Providing support and assistance to faculty and staff related to the issue of undue foreign influences on research integrity.

The nation’s public research universities have a unique, long-standing partnership with the federal government conducting research on behalf of the American people. This research represents one of the nation’s greatest assets, which is why it is a target for foreign attack. The University of Colorado Denver | Anschutz Medical Campus is working to help protect against foreign interference, influence, and theft of research and the discoveries that come from it.

In recent months, several federal agencies, including the National Institutes of Health (NIH), the National Science Foundation (NSF), and the U.S. Departments of Defense (DoD) and Energy (DoE), have expressed growing concerns about foreign influence on the integrity of research conducted in or for U.S. institutions.

Disclosure to Sponsors

Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended" [emphasis added].

The definition of “foreign component” (which can be found here) may include a large number of collaborative activities, including “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.” Other sponsors have similar requirements to disclose foreign components.

There are multiple ways in which foreign components can be disclosed, e.g.,

Identifying a “foreign component” in an NIH grant application;
Listing a “non-U.S. performance site”;
Identifying foreign relationships and activities in a biosketch;
Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”

Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the **Office of Grants and Contracts (xenia@ucdenver.edu) to have the error corrected.

“Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through the University of Colorado, through another institution, or provided directly to the researcher himself or herself. (NIH’s most recent guidance can be found at NOT-OD-19-114. Please also address the FAQ if you have any additional questions)

Conflict of Interest

Disclose all relationships, both paid and unpaid, through the University of Colorado Denver | Anschutz Medical Campus Conflict of Interest (COI) process.

This includes all relationships, paid and unpaid, with foreign institutions, or the governments or quasi-governmental organizations of other countries.

All travel, including foreign travel, must be disclosed in accordance with the University of Colorado Denver | Anschutz Medical Campus Policy, and within 30 days of returning from each trip. The Travel Disclosure form is separate from the COI Disclosure form.

Questions? Please contact the COI Office at coi@ucdenver.edu.

Visiting Scholars

Sponsors of J-1 Exchange Visitors are responsible for providing appropriate oversight and restricting access to university information and resources to only those necessary to fulfill agreed-upon J program objectives. In addition, sponsors assume substantial responsibility for compliance with all applicable rules and regulations of this U.S. State Department Program.

IT Security

The University of Colorado Denver | Anschutz Medical Campus Office of Information Technology provides services to keep information and University data safe. Visit the Secure Campus site to learn more.

If you suspect that your university-provided computer may be compromised or if you inadvertently disclosed sensitive university information to unauthorized individuals, it is important to report it immediately by contacting the OIT Service Desk at 303.724.4357.

Reference Materials

June 7, 2019 DOE Directive regarding Foreign Government Talent Recruitment Programs

FBI report on the risks to academia

Foreign Influence Management

Chris Puckett, JD

Managing Associate Counsel

303-315-6691

Alison Lakin RN, LLB, LLM, PHD

Associate Vice Chancellor for Regulatory Compliance and Research Integrity Officer

303-724-1010

Regulatory Compliance

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Foreign Influence

Regulatory Compliance

Providing support and assistance to faculty and staff related to the issue of undue foreign influences on research integrity.

Disclosure to Sponsors

Conflict of Interest

Visiting Scholars

IT Security

Reference Materials

Foreign Influence Management

Chris Puckett, JD

Managing Associate Counsel

Alison Lakin RN, LLB, LLM, PHD

Associate Vice Chancellor for Regulatory Compliance and Research Integrity Officer

Regulatory Compliance

Providing support and assistance to faculty and staff related to the issue of undue foreign influences on research integrity.

Disclosure to Sponsors

1. Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports

2. Researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors.

Conflict of Interest

Visiting Scholars

IT Security

Reference Materials

Foreign Influence Management

Managing Associate Counsel

Associate Vice Chancellor for Regulatory Compliance and Research Integrity Officer

Regulatory Compliance