Research Security - Faculty Guidance
Research Security or “foreign influence” is an issue that continues to receive increased attention in the media and by Congress, as well as from all major federal agencies sponsoring research at Wellesley College and at our peer institutions.
While Wellesley strongly supports and encourages international collaboration and values our global network, including partnerships and collaborations, it is important that all faculty members understand the concerns being expressed. We also recognize the importance of consolidating Wellesley’s available tools and resources, to simplify and inform any actions that may need to be taken at the college or individual level in response to this information.
The U.S. Government has raised concerns about foreign threats to the integrity of research at U.S. academic institutions. These concerns include:
- Diversion of intellectual property to foreign entities;
- Disclosure of confidential grant application information by peer reviewers to third parties; and
- Failure of researchers to disclose research resources and support provided by other organizations, including foreign entities.
Recent Federal Guidance:
Given a variety of recent federal guidance (see examples below), Wellesley recommends that all faculty and staff re-examine their documentation to ensure compliance with respect to mandatory reporting of all sources of research support, financial interests and relevant affiliations. We must have a heightened awareness of the relationships federally-funded faculty/staff may have with foreign governments or entities.
- A reminder Guide Notice from the NIH regarding investigator disclosures of foreign financial interests; a letter sent by the director of the NIH, Francis Collins alerting the research community to “threats” from foreign entities;
- A Department of Energy (DOE) talent policy notification stating that the DOE plans to implement a policy which will mandate that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs”;
- In a dear colleague letter issued in July 2019, former NSF Director France Cordova highlighted NSF’s concerns and outlined plans to clarify expectations for current and pending support, as well as to prohibit participation in talent programs by NSF staff, including those at NSF on an IPA;
- Since 2011, NASA has restricted bilateral activity with China. This law limits NASA’s ability to fund research performed bi-laterally with the Chinese government or Chinese companies as outlined in NASA’s current Grant and Cooperative Agreement Manual;
- and Section 889 of the FY19 National Defense Authorization Act, which restricts federal funding to institutions doing business with certain Chinese telecommunications companies and their subsidiaries via 2 CFR 200.216(applies to grants and cooperative agreements across all federal awarding agencies) and FAR 52.204-25 (applies to FAR-based contracts with federal agencies when included in the contract).
As Wellesley continues to strengthen existing international collaborations and pursue new opportunities that benefit our faculty, students, and research objectives, we ask that all principal investigators remain mindful of the following requirements:
Be thorough and complete in accounting for all forms of research support, including from foreign sources and gifts, in the NIH’s other support, the NSF’s current and pending, and similar documentation submitted to other sponsors.
Disclose financial interests and outside professional activities in the College’s annual Financial Detailed Disclosure process or at the time of proposal submission and at the point of acquiring new interests, as required by our Conflicts of Interest/Conflicts of Commitment Policy. Activities requiring disclosure include support from foreign governments and foreign academic institutions, domestic and foreign consulting relationships, visiting positions at domestic and foreign institutions, investment in a start-up company, grant support not administered by the College, etc. The Office of Sponsored Research is available to provide additional guidance on what you need to disclose and how and when to make a disclosure. In addition, faculty and staff should refresh their understanding of the Conflicts of Interest/Conflicts of Commitment Policy.
Discuss any invitation for any academic appointment or position at another domestic or international institution (visiting, honorary, or other) with the Provost’s Office prior to accepting the appointment, as required by the Wellesley’s Faculty Handbook and Conflicts of Interest/Conflicts of Commitment Policy.
Disclose to the Office of Sponsored Research and the Provost’s Office any involvement in any foreign recruitment or “talent” programs. These programs are of particular interest to the federal government, due to the potential risk of undermining U.S. economic and security interests.
All research personnel whose research is supported with federal funding should update their other support documentation. This includes NIH Other Support, for awarded projects or projects that are pending issuance of a new award. For NSF current and pending support, include all sources of support and commitments of time, even if not receiving salary support.
Biosketches should be current and thorough.
- NIH: Biosketch Format, Instructions, and Samples
- PHS: Promoting Objectivity in Research
- NSF: Current and Pending Support
- NSF: Biographical Sketch(es) – Synergistic Activities
- NSF: Collaborations and Other Affiliations
- NIH: What to Disclose in Various NIH Documents (Table)
- NSF: What to Disclose in Various NSF Documents (Table)
For key personnel, progress reports should indicate any change in other support that occurred over the last budget year.
The NIH policy applies to foreign involvement in any of the work scope, regardless of whether NIH funds are actually expended to directly pay for such involvement. NIH has clarified that the policy also applies to unfunded collaborations where a foreign entity or person performs work contributing to the NIH work scope, at no charge to the NIH grant (e.g., performing an analysis, animal study).
NIH has now reminded the research community that “receipt of financial support or resources from a foreign entity” includes visiting scientists funded by foreign sources who are engaged in NIH work scope while collaborating with NIH-funded faculty here.
Given this last clarification, NIH expects researchers—at a minimum—to disclose the in-kind support that visiting scientists provide as part of the “Other Support” portion of the grant application. Furthermore, NIH also requires prior approval of a foreign component if the visiting scientist will continue to perform any of the NIH grant work scopes upon return to their home country.
It is imperative that researchers seek prior approval as a foreign component if NIH-funded work is performed in a foreign country or by foreign collaborators, and that researchers disclose as part of “Other Support” the involvement of foreign students or visiting faculty or scholars funded from foreign sources who are participating in NIH-funded work here.
Other federal agency sponsors may have different requirements. Please check the specific funding opportunity announcement and relevant agency grant policies for individual applications and if you have any questions, please reach out to the Office of Sponsored Research.
Regulations around export controls are complex and constantly evolving, and there are several issues to be considered before engaging in a wide range of export-controlled activities. Consult the College’s export control webpage for general export control related questions. Any questions regarding export control compliance and procedures should be sent to the Office of Sponsored Research.
Certain organizations, individuals are subject to sanctions, embargoes, and other restrictions under US law. These restrictions can apply to both foreign and domestic transactions.
Certain countries are subject to either comprehensive sanctions or targeted sanctions. Since these designations are subject to change and travel would be impacted accordingly, remember that all student and faculty College-related travel to Cuba, Iran, North Korea, Syria and the Crimea Region of the Ukraine must be disclosed to the Office of Sponsored Research and receive appropriate government clearance in advance.
International travelers should refer to Wellesley’s Guidance on Securing Your Laptop to ensure that any information carried abroad is properly secured.
Visiting faculty are an asset to Wellesley. In addition to restricted party screening, it is important to follow proper appointment procedures to ensure that we obtain the required documentation to ensure that individuals are properly reviewed and approved. Please work with Wellesley’s Slater International Center to ensure that visiting faculty are given access to College space and systems that is appropriate for the proposed work.
Be diligent in evaluating the nature of any visiting collaborators: visitors with extended stays, or who do not have the appropriate background for the anticipated research activity, must be carefully scrutinized. Any activity that raises suspicion should be thoroughly evaluated in consultation with the Provost’s Office.
When materials or data will be shared with other institutions, foreign or otherwise, it is often prudent to have an agreement, such as a Material Transfer Agreement (MTA), Data Use Agreement (DUA), or nondisclosure agreement (NDA), in place governing the use of those materials or data. Having an agreement also allows the College to complete all required internal checks. For assistance with in-coming and out-going MTAs, DUAs and NDAs please contact the Office of Sponsored Research. Remember that all agreements must be reviewed and signed by an authorized institutional official.
Accepting any sensitive or controlled information under a research contract may require heightened cybersecurity requirements. Always consult with LTS to confirm that these requirements are properly managed.
Based on state department warnings, Wellesley has designated these countries as presenting an enhanced degree of cybersecurity risk, often because of government control of the internet and/or threats to cellular networks.
North Korea (embargoed; all travel prohibited)
United Arab Emirates
If you are planning travel to these countries, please contact LTS to borrow a laptop to bring with you instead of your own.
Researchers must make reasonable efforts to protect their own and the College’s interests (and, in the case of federally-sponsored research, the federal government’s interest) in intellectual property developed in the course of their Wellesley research. Intellectual property developed under a sponsored research agreement is subject to Wellesley’s Intellectual Property Policy.
To ensure that faculty intellectual property is protected and, when required, appropriately reported to sponsors, promptly disclose any potential inventions or other intellectual property to the the Office of Sponsored Research. See the College’s Intellectual Property Policy.
Always remember that all information gained through peer review processes – whether reviewing grant applications or publications – is confidential and should never be shared. The letter sent by the director of the NIH, Francis Collins specifically reminds the research community to adhere to the confidentiality of these processes.
Individuals serving on NIH, NSF or other federal agency scientific peer review panels should note and comply with all requirements to maintain the confidentiality of the information in research grant applications.
National Institutes of Health
- General Guidelines
- Protecting Innovation Grid (shows what to report and when)
- Conflicts of Interest
- Maintaining Confidentiality
National Science Foundation
Department of Education
Department of Energy
Per the College's gift acceptance policy, primary responsibility for the review and acceptance of gifts sits with the Vice President for Development (Mary Casey) and the Gift Review Committee. As you'll see on the linked page, certain gifts (including those from any foreign source) must be reviewed by the committee prior to acceptance. Only designated College personnel are authorized to accept gifts from any source. For this reason, you must work with Wellesley’s Development Office Staff regarding all gifts from any domestic or foreign individual or organization.
Other Points to Remember
You may not enter into informal or unofficial agreements to restrict publication or sharing of research results. College policy prohibits acceptance of publication restrictions in research, except in the case of unusual exceptions, which can only be negotiated by College officials who have authority to accept contracts and grants.
You must comply with U.S. export control regulations when traveling internationally and/or attending conferences; participating in international collaborations; using proprietary information; working with international staff and students; hosting international visitors; shipping materials internationally; or engaging in any international transactions.
Wellesley College is committed to maintaining an open and robust research environment while complying with applicable laws and regulations and protecting the integrity of our research. These requirements are complex. For that reason, the resources and links on this page are available to assist you in understanding and complying with these obligations.
In addition, the staff of the Office of Sponsored Research and the Provost’s Office and others linked in this message, are familiar with these issues and policies and are here to guide and assist you.