Federal Research Sponsoring Agencies

In addition to the U.S. Departments of Commerce, State, and Treasury, many federal agencies who sponsor research have their own regulations related to international research collaborations with the goal of mitigating foreign influence in research.

The National Defense Authorization Act, signed in August 2018, included Sec.1286, which stated, “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities…to limit undue influence, including through foreign talent programs, by countries to exploit United States Technology…”

National Security Presidential Memo (NSPM)-33

On January 14, 2021, President Trump issued National Security Presidential Memo (NSPM)-33 to strengthen protections of government supported research and development against foreign interference and exploitation.

In January 2022, the National Security and Technology Counsel issued implementation guidance with the goal of providing clear and effective rules for ensuring research security and researcher responsibilities. The final guidance has yet to be issued, and the UO will have one year to comply with the new requirements.

Department of Defense (DOD)

  1. DOD's Academic Research Security website
  2. June 29, 2023: A DOD-issued statement on countering foreign influence in research at institutions of higher education, which outlined policies for risk-based security reviews of proposals; for research security training and mitigation; and for rejecting research projects based on security risks
  3. October 10, 2019: A DOD-issued memo providing additional updates on efforts to address this evolving issue
  4. March 20, 2019: A DOD-issued memo outlining disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements

Department of Education

  1. February 10, 2020: The Department of Education published a proposed information collection to ensure institutions of higher education report gifts or contracts with foreign sources.

Department of Energy (DOE)

  1. June 7, 2019: Directive DOE O 486.1 mandates “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs” on new DOE contracts and subcontracts. DOE is expected to issue a separate policy directive to implement the requirement on DOE grants and cooperative agreements.

National Institutes of Health (NIH)

  1. NIH's website on foreign interferences
  2. November 14, 2023: NIH issues a clarification of implementing foreign disclosure on NIH SBIR and STTR awards
  3. June 6, 2023: NIH issues new requirements for foreign subawards, in which foreign subawards must make available all records and financial statements
  4. July 10, 2019: NOT-OD-19-114 issued. A reminder for research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.” Other Support includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”
  5. June 19, 2019: Frequently Asked Questions for Other Support and Foreign Components
  6. June 2019: Report from NIH Advisory Committee to the Director
  7. August 20, 2018: NIH Dear Colleague Letter NIH Director Francis Collins issued a Foreign Influence Letter to Grantees and testified to the Senate Health, Education, Labor, and Pensions Committee regarding concerns about systematic programs of foreign influence in U.S. research.
  8. December 2018: Initial report from NIH Advisory Committee to the Director

National Science Foundation (NSF)

  1. May 2024: NSF's updated Proposal and Award Policies and Procedures includes information about research security and disclosure of foreign sources of support.
  2. April 2023: NSF's draft Proposal and Award Policies and Procedures Guide includes updates related to malign foreign talent programs.
  3. December 9, 2022: NSF announces awardees for developing research security training that will soon become required for all grantees.
  4. September 1, 2022: NSF issues guidance on the implementation of National Security Presidential Memo (NSPM)-33
  5. December 6, 2019: NSF-Commissioned JASON Report was intended to enhance NSF’s understanding of the threats to basic research posed by foreign governments that have taken actions that violate the principles of scientific ethics and research integrity. With the official receipt of the report, NSF will now begin the process of analyzing its findings and recommendations.
  6. July 11, 2019: NSF Dear Colleague Letter: Research Protection outlines NSF's plans to “address emerging risks to the nation’s science and engineering enterprise.”

Office of Science and Technology Policy (OSTP)

  1. September 16, 2019: Letter to the U.S. research community regarding research security matters