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.
Disclosure to Sponsors
The following information must be disclosed:
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.
All ongoing or proposed research projects and sources of support in your Current and Pending Support, Other Support, or Just-in-Time response, when you apply for research funding, following 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:
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:
Mary Lee, Director of University Conflicts of Interest, or
Barbara L. Flynn, Director of the School of Medicine Conflict of Interest Review Program.
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.
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,
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.
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.
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
- Science Magazine Article
- Report of Investigation
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
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
DOE P 485.1, Foreign Engagements with DOE National Laboratories – DOE Office of Science - January 19, 2017