Office of Sponsored Programs

Undue Foreign Influence in Research

International Collaborations in University Research

The benefits of international research collaborations in university research are numerous. Among many other things, collaborations that bring together researchers from different countries enable the sharing of diverse knowledge and experience and make it possible for our scientists to gain access to a wider pool of resources. These advantages accelerate progress in many fields and often lead to innovative solutions that benefit not just the faculty, students, and universities involved, but the world. Therefore, Tennessee Tech University supports international collaborations as deemed appropriate and necessary by our faculty members.

Governmental and Research Funding Agencies' Concerns

Like many other research institutions in the United States, Tennessee Tech follows a tradition of integrity, openness, transparency, honesty, respect, and accountability in its conduct of research activities. However, the research community faces a rising threat from foreign governments that seek to exploit U.S. research and intellectual capital, which can undermine our national security and economic competitiveness.

Governments and agencies at both federal and state levels in the U.S. have expressed serious concerns regarding inappropriate influences on research by foreign entities. Foreign governments’ recruitment of scholars into MFTRPs, and their efforts to influence nationals of their country (and sometimes of other countries) to misappropriate federally funded research results and intellectual property from U.S. institutions of higher education are of particular concern.

The NIH, NSF, DOE, and other agencies are increasingly warning U.S. higher education institutions of faculty or researchers who are not in compliance with grant funding regulations and other laws by failing to disclose their foreign associations.

The government continues to ramp up investigations and criminal prosecutions, and this is expected to increase in frequency and scope as tensions mount between the U.S. and various foreign governments.

The following links illustrate the growing concern that the US government and various sponsoring have regarding undue foreign influence in research:

Malign Foreign Talent Recruitment Programs

One of the methods used by foreign governments to gain access to U.S. talent and innovation is to recruit science and technology professors, researchers, and students into “foreign talent recruitment programs” (“FTRP”). While many countries sponsor FTRPs for the legitimate purposes of attracting talent in targeted fields, there are some who use these programs to encourage or direct unethical and criminal behaviors. These behaviors are aimed at illegitimately acquiring proprietary technologies, data, or intellectual property from U.S. research institutions to benefit the sponsoring country’s economic and military capabilities.

China’s “Thousand Talents Plan” is perhaps the most prolific example of a Malign Foreign Talent Recruitment Program (MFRTP). Talented scientists and researchers are recruited into the program with offers of financial, personal, and professional gains. Once successfully recruited into the program, they are contractually obligated, and often face significant pressure to transfer information, technology, expertise, or intellectual property from the U.S. and its allies to China. Recruited scientists and researchers are offered incentives to take part in undisclosed and illicit transfers of information and technologies. These unauthorized one-way transfers are then used in furtherance of China’s national, economic, and military strategies, often to the detriment of the United States.

The CHIPS and Science Act of 2022 directly addresses the security threats posed by MFTRPs by prohibiting individuals involved with the preparation or carrying out of federal research awards from participating in MFTRPs. Sections 10631 and 10632 of the Act provide for these individuals to disclose if they are a party to any foreign talent recruitment program, and to certify that they are not a party to a malign foreign talent recruitment program.

TTU Policy 790 on Malign Foreign Talent Recruitment Programs, which became effective on August 1, 2024, prohibits all Tennessee Tech faculty, staff, and students whose research and development activities are funded by federal or state grants/contracts from participating in malign foreign talent recruitment programs. Please reach out to the Office of Research and Economic Development at research@tntech.edu with any questions.

Required Disclosure of Foreign Research Relationships, Collaborations, Support, or Interests

NSPM-33 (National Security Presidential Memorandum-33) is a directive issued by President Trump on January 14, 2021 which has subsequently continued under the Biden administration, that requires all federal research funding agencies to strengthen and standardize disclosure requirements for Universities and researchers receiving federally funded awards. More specifically, NSPM-33 charged the Office of Science and Technology Policy (OSTP) with “coordinating activities to protect Federally funded R&D from foreign government interference, and outreach to the United States scientific and academic communities to enhance awareness of risks to research security and Federal Government actions to address these risks.”

NSPM-33 also mandates the establishment of research security programs at research institutions receiving federal funds.

In light of governmental and sponsoring agencies’ concerns, academic research institutions need to be vigilant and aware of the affiliations and relationships that their faculty members may have with foreign governments and entities. As international research collaborations continue to flourish at Tennessee Tech, it is crucial for our faculty and researchers to be fully transparent about their foreign relationships and activities. Consequences of non-disclosure are severe and can include:

Rejection of a research and development application
Loss of current and future federal research funding
Potential loss of intellectual property
Personal and organizational reputational damage
Individual criminal, civil, and/or administrative penalties

As such, TTU faculty and researchers must be mindful of disclosure requirements at the various stages of their projects.

1. Proposals, Progress Reports, and Final Technical Reports

A “foreign component” refers to 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.

Activities that meet the definition of foreign component include, but are not limited to:

Extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities
Receipt of financial support or resources from a foreign entity
Collaborations with investigators at a foreign site anticipated to result in co-authorship
Activities that may impact U.S. foreign policy through involvement in the affairs or environment of a foreign country
Use of facilities or instrumentation at a foreign site

There are multiple ways in which foreign components can be disclosed on grant applications. They include:

Identifying all foreign components
Disclosing foreign relationships and activities for each proposed senior/key personnel and other significant contributor in the biographical sketch
Listing all non-U.S. performance sites

Financial sources should be disclosed even if they relate to work that is not performed at Tennessee Tech, and/or performed outside of a researcher’s appointment period at Tennessee Tech. For example, if a researcher with a nine-month appointment spends two months at a foreign university during the summer conducting research under a foreign award, that activity should be disclosed on the grant application.

Principal investigators 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, the PI should contact the Office of Sponsored Programs to have the error corrected.

2. All Applicable “Other Support” as Required by Federal Sponsors

Most federal sponsors provide their own guidance on how to complete the “Other Support”, sometimes referred to as the “Current and Pending Support” form.

Generally, “Other Support” includes resources and/or financial support - domestic or foreign - available to the researcher in support of his or her research activities. Such support should be disclosed on an “Other Support” or “Current & Pending” form.

It is ultimately the responsibility of the individual researcher to ensure that the responses on the form are complete and accurate to the best of their knowledge.

Principal investigators should review all pending proposals and active awards to make sure that all sources of support have been disclosed. If a PI identifies an omission or error in a previously submitted form, he or she should contact the Office of Sponsored Programs to have the error corrected.

3. Intellectual Property

Intellectual Property (IP) is a critical asset to not only our university and its research community, but the United States as well. All TTU faculty, staff, and students have an obligation to safeguard research data and materials and the IP contained within.

Inventions and other technologies should always be promptly disclosed to the Office of Research and Economic Development.

If you are active* in a company with foreign investments, the relationship must be reported to the Office of Research and Economic Development. Foreign investments include foreign financial investments, companies with foreign nationals as principals and/or substantial equity holders, and corporate partnerships (for example a joint venture) with a foreign company or entity.

*E.g. Holding titles such as CTO, CEO, Founder, Board Member, Researcher, or equivalent; serving on a scientific advisory board, etc.

Any questions regarding the disclosure of foreign research relationships, collaborations, support, and/or interests related to intellectual property should be directed to the Office of Research and Economic Development. You can also find more information here.

4. Materials, Data, and Confidential Information

Any anticipated sharing of materials, data, and/or confidential information between Tennessee Tech and another organization may require a material transfer agreement (MTA), data use agreement (DUA), or non-disclosure agreement (NDA).

All agreements that bind the university must be reviewed and signed by Tennessee Tech officials with the appropriate signing authority.

Please contact the Office of Sponsored Programs for more information.

5. Conflicts of Interest and/or Conflicts of Commitment

Transparency is crucial when it comes to conflicts of interest and commitment. The possibility of real or perceived impacts to one’s research means that such conflicts must always be disclosed, even if the researcher feels that the conflict is insignificant.

Researchers with foreign research relationships, collaborations, support (financial and non-financial), or interests must disclose them to the Office of Research and Economic Development. Some examples include but are not limited to:

Foreign consulting
Teaching courses at organizations other than Tennessee Tech
Foreign entrepreneurial ventures related to your area of research
Presentations and workshops at professional meetings or other similar gatherings
Editorial services for educational or professional organizations
Leadership positions in professional societies
Preparation of scholarly publications

The information provided here is meant to be general in nature. For further information, please reach out to the Office of Research and Economic Development at research@tntech.edu.

With the dynamic situation in this area, information related to these guidelines may change over time. Please check back often to obtain updated information.

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