Foreign Influence Disclosures
Federal agencies require disclosures related to potential foreign influences. To achieve full disclosure, any foreign funding, foreign affiliations, and foreign investments must be disclosed by PIs and co-PIs when they are applying for Federal grants. Such disclosures must include involvement in a foreign talent recruitment program (FTRP). Further, researchers applying for Federal funding must attest to the fact that they are not involved in a Malign Foreign Talent Recruitment Program (MFTRP). These disclosures and attestations are part of the grant application.
Further, to ensure compliance with the Department of Defense, the University of Akron has implemented an MFTRP Policy. This policy prohibits PIs and co-PIs/co-Is at the University of Akron from being involved with an MFTRP when working Federally funded projects. Further, it requires all employees to disclose their involvement with any FTRP, as part of their annual COI/COC disclosure.
It is important to note that being involved with an FTRP is generally permitted. International collaborations are encouraged, as long as they are undertaken in an open and transparent manner. Open and transparent international collaborations ensure the free exchange of ideas and contribute to more rigorous science.
WHAT DO I NEED TO DISCLOSE?
The Office of Science and Technology Policy defines FTRP and MFTRPs here. You must disclose FTRPs annually to the University of Akron, on any Federal grant applications, and make updates to your FTRP affiliations during the performance of a Federal award. An FTRP is any program, position, or activity that includes compensation of any kind, including:
- cash,
- in-kind compensation,
- research funding,
- promised future compensation,
- complimentary foreign travel,
- things of non de minimis value,
- honorific titles,
- career advancement opportunities, or
- other types of remuneration or consideration.
Further, this compensation must be provided by a foreign government entity, their designee, or any entity based in a foreign country.
The following are not considered FTRP activities:
- Scholarly presentations or publications;
- Participating in international conferences or exchanges, research projects, or other programs where the exchange of scientific information is open and reciprocal, and are aimed at advancing international scientific understanding;
- Advising foreign students at the student's request;
- Several more activities are excluded from the FTRP definition. See the OSTP guidance for more information.
FAQS
Disclosure of involvement in an FTRP is required of all employees at the University of Akron. This disclosure should occur in the annual COI/COC disclosure due in May each year.
Disclosure during Federal grant applications is also required. This is accomplished through the significant financial interest (SFI) disclosure form. On this form, be sure to include any FTRP or financial support from foreign sources (e.g. travel paid for by a foreign-based university). Most foreign activity must be disclosed on the Federal agency application documents, as well. Where the disclosure should occur depends on the Federal agency:
- NSF: Disclosure Table describing which grant applicaiton documents should contain foreign associations. Note that academic appointments (paid or not) by foreign universities should be in your Biographical Sketch.
- NIH: Disclosure Table describing which grant applicaiton documents should contain foreign associations. Note that academic appointments (paid or not) by foreign universities should be in your Biographical Sketch.
- DOE: Requires contractors to disclose any foreign affiliations, under DOE Order 486.1A. Further DOE grant applicants must disclose foreign affiliations, as per the DOE Financial Assistance letter, FAL 2022-04.
- DOD: Similar to NSF and NIH, disclose foreign affiliations in the Biographical Sketch.
- DARPA: Requires foreign affiliations be disclosed, per the Broad Agency Announcement.
- NASA: Generally prohibits funding by NASA if the researcher's project(s) involve "bilateral" activity with any Chinese entity. This generally means visiting scholars (on J-1 visas), adjunct faculty, and exchange students (on J-1 visas) from Chinese Universities (other other entities based in the People's Republic of China) will be barred from working on a project funded by NASA. For more information see NASA FAQs.
Disclosures or updates to them are also required during the course of Federally funded research, when a change to affiliations is made. Most agencies are moving towards using SciENcv as the portal for updating Biographical Sketches.
Most agencies also require the disclosures include when research team members (including students) participate in an FTRP. Typically this type of disclosure would be in the Current and Pending Support document. See the tables above for more information on where that information should be disclosed.
Not at all. FTRPs are permitted as activities that a researcher may be invovled with. The goal of disclosure of the association is to ensure that reearchers are transparent about their foreign affiliations.
Note, however, that investigators funded by the DOE and working at a National Lab are prohibited (by the DOE) from involvement in FTRPs in a country of concern. Although subject to change, the current countries of concern include China, Iran, Russia, and North Korea. Further, investigators working under DOE funding and expecting to be involved in any FTRP must receive permission from the DOE prior to becoming involved.
Note that researchers are prohibited from accepting Federal funding if they are involved in an MFTRP. Review the MFTRP policy for more information on what constitutes an MFTRP.
You could be subject to sanctions by UA and/or by the Department of Justice. The goal of disclosures is to ensure that research is conducted in a transparent, open environment, and to reduce any potential conflicts or influences. If you are not sure whether something is an FTRP, disclose it.
The Deparment of Justice has been pursuing researchers who make false claims on grant or contract applicaitons, through the False Claims Act. Even if the legal action eventually gets settled, rather than fully litigated, the costs can be quite high to the individual and the university. See the Research Security Case Studies webpage for examples of Federal actions taken.