A foreign government talent recruitment program covered by this NSF policy includes:
      • Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring knowledge and expertise to the foreign country. The compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or other consideration.
      • Recruitment refers to the foreign state sponsor’s active engagement in attracting the targeted individual to join the foreign-sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the United States, or in the foreign state. Note that, generally, an invitation by a foreign state to simply attend or present work at an international conference would not constitute recruitment.

One of the most well-known FGTRPs is China's Thousand Talents programs. Georgetown University’s Center for Security and Emerging Technology “CSET” Chinese Talent Program Tracker provides a non-exhaustive list of programs. You can review the list here.

IMPORTANT: Participation in these programs should always be approved by your School Dean, disclosed to Stanford and federal funding agencies. See the links below for more information about disclosure. If you have any questions or are unsure if a program is a FGTRP, please contact Jessa Albertson at jalbertson@stanford.edu.

 

Disclosures

Disclosure to Sponsors

If you have questions about preparing sponsored research documents, visit the Office of Research Administration's online disclosure resources or SoM Research Management Group's online disclosure resources. You may also contact:

  • Russell Brewer, Associate Vice President, Office of Research Administration, or

  • Kathleen Thompson, Director, SoM's Research Management Group

Check your sponsor’s current disclosure requirements carefully: if in doubt, disclose

 

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:

    • Ronda Anderson, Director, Conflict of Interest and Conflict of Commitment, or

    • Barbara L. Flynn, Director of the School of Medicine Conflict of Interest Review Program.

Foreign Travel

  • 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.

Export Control

  • 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,

Intellectual Property

  • 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:

    • Karin Immergluck, Director, Office of Technology Licensing, or

    • Glennia Campbell, Director, Industrial Contracts Office.

Peer Review

  • 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.

 

News and Background Information

2022

NSF Pre-award and Post-award Disclosures Table - updated January 10, 2022

Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33). This document provides guidance to Federal departments and agencies for implementing NSPM-33 on National Security Strategy for U.S. Government-Supported Research and Development - January 4, 2022

2021

Clear Rules for Research Security and Researcher Responsibility, Statement from Dr. Eric Lander, President Biden's Science Advisor and Director of the Office of Science and Technology Policy (OSTP) - August 10, 2021

NIH Foreign Interference Summary of Findings, Background information and summary of compliance reviews and findings from Dr. Mike Lauer, Deputy Director for Extramural Research at NIH - July 2021

NIH Frequently Asked Questions (FAQs) Other Support and Foreign Components, New and Updated FAQs

A Renewed U.S. Commitment to International Education, Joint Statement from U.S. Departments of State and Education - July 2021

Recommended Practices for Strengthening the Security and Integrity of America's Science and Technology Research Enterprise, Report from the National Science and Technology Council Joint Committee on the Research Environment (JCORE) - January 19, 2021

2020

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

-  Science Magazine Article

Report of Investigation

2019

Science and Security Concerts Continue to Grow, NIH - December 16, 2019

NIH Other Support and Foreign Components FAQ - August 6, 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

NIH Advisory Group to the Director, Working Group on Foreign Influences on Research Integrity Update - June 19, 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.

Letter from Senator Charles Grassley to the Director of the National Science Foundation - April 15, 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, 2019

New DOE policies would block many foreign research collaborations, Science Magazine – February 8, 2019

2018

Foreign Influences on Research Integrity - 117th Meeting of the Advisory Committee to the Director of the NIH -  December 13, 2108

Statement by the Association of American Universities - 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

NIH Notice NOT-OD-18-160 Financial Conflict of Interest: Investigator Disclosures of Foreign Financial Interests - March 30, 2018

2017

DOE P 485.1, Foreign Engagements with DOE National Laboratories –  DOE Office of Science - January 19, 2017

Created: 03.02.21
Updated: 02.01.22