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This message is intended for all campus PIs and individuals supporting the preparation of federal sponsored research funding applications. Please distribute widely.
Dear Colleagues:
In recent weeks and months, the major federal funding agencies have issued new guidelines and policies regarding disclosures from Principal Investigators on foreign funding for research and participation in foreign talent programs. I write to share highlights of important changes, reflections on these changes from my recent visit to Washington, DC, and information on where to get additional information or future updates.
I encourage all PIs and supporting staff, researchers, and students to review the new guidelines and consider how they may apply to your future federal grant applications and federally-funded research projects. A summary of recent changes is provided below, along with links to additional resources to lear n more.
In writing, I want to reiterate our campus’ commitment to international research collaboration. International exchange in research and scholarship is a fundamental part of UC Berkeley’s excellence. Given heightened concerns among Congress and federal agencies around the protection of intellectual property, however, it is in our collective interest and responsibility to be transparent, and to ensure that our research enterprise complies with federal guidelines. As shared in our July 22 message to the campus, VPAP Lisa Alvarez-Cohen and I have convened the International Engagement Policy Task Force to help the campus navigate this balance and sustain our commitment to academic freedom and inclusiveness.
Summary of recent developments in federal funding guidelines
National Science Foundation
On July 11, the NSF Director sent out a Dear Colleague Letter clarifying numerous policies (https://www.nsf.gov/pubs/2019/nsf19200/research_protection.jsp).
Among the key points are:
- NSF is proposing to use an electronic format for submission of biographical sketches, including disclosure of all appointments.
- NSF has commissioned a study to assess risks and recommend possible practices for NSF and its awardee organizations to achieve the best balance between openness and security of science.
- NSF is issuing a policy making it clear that NSF personnel and IPAs detailed to NSF cannot participate in foreign government talent recruitment programs.
National Institutes of Health
On July 10, NIH issued “Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components” (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html).
Among the key points are:
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All pending support at the time of application submission and prior to award must be reported.
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Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted pending support.
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If other support is obtained after the initial NIH award period, the details must be disclosed in the annual research performance progress report.
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Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH.
NIH also publicized Frequently Asked Questions about Other Support and Foreign Components (https://grants.nih.gov/grants/faq-other-support-foreign-components.htm).
Department of Defense
Recent Broad Agency Announcements (BAAs) from Defense agencies such as DARPA are seeking more detailed disclosures on the sources of support for Principal Investigators, as well as all other Key Personnel (https://spo.berkeley.edu/procedures/federaldisclosure/undersecretaryofdefensememo.pdf).
National Security Impact Statements are now features of these proposals, with particular attention being paid to plans to transfer technology to U.S. industry and disclosure s on whether technologies developed under the contract will be transferred to foreign entities. Proposers are also instructed to disclose any prior instances of transfer of technology to foreign entities.
Department of Energy
In June, DOE issued a directive that prohibits DOE and contractor personnel from participating in talent recruitment programs operated by certain foreign countries (https://www.directives.doe.gov/directives-documents/400-series/0486-1-border/@@images/file). While this directive does not directly affect faculty who are unaffiliated with DOE or its National Labs, it illustrates a pervasive concern across the federal agencies. DOE is still developing guidance to its community of university performers.
General Observations from Washington
In my recent meetings with the senior leadership of many of the Federal agencies that are major sponsors of research funding, the topic of research protection was their highest priority. Across the agencies, I was pleased to hear that there is a broad understanding of the importance of international collaboration, and a continued commitment to bringing the world’s best and brightest to work in our scientific enterprise. Nevertheless, the agencies are demanding more visibility into how the research they support is being broadly funded, who is performing the research under their sponsorship, and how that research is being translated into practical know-how and products, and to whom. Let me assure you that the University of California campuses do not perform classified research, nor will we accept any research projects that limit participation due to national origin. Our overarching goal is to push forward the boundaries of knowledge by wide dissemination of our research results, th rough open publication.
When in doubt, ask. All of the federal agencies encouraged PIs who have questions about disclosures to speak with their program officers.
UC Berkeley resources to stay up to date
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Our Sponsored Projects Office (SPO) has posted a new resource web page summarizing changes to agency disclosure guidelines regarding foreign sources of funding at https://spo.berkeley.edu/procedures/federaldisclosure.html. It will be updated regularly as new agency announcements are released.
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Our Research Administration and Compliance Office regularly posts announcements of interest to the campus research community on its website at https://news-rac.berkeley.edu/.
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The Sponsored Projects Office regularly sends out priority updates to the research community via SPO News. To subscribe to the list, send a blank email to sponews-l+subscribe@lists.berkeley.edu.
Support for preparing funding disclosures
Phoebe Search can generate reports on key personnel working at Berkeley that include each individual’s current and pending research support (from industry, government and nonprofit sponsors). Projects can be listed by the name of the sponsor, project title, amount of funding (pending or received), and period of performance. Information on gifts received can be provided by your academic unit’s development officer.
Further Reading
This story from Inside Higher Education from April provides further background on the growing federal scrutiny of foreign research.
If you have specific ideas or concerns or would like to become more engaged in following these issues, please contact my office at vcr@berkeley.edu.
Thank you for your attention.
Randy Howard Katz
Vice Chancellor for Research
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