Office of Research & Innovation
Compliance

International Relationships and Activities

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It is critically important that the entire Drexel community demonstrate leadership not only in research, but also in our responsibility and accountability through compliance, trainings, risk assessments, and protocols for investigations with a clear understanding of what is at stake. Drexel is committed to helping our faculty, staff, and students have the greatest global impact possible while educating our community about protecting the integrity of our research. 

Drexel University encourages international collaborations, but it is important for our investigators to be transparent about their foreign relationships and activities. We have compiled the following information to provide guidance and resources to remind Drexel researchers of their compliance obligations to federal sponsors.

Federal sponsors have also expressed concerns about improper foreign influence in U.S. academic research. Examples of this include a letter sent by Francis Collins [PDF], director of the NIH, and letter from France Córdova, director of the National Science Foundation both alerting the research community of “threats” from foreign entities on U.S. funded research.  Three areas of concern have emerged:

  1. Diversion of intellectual property (IP) in grant applications or produced by federally funded research to other entities, including other countries;
  2. Sharing of confidential information on grant applications peer reviewers with others, including foreign entities, or otherwise attempting to influence funding decisions; and
  3. Failure by some researchers working at federally funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of federal funds.

Rising Concern (Background)

  1. The National Institutes of Health (NIH) issued a Notice on July 10, 2019, reminding research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap” (NOT-OD-19-114). Other Support includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” A FAQ can be found here.
  2. The National Defense Authorization Act [PDF], signed on August 2018, including Subtitle F – Reports and other matters stated that “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities . . . to limit undue influence, including through foreign talent programs, by countries to exploit United States Technology ... ”
  3. On March 20, 2019 the Department of Defense issued a memo explicitly outlining disclosure requirements for all key personnel listed on research and research-related educational activities supported by DoD grants and contracts.
  4. The National Science Foundation issued a Dear Colleague Letter on July 11, 2019 [PDF], outlining its plans to “address emerging risks to the nation’s science and engineering enterprise.”
  5. The Department of Energy issued a directive [PDF] dated June 7, 2019, mandating that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs” on new DOE contracts and subcontracts. DOE is expected to issue a separate policy directive to implement the requirement on DOE grants and cooperative agreements.
  6. As a reminder, NASA has long-standing restrictions on using NASA funds to enter into agreements “to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement” (grant restrictions, contract restrictions [PDF]).
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Drexel's Commitment to Global Engagement

Drexel's global ties are integral to our mission, whether in educating international students here on campus, placing Drexel undergraduates in career-defining co-ops with companies, or creating new knowledge through research partnerships that span continents. That is why we will do everything possible to preserve these critical relationships, and to safeguard the students, faculty, and professional staff who are at the heart of what we do.

Federal agencies and policy makers have expressed concern that foreign entities may be trying to use academic research institutions to compromise national security and economic competitiveness. While we must remain alert and take steps to guard against any attempts to do us harm, we must balance those concerns with our commitment to academic freedom and the important role international students and scholars play at Drexel.

The University’s global academic partnerships are vital to the research, discovery and innovation we do in a variety of sectors, including energy, healthcare, engineering and information technology. The knowledge gained from that pathbreaking research is a powerful economic engine, which can be applied toward solving some of society’s most difficult and persistent problems.

We will continue to welcome talented international students and scholars from around the globe, while also safeguarding our research enterprise, intellectual property, and academic freedom. Such openness and collaboration underscores why higher education in the United States remains the gold standard in helping to advance society. It is also why we must continue to welcome international students and scholars, while maintaining and enhancing our research partnerships.

Importance

Drexel is committed to fostering dynamic research collaborations and protecting principles of academic freedom, while also promoting transparency surrounding interactions with industry and foreign entities in order to protect our students, faculty, and staff, as well as the University. It protects everyone’s interests – the Federal government, Drexel University, individual researchers, and their international collaborators – to have international relationships disclosed and vetted to determine if there are any potential conflicts of commitment, duplications of research, and/or diversion of intellectual property in the performance of federally funded research.

In extreme cases, failure to disclose all relationships could result in the termination of funding for a project and potential ineligibility for future funding. Noncompliance can also threaten not only the funding for individual projects, but overall funding for the University and from federal appropriations as a whole.

How to disclose:

  1. If a faculty or professional staff member identifies an omission like participating in any foreign talent program, we strongly advise faculty to update their conflict of interest report through Drexel One by completing a “Interim COI Report” immediately. To access your Conflict of Interest report, log in to DrexelOne, navigate to the Employee tab, select “Conflict of Interest Disclosure” followed by selecting “Start an Interim COI Report”. Please email compliance@drexel.edu with questions or requests for more information.
  2. Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Compliance awards@drexel.edu to have the error corrected.

Education & Awareness

To aid in the protection of interest we offer training and awareness that centers on the need to safeguard our academic research and intellectual property from unauthorized use, theft or transfer. As such, I would like to remind you of our conflict of interest and export control online training modules offered through CITI Program. The training modules are available to all faculty, staff and students. We strongly encourage all research teams complete these modules. During CITI registration, you will be prompted to add a course. Select the courses required for your research. Additionally, with respect to protecting unauthorized access to our IP, it is important to also highlight the Office of Information Technology’s Phishing Awareness training class accessible through Career Pathways and leverage their published best practices in information security. 

How to Get Assistance

The Office of Research & Innovation and the Office of Compliance, Policy and Privacy Services aims to work together and closely with Drexel colleges, schools, and departments to provide advice regarding appropriate action for scenarios and questions asked by Drexel community members.

Faculty members should be encouraged to contact their Dean and/or Department Head for an initial discussion regarding any foreign affiliations related to their research efforts. Questions regarding research related disclosures can be directed to Research Compliance at award.comp@drexel.edu and specific questions regarding export compliance can be directed to export@drexel.edu. Questions regarding your University COI Report, accessed through DrexelOne, can be directed to compliance@drexel.edu.

Sources

NIH/Senate Communications:

Funding Agency Communications:

Other Sources:

Best Practices for Disclosing Foreign Relationships and Activities

While most international collaborations are perfectly acceptable and encouraged, we urge researchers to err on the side of transparency by disclosing collaborations with foreign or domestic entities in compliance with sponsor requirements in your proposals and reporting. These collaborations may include exchanges of personnel, materials, or data, or other significant activity likely to result in co-authorship. Check your sponsor’s current disclosure requirements carefully: if in doubt, disclose. The items below contain guidance regarding the types of relationships and activities that Drexel University researchers are expected to disclose.

Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports.

Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports. Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.” The definition of “foreign component” may include a large number of collaborative activities, including “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.” Other sponsors have similar requirements to disclose foreign components.

There are multiple ways in which foreign components can be disclosed, e.g.,

  • Identifying a “foreign component” in an NIH grant application;
  • Listing a “non-U.S. performance site”;
  • Identifying foreign relationships and activities in a bio-sketch;
  • Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
  • Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Compliance comp.awards@drexel.edu to have the error corrected.

Drexel University researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors.

Drexel University researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors. “Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through Drexel University, through another institution, or provided directly to the researcher himself or herself. (NIH’s most recent guidance can be found at NOT-OD-19-114. An FAQ can be found here.)

Most federal sponsors will have their own guidance on how to complete “Other Support” forms. It is ultimately the responsibility of the individual researcher to ensure that the report of Other Support is complete and accurate to the best of his or her knowledge. Again, PIs should review all pending proposals and active awards to ensure that all Other Support has been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Compliance comp.awards@drexel.edu to have the error corrected.

Foreign talent programs

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Please see:

Additionally, Outside Business Activities may create the potential for or perceptions of a conflict of interest between the faculty's financial interests created by the Outside Business Activity and his/her related University research. In addition to any prior approval required by this Policy, such potential or perceived conflicts must be disclosed and properly managed or eliminated prior to engaging in the Outside Business Activity, in accordance with Policy CPO-2 Conflict of Interest and Commitment.

Significant financial interests

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Foreign Travel Agencies and other entities that fund your work may require advance approval and/or disclosure of foreign travel or domestic travel sponsored by foreign entities. Check the requirements associated with your specific funding sources. When traveling to high risk countries, follow recommendations including the use of a clean devices to protect information.

Refer to the following websites for more information.

Disclose all foreign consulting and other outside business activities

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Intellectual property

Promptly report inventions or intellectual property to the Office of Applied Innovation. According to the intellectual property policy inventors are responsible of the inventors to disclose to Drexel all potentially patentable inventions conceived or first reduced to practice in whole or in part in the course of your University responsibilities or with more than incidental use of University resources. Remind your group members and collaborators to do the same.

Peer review

Never share information gained through peer review processes, whether reviewing grant applications or publications. This information is confidential. Declare all competing or conflicting interests when agreeing to serve as a reviewer. Check the requirements of the relevant agency or journal. If in doubt, disclose or ask.

Equipment purchases

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International contracts and agreements

Drexel is positioned to capitalize on and grow its international relationships and funding opportunities. Therefore, it is critical to conduct due diligence when establishing agreements; establish a common process for vetting all international research related gifts, memorandums, contracts, and grants to identify risks and risk mitigation strategies. Contact the Office of Research Compliance for an export control risk assessment. Research Compliance performs risk assessments for grants/contracts and other individual requests. Assessment include, but not limited to:

  • Determining if the educational or fundamental research exception is applicable;
  • Reviewing the material/technology EAR or ITAR classifications;
  • Assessing country interactions as sanctions vary by country and change often. Current heavily sanctioned countries include but are not limited to Cuba, Iran, North Korea, Syria, and Sudan; and
  • Conducting individual screenings to ensure persons/entities have not been identified as a restricted party.

Export control compliance

The university has an established export control compliance program. When collaborating with international partners, making financial transactions, shipping materials, transferring technology, traveling abroad, or using restricted materials for research, comply with US export control regulations. If you have questions about export control,consult the Export Control Handbook [PDF], contact the Export Control Office at export@drexel.edu.

International scholars

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FAQs

No. The Department of Defense, the National Science Foundation, and the Department of Energy have also issued statements regarding this issue. Given the current U.S. Government focus on this issue, we anticipate similar guidance, statements, or requirements will be forthcoming from other funding agencies.

Please see the Background section above for additional details.

In most cases, there is no reason to disclose participation of foreign students or postdocs on sponsored research, especially if all such work will be performed in the U.S. However, classified and export-controlled projects will be subject to foreign national restrictions. It may be possible to employ certain foreign nationals on controlled projects after appropriate licenses and/or exemptions are secured. Please contact Drexel University’s Export Compliance Office for more information on such cases.

There are no foreign national restrictions on “Fundamental Research” projects (see Drexel University’s Export Control Handbook for a definition of “Fundamental Research”).

Drexel is working with the Council on Governmental Relations (COGR), an association of research institutions, to provide feedback and suggest policy improvements and clarifications around this issue.

Among the suggestions made by the advisory committee to the NIH was to update policies and forms to make requirements more explicit and clarify when nondisclosure constitutes research misconduct. The Dec. 13, 2018 Report of the Advisory Committee to the NIH Director can be found here.

Yes – If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Research Compliance comp.awards@drexel.edu to have the error corrected.

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