Wright State supports the goal of providing students, faculty, and collaborators with meaningful research activities in an open, public fashion. However, there are some types of research that come with restrictions which we must accommodate or risk losing the funded project. Restrictions associated with national security and trade protections have been around for several years, but one related area – foreign influence – has been receiving heightened scrutiny from Congress for the ways in which U.S. higher education institutions are protecting research advances from foreign appropriation. Several federal funding agencies have released clarifications to their requirements for investigators to disclose connections with foreign entities or published an intent to change their rules in this area.
Wright State wants to assist our faculty in staying current with the developing changes in this important area. Please see the information below for additional details and links to source documents. As always, please contact the Office of Research Compliance or the Vice Provost for Research for further assistance.
In an August, 2018 letter from NIH Director, Dr. Francis Collins, institutions were warned that the concerted efforts aimed at influencing U.S. researchers threatened to undermine the trust and integrity of scientific discovery in the United States. Dr. Collins also reminded us that NIH requires the disclosure of “all forms of other support and financial interests, including support coming from foreign governments or other foreign entities.”
Wright State researchers are required to disclose financial interests or support in their annual Significant Financial Disclosure documents, including from foreign sources. Please see University Policy 6110 for more information. To update your disclosure please login at: rspgateway.wright.edu.
Similarly, the NSF issued a “Dear Colleague” letter on July 11, 2019 reaffirming its support for the diverse research communities across the country, but highlighting that the threats to research activities have changed in size and complexity in recent years. In an attempt to combat these threats, NSF is reminding researchers about long-standing requirements to disclose pending and current support information.
The U.S. Department of Energy issued an order on June 7, 2019 banning researchers working for DOE or on DOE-sponsored contracts from participating in “foreign government talent recruitment programs.”
The Undersecretary of Defense, Michael Griffin, issued a memorandum to academic institutions identifying a list of information that must be included in each new proposal for all key personnel, whether or not that person will be supported by the proposed project. The information relates to sources of support, time allocation to various projects, and periods of performance. The DOD will review that information to protect intellectual property, national security interests, and to “limit undue influence, including foreign talent programs, by countries that desire to exploit United States’ technology….”
Colleges and universities within the United States are frequently targeted for exploitation due to the high levels of cutting-edge R&D as well as the open and collaborative nature of academics. It is important to be vigilant and maintain an appropriate level of skepticism when it comes to unsolicited contacts from unknown people. The FBI and other agencies have put together resources that can help you identify suspicious behaviors if you believe you have been a target for exploitation.
University Policies and Procedures
Wright State is committed to complying with all federal and state regulations, contractual obligations, and ethical norms. To that end, the University has developed the following policies and procedures to assist faculty and staff with avoiding inappropriate foreign influence in their research efforts. Additional policies and/or revisions will be adopted as needed in the coming months.
Policy 6110 – Research Conflict of Interest and Financial Disclosure
Policy 6150 – U.S. Export/Trade Controls Compliance
Policy 9510 – Travel
Restricted Party Screening – screen foreign institutions, organizations, or individual names for inclusion in embargoed or debarment lists as maintained by U.S. and foreign governments.
Clean Laptop Program – when traveling abroad WSU can provide you with a laptop and cell phone that have the software you need without the risk of losing confidential or proprietary data. More information:
IT Security Blog – for general information covering all aspects of IT security across the WSU campus:
If you believe you have been approached by someone seeking to exploit you or Wright State, please contact the Office of Research Compliance (937-775-3853) or the Vice Provost for Research (937-775-3336). You may also submit your report anonymously via the EthicsPoint system here.
FBI website: https://www.fbi.gov/resources/businesses
NIH website: https://grants.nih.gov/policy/index.htm
NSF website: https://www.nsf.gov/bfa/dias/policy/
DOE website: https://www.directives.doe.gov/