The US Government has expressed serious concerns regarding inappropriate influence by foreign entities over federally funded research. Several federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.
Michigan Tech and all other US educational institutions must comply with federal reporting and disclosure requirements. Michigan Tech’s Conflict of Interest Policy (Board of Trustees Policy 4.7 Conflict of Interest Policy) and Procedures (Faculty Handbook Appendix B) require the disclosure of activities that may create a financial conflict of interest or more generally a conflict of commitment, whether compensated or not, to your immediate supervisor and, under some conditions, to the conflict of interest coordinator. These activities must also occasionally be disclosed to comply with federal guidelines; the National Institutes of Health Grants Policy Statement requires such disclosure on all applications and progress reports, and the National Science Foundation requires disclosure on the Current and Pending support documents accompanying proposals. Also, all US institutions of higher education are required to disclose funding received from foreign sources, including sponsored grants and contracts, to the US Department of Education every six months. More information can be found in Section 117 of the Higher Education Act of 1965.
Any external support or engagement that you would acknowledge in a presentation or publication must generally be disclosed in funding applications and through the University's conflict of interest procedures. It is critical for all members of the campus community to be transparent, particularly with respect to any affiliations with foreign entities. Your disclosure is required by University policy and procedures and for the University to be in compliance with federal guidelines. Only through disclosure can the University advise, assist, and protect you and the integrity of your scholarly activities.
If you have any questions regarding regulations related to collaboration with organizations, individuals in foreign countries, or the transfer of information or materials to foreign countries please contact Ramona Englund, Sr. Research Security Specialist, at 906-487-2654.
If you have any questions regarding conflict of interest procedures or funding agency disclosure requirements, please contact Jim Baker, Associate Vice President for Research Administration, at 906-487-2226.
Foreign Government Talent Recruitment Program (FGTRP)
Based on the U.S. Office of Science and Technology Policy's National Security Presidential Memorandum 33 (NSPM-33), a foreign/international talent recruitment program (FGTRP) is an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship, national origin, or full-/part-time status).
FGTRPs raise U.S. sponsor concerns when they appear to operate with the intent of acquiring proprietary technology or software, unpublished data and methods, or other intellectual assets to further the military and/or economic goals of a foreign government through actions including, but not limited to:
- Incentivizing/compensating the FGTRP participant to relocate physically to a foreign country in order to import/acquire the proprietary technology, software, etc.;
- Allowing for or encouraging the FGTRP participant to receive U.S. Federal research funds while concurrently working at and/or receiving compensation from a foreign institution for the same, or similar, work;
- Directing FGTRP participants not to disclose their participation to United States entities;
- Compelling FGTRP participants to enter into contracts that conflict with their responsibilities to, or that are disallowed by Michigan Tech.
Compensation may include cash, research funding provided directly to the individual and not through U-M, access to research facilities or other in-kind support, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration/consideration.
Michigan Tech researchers are advised that participation in an FGTRP must be disclosed to the university by contact Ramona Englund, and to federal sponsors in Biosketches and Current & Pending/Other Support, as applicable.
Federal governments consider this disclosure in determining funding. Failure to disclose participation in an FGTRP has resulted in legal action by the U.S. government against researchers who are engaged in federally-sponsored research.
National Institutes of Health Policies
National Science Foundation
Under Secretary of Defense for Research and Engineering
Office of Private Sector
2019 FBI Academia Summit on October 10, 2019:
Department of Defense
- DoD Policy: Countering Unwanted Foreign Influence in Department-Funded Research at
Institutions of Higher Education
- Beginning August 2024, no award will be made where a "covered individual" is part of a foreign talent program (as defined in the CHIPS and Science Act). Page 10 contains a table titled "Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions Factors for Assessing a Covered Individuals Associations, Affiliations, Collaborations, Funding, and the Policies of the Proposing Institution that Employs the Covered Individual".
In The News
September 2, 2021 — CBS Detroit
"A biomedical research center in Grand Rapids has agreed to pay $1.1 million to settle a federal investigation that began when authorities in 2020 discovered research samples in the luggage of a Chinese scientist arriving at the Detroit airport. The government accused the Van Andel Institute of failing to disclose a foreign component of federally sponsored research."
July 9, 2020 — US Department of Justice Office of Public Affairs
"A rheumatology professor and researcher with strong ties to China has been ordered held without bond to face a charge of grant fraud for not disclosing that he was engaged in a sophisticated scheme to use approximately $4.1 million in grants from the National Institutes of Health (NIH) to develop China’s expertise in the areas of rheumatology and immunology."
July 7, 2020 — Nature
"The funding agency has taken action in 16-20 cases where foreign ties were not properly reported."
March 9, 2020 — Inside Higher Ed
"There's an urgent need for increasing and maintaining good security policies and practices, writes Ted Mitchell (President of the American Council on Education), who recommends some immediate actions to take. ... Sobering warnings have been delivered to the U.S. higher education community over the past several years by national security and law enforcement officials about the threats to campuses from some foreign governments, notably China, seeking to influence, interfere and, in some cases, steal scientific research and intellectual property."
University of Tennessee researcher arrested, charged with wire fraud, making false statements about relationship with Chinese university
February 27, 2020 — WBIR
"Anming Hu was booked into the Blount County jail after federal authorities allege he illegally worked with a Chinese university while also doing UT projects."
February 19, 2020 — NPR
"'This is a big, big case,' says Frank Wu, a professor at the University of California Hastings College of the Law who tracks Chinese espionage cases. 'This is a case that's all about U.S.-China relations. It's about competition. It's about how science should be done.'"
In Wake of Lieber Arrest, Dean of Science Says FAS ‘Limited’ In Its Ability to Track Unauthorized Research Activity
February 10, 2020 — Harvard Crimson
"The charges against Lieber form the latest development in a months-long federal crackdown against 'academic espionage,' the process by which scientists pass academic research from American universities to foreign governments."