What should I do?

Please report any concerns you have regarding possible undue foreign influence impacting the conduct or reporting of University research to the Office of the Vice President for Research (OVPR) at foreigninfluence@virginia.edu.

You may also contact us for guidance or assistance in reporting concerns about possible undue foreign influence in sponsor or publisher peer review processes.

The following information supplements the the Foreign Support and Affiliations information that must be acknowledged as part of UVA's online disclosure process for conflicts of interest. Due to the evolving nature of these requirements, investigators are advised to read sponsor instructions and guidance carefully when preparing proposals and reports to federal sponsors.

On 8/31/2022, the National Science Foundation, on behalf of the National Science and Technology Council's Research Security Subcommittee, released NSPM-33 Implementation Guidance Disclosure Requirements & Standardization developed for consistent disclosure requirements for Biographical Sketch and Current and Pending (Other) Support sections of federal research applications. The Federal Register Notice soliciting public comments (due by 10/31/2022) on the form guidance (Biographical Sketch and Current and Pending (Other) Support), includes an excel spreadsheet detailing the data elements and their attributes to be collected. The NSTC concurrently released an updated Disclosure Table summarizing pre- and post-award requirements.

Unless it conflicts with stated sponsor requirements/instructions, UVA encourages investigators to use this guidance to inform their future disclosures in Federal research proposals and Research Performance Progress Reports (RPPRs). 

Assistance with proposal, award or sponsor specific questions should be directed to the Office of Sponsored Programs.

Questions about specific University policy requirements should be directed to the contact office listed on each policy.  

To request review of a current or potential foreign affiliation or appointment, including but not limited to those that may be a foreign government talent recruitment program, email the VPR's office at foreigninfluence@virginia.edu.

It is important to realize that all aspects and phases of the research lifecycle can be vulnerable to undue foreign influence, this is particularly true of the peer review process that selects which research proposals receive funding and which manuscripts are published. 

Similar to how shared core principles and values (i.e., openness and transparency; accountability and honesty; impartiality and objectivity; respect; freedom of inquiry; reciprocity; and merit-based competition) form the foundation for principled collaborations, the peer review process relies on individuals commitment to confidentiality, disclosure (e.g., of potential conflicts of interest), and data security.  Regardless of whether or not you are submitting content for review or serving as a reviewer, you need to understand how and why confidentiality is assured and the potential for bias in the review process is mitigated.

In response to recent findings of confidentiality breeches during the peer review process, federal sponsoring agencies have taken additional steps to clarify expectations regarding required disclosures (e.g., of potential conflicts), enhance system safeguards, and increase monitoring. They have also taken steps to address inappropriate behaviors that undermine the integrity of the peer review process and the overall research enterprise, primarily by removing individuals from peer review panels.  Similar steps are being taken by reputable publishers.

Check out this NIH Case Study in Review Integrity: Sharing an Application Being Reviewed for additional insights on sponsor and institutional expectations regarding peer review confidentiality.

The following are provided as examples, please refer to the policies, procedures, and guidelines issued by the sponsors and publishers appropriate to your field or discipline.

Sponsoring Agencies (Funding Proposals)

• NIH Peer Review Policies and Practices
• NSF Merit Review
• DOD CDMRP's Two-Tiered Review Process
• NEH Application Review Process and Privacy Policy

Publishers (Journals and Manuscripts)

• ICMJE Responsibilities in the Submission and Peer-Review Process
• Nature Peer-review Policy and Confidentiality
• Science Peer Review at Science Publications
• IEEE About the Peer Review Process and Ethics in Peer Review
• Springer Peer Review Policy, Process and Guidance
• PNAS Information for Reviewers

What are FGTRPs? 

In general, FGTRPs are described as efforts sponsored by a foreign state entity (e.g., national, regional, or local foreign government agency, as well as certain foreign corporations and foreign public universities) to acquire U.S. scientific research results or technology through a government-run or government-funded program that recruits scientists, engineers, academics, researchers, and entrepreneurs. These programs recruit individuals of any nationality but often focus on ex-pats or others with family ties to the country working or educated in the US and other countries with advanced research programs relevant to military development or emerging technology sectors. 

Distinguishing features of FGTRPs include: 

1. Compensation provided by the foreign state entity to the recruited individual in exchange for the individual sharing knowledge, research, and/or expertise. Compensation may take a variety of forms, such as, cash; research funding (not provided through the US employer); access to laboratory facilities, materials, or support staff; appointments or honorific titles; career advancement opportunities; promised future compensation; or other types of remuneration or things of value. 

2. Recruitment in this context refers to the foreign state entity’s active engagement in attracting the targeted individual to join the FGTRP and transfer knowledge and expertise to the foreign state. The recruited individual may be employed and located in the U.S. or in the foreign state. Recruitment would not necessarily include any invitation by the foreign state to attend or present work at an international conference, provide an invited lecture, or conduct other activities outside the U.S. 

3. Many, but not all, FGTRPs aim to incentivize the targeted individual to physically relocate to the foreign state (full-time or part-time). Some FGTRPs may allow or require continued employment at the University (or other US employer) and/or receipt of US research funding while concurrently receiving compensation from the foreign state.     

The following are not FGTRPs: 

1. Research agreements, whether or not funded, between the University and a foreign entity. 

2. Agreements for the provision of goods or services by commercial vendors. 

3. Invitations to attend or present at conferences.  

Can I legally participate in an FGTRP?

Participation in an FGTRP is not illegal.  However, some FGTRP participation agreements/contracts have been found to include language that requires or encourages participants to violate research integrity values and principles; University and sponsor disclosure requirements (e.g., conflict of interest, conflict of commitment, and prohibited double funding); and illegally transfer intellectual property.

Some U.S. government sponsors prohibit participants in FGTRPs from receiving or working on funded awards; accessing sponsor facilities or systems; and/or participating in certain program meetings. 

Required Disclosures 

See the "Disclosure Requirements" topic on this page for information on disclosures required in Federal research proposals and progress reports. 

• RES-005, Financial Conflicts of Interest for Research Investigators, requires disclosure of significant financial interests at least annually.  Disclosure of compensation, paid travel costs, or other financial benefits received for participation in a FGTRP is likely required under this policy. 

• HRM-045, Faculty External Consulting and Internal Overload, establishes a limit on the number of days a faculty member may devote to external consulting and internal overload activities and requires that the number of days spent on these activities while on salary, the clients/units for whom it is done, and any other information required by their school be reported on the Annual Performance Reports. Participation in an FGTRP may qualify as external consulting and be subject to the requirements in this policy. 

• PROV-009, Faculty Holding Appointments at Other Institutions or Organizations, prohibits, in most circumstances, faculty members from accepting or holding a non-visiting appointment at another educational institution or organization without the prior approval of the Provost. Appointments, titles, or affiliations resulting from participation in a FGTRP are likely to be subject to this requirement. 

Additionally, faculty are advised to consult with school leadership on how to report participation in an FGTRP on their faculty annual reports.

Where can I go for help?

Individuals in the Office of the Vice President for Research are available to help you assess the risks and benefits of continuing or entering into a new FGTRP.  You may request a review by contacting foreigninfluence@virginia.edu.  Whenever possible, please provide a copy of any current or proposed agreements, invitation emails, or links to public websites describing the program to facilitate the review.