Most NIH grant awards go to domestic organizations, but we welcome applications from foreign organizations that include talent, resources, populations, or other resources not found in the United States. Even for domestic grant recipients, establishing partnerships with foreign researchers can be critical for access to a unique study population or an emerging infectious disease (we refer to these as “foreign components”). Academic research activities—writing a letter of recommendation for a foreign scientist, coauthoring scientific publications, or lecturing or teaching abroad—are commonplace.
At the same time, NIH maintains Requirements for Disclosure of Other Support, Foreign Components, and Conflicts of Interest. NIH staff use that information to help ensure funded projects do not receive duplicative support, research is conducted objectively, and sensitive data are kept confidential. The disclosure requirements align with National Security Presidential Memorandum (NSPM-33)—Supported Research and Development National Security Policy.
Should an institution or investigator fail to disclose other support, foreign components, or financial conflicts of interest, NIH follows a standard Process for Handling Allegations Related to Foreign Interference. In short, NIH reviews the allegation, assesses submitted disclosure forms, requests information from the recipient organization, and then takes action commensurate to the degree of noncompliance.
In an effort to increase transparency, NIH recently published its Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel. We encourage you to review the document to understand NIH’s procedures for processing allegations of foreign interference which, until now, haven’t been broadcast publicly.
Notably, NIH considers three factors when assessing potential foreign interference:
- Participation in a malign foreign talent recruitment program.
- Undisclosed or incompletely disclosed past funding from a foreign country of concern (FCOC).
- Undisclosed or incompletely disclosed affiliation with an institution or entity connected to an FCOC.
Based on the degree of severity, NIH will determine that:
- Mitigation measures are required (and contact the recipient institution for more information).
- Mitigation measures are recommended (and contact the recipient institution for more information).
- Mitigation measures are suggested (and consider contacting the recipient institution).
- Mitigation measures are not needed.
Review the Decision Matrix linked above for additional details; for example, a list of possible remedies to noncompliance.
It’s worth noting that NIH received many more allegations of foreign interference from 2018 to 2021 (more than 125, on average) than it has over the past 3 years (around 25, on average), as illustrated at Outcomes of NIH Foreign Interference Cases. Lately, the majority of foreign interference cases have been resolved without NIH needing to contact the recipient institution.
Lastly, as expressed in NIH Director Dr. Monica Bertagnolli’s statement NIH Supports Our Valued Asian American, Asian Immigrant, and Asian Research Colleagues, an NIH priority is that compliance reviews do not stigmatize or unfairly treat members of the research community, including members of ethnic or racial minority groups, or discriminate with respect to national origin or identity.
Should you need to submit an anonymous allegation, contact NIHResearchIntegrity@mail.nih.gov.