February 8, 2023 |
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 principled international collaboration.
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.
Resources
National Counterintelligence and Security Center (NCSC) Safeguarding Science
Dept. of Energy: Office of Science Laboratory Policy, Science and Security
DARPA: Countering Foreign Influence Policy
Stanford Guidance: Contact with law enforcement
- Guidance regarding Foreign Government Talent Recruitment Programs "FGTRPs"
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 the governments of 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 "FGTRP"
- 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.
- Examples of FGTRPs
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.
Disclosure
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
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,
consult the Export Controls Decision Tree or
contact Steve Eisner, Director of Export Compliance.
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
2023
NPR: Congress tightens U.S. manufacturing rules after battery technology ends up in China - January 30, 2023
DOJ. Castro Valley Resident Pleads Guilty To Illegally Exporting American Aviation Technology To Beijing University - January 17, 2023
2022
National Academies of Sciences, Engineering, and Medicine 2022. Protecting U.S. Technological Advantage - 2022
MIT: University Engagement with China: An MIT Approach - November, 2022
WSJ. U.S.-China Tensions Fuel Outflow of Chinese Scientists From U.S. Universities - September 22, 2022
NYT. Russian Scientists Face Isolation Following Invasion of Ukraine - March 12, 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
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
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