Review guidance updates on Malign Foreign Talent Recruitment Programs and Institutional Disclosures and Reporting.
The University of Washington is committed to international collaborative research, with partnerships and projects in over 130 countries. Our track record of collaborative research, coupled with strong individual research groups has kept the UW globally competitive and provided us opportunities critical to advancing science and to solving society’s most pressing issues. The quality of our researchers and students make the UW a leader in funding, quality and impact.
Our collaborative approach is one of our principal values, but it can expose us to foreign influence security risks and to those who would seek to exploit U.S. academic institutions. We are dedicated to complying with all U.S. regulations governing international research collaborations, with the goal of mitigating our inherent vulnerabilities as an academic institution to ongoing and emerging threats to our national security, while preserving our ability to engage internationally.
We have been providing regular guidance and resources including requirements for disclosure of all foreign collaborations. Review the announcements on the Research homepage. We expect ongoing guidance from the NIH and other federal agencies to evolve. In conjunction with the Faculty Council on Research and the Research Advisory Board, we will be looking at how the UW, with our peers, define collaboration and how we can adapt research policy to this new understanding.
Potential risks to national security at higher education and research organizations continue to be of national priority. As a result, federal sponsors are issuing guidance intended to mitigate these risks. Information and guidance from select sponsors is collected here for reference.
We will provide updates as they become available. Other federal sponsors may have different requirements. Please check specific funding opportunity announcements and relevant federal policies for individual applications.
UW researchers whose research is supported with federal funding should update and maintain their current and pending or other support documentation. Make sure to include all sources of support, foreign or domestic, including scholarships or fellowships.
When in doubt, err on the side of inclusion when completing Current and Pending or Other Support documentation. Inform yourself of all sponsor requirements and follow all directions for content and format.
Review more information for some of our major federal sponsors on Current and Pending, or Other Support.
In accordance with the CHIPS and Science Act of 2022, all faculty, staff and other University personnel are prohibited from participating in malign foreign talent recruitment programs (MFTRP).
Most of the federal government’s attention has focused on programs originating in China, but MFTRPs have also been associated with other governments.
Malign Foreign Talent Recruitment Programs (MFTRPs) have the following characteristics.
Sponsored by a foreign entity of concern:
And is a program, position or activity that involves one or more of the following:
There is no particular formula or format for these programs and each one can be unique. Typically the entity reaches out to an investigator directly via email, letter, contract, application, or some other invitation to join.
In addition to sponsor specific requirements, before submitting a proposal at the UW, covered individuals are required to make an attestation that they are not participating in a MFTRP within the FIDS system.
Information available on MFTRPs continues to evolve. The UW Office of Research (research@uw.edu) can help researchers assess whether a specific program might be regarded as a malign foreign talent recruitment program.
Many federal forms, such as the Biographical Sketch and Current and Pending (Other) support forms require individual certification at the time of submission that you are not a party to a MFTRP. In addition, other agencies may look to past participation in a foreign talent program when considering mitigation to reduce the security risk. Therefore, as an institution, it is our practice to disclose any known past participation to our sponsors. This is based on White House Office of Science and Technology Policy (OSTP) guidance.
The Dept. of Energy prohibits participation in foreign government talent recruitment programs.
The NSF has a prohibition on participation in Malign Foreign Talent Recruitment Programs.
When the NSF Common Forms for Biographical Sketches or Current and Pending Support are completed they require each senior/key personnel to certify that they are not party to a malign foreign talent recruitment program, that the information is current, accurate, & complete, and that misrepresentations / omissions may be subject to prosecution.
Review more on Current and Pending or Other Support.
The DoD is prohibited from providing funding to or making an award of a fundamental research proposal in which a covered individual is participating in a malign foreign talent recruitment program.We anticipate the DoD will also prohibit making funding and awards to proposing institutions that do not have a policy addressing malign foreign talent programs.
See the UW Presidential memorandum addressing participation in Malign Foreign Talent Programs.
A visiting scholar, in this context, is a foreign visiting graduate student, postdoc, or faculty member who will contribute in any way to the research set out in the scope of work.
Visiting scholars (students, postdocs and faculty) must provide Current and Pending or Other Support documentation if the sponsor requires it or if they meet the definition of a key personnel.
Documentation must also be provided if the visiting scholar is not considered key personnel, but is:
In most cases, the Principal Investigator (PI) does not need to receive prior approval for a visiting scholar (student, postdoc or faculty) to work on a project in the United States, such as a UW lab on campus, however:
Prior approval is required before adding a foreign component to an NIH project. This is not a new requirement.
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 a researcher employed by a foreign organization, whether or not grant funds are expended.
As with any other significant change to a project, send your request to add a foreign component via OSP as a concurrence request.
Foreign Component Examples:
Activity conducted within the U.S. that involves non-U.S. resource support is NOT considered a “foreign component” such as:
With respect to disclosing financial interests for conflict of interest review, you are not required to disclose the following domestic sources of income (also see GIM 10):
NIH has reminded the research community that these exclusions are limited to U.S. Institutions of higher education or a federal, state, or local government agency within the U.S. Therefore, all financial interests, including those received for the activities excluded in the U.S., must be disclosed if they are from a foreign institution of higher education or the government of another country.
The Electronic Code of Federal Regulations establishes standards on Promoting Objectivity in Research for institutions that receive Public Health Services funding from a grant or cooperative agreement.
As an institution, UW discloses foreign financial support as required under federal regulations and sponsor policies. This includes Section 117 of the Higher Education Act of 1965 and in accordance with the CHIPS and Science Act of 2022.
The UW discloses:
Approval for outside work relationships with external entities, including foreign entities and governments must be requested in advance as described in:
Promptly report all inventions:
Researchers must take reasonable efforts to protect the University’s interest (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their UW research.
Intellectual property developed under a sponsored research agreement is subject to the University’s policy on UW IP Disposition in Sponsored Program Agreements.
Individuals serving on NIH, NSF or other federal agency scientific peer review panels should note and comply with all requirements to maintain the confidentiality of the information in research grant applications. There have been recent documented cases nationally of peer reviewers sharing information in grant applications outside of the peer review process. This is not allowed.
The federal government, through executive order, law, regulations, sanctions and other limitations, restricts or prohibits transacting with certain entities, including Huawei Technologies, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate).
In keeping with this prohibition, UW is not entering into transactions with the previously mentioned entities on certain U.S. proscribed parties lists, or other entities known to be indicted for crimes that threaten US intellectual property or economic wellbeing.
This prohibition is in addition to individuals or entities that are debarred, suspended or otherwise ineligible from receiving federal funding. Review examples of foreign universities that have been debarred in the On Projects section.