Monday, February 17, 2020

Many of you are aware of federal investigations into the activities of some NIH funded researchers at institutions across the United States, and related arrests, indictments, and investigations at Harvard, Emory University, the University of Kansas, and other institutions. While this recent news should in no way be perceived to reflect on the institutional commitment or character of researchers engaged in work that reaches beyond the United States, the growing scrutiny into unreported foreign research activities is a stark reminder to make sure we at the University of Iowa have our house in order.  

To protect the reputation and the integrity of our research in the face of foreign influence concerns, we must ensure that we all follow university policies, agency rules, and federal laws governing appropriate uses of funding and laboratory space, the sharing of data, and potential conflicts of interest and commitment. It is imperative researchers completely and accurately disclose all external financial interests, affiliations, activities, and relationships, including with any foreign entities that could reasonably be related to their institutional responsibilities.

To comply with federal disclosure requirements, researchers should:

Disclose foreign components of federally funded research on proposals, biosketches, progress reports, and final technical reports. The NIH Grants Policy Statement defines a Foreign Component 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" and includes “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 federal sponsors have similar guidance for defining and disclosing collaborations with foreign individuals/entities.

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 an individual’s research regardless whether they are awarded through UI, through another institution, or provided directly to the researcher. NIH’s most recent guidance can be found at NOT-OD-19-114; other federal sponsors have similar guidance on how to report “Other Support”.

Questions about how to report foreign components in research or “other support” should be directed to the Division of Sponsored Programs at 319-335-2123.

Disclose new significant financial interests and changes to previously reported financial interests within thirty days for review by the Conflict of Interest Office. The university requires all researchers to disclose activities with foreign governments, institutions of higher education, and any other foreign entity for activities such as consulting, presenting or teaching, through the eCOI Disclosure system. These disclosures should include any form of payments, stipends, honoraria, living allowances and remunerations. Questions about whether a particular interest or remuneration meets this definition should be directed to the Conflict of Interest in Research Office at 319-467-1012 or 319-384-4256. 

If you have any questions regarding the University of Iowa’s policies or in general, please do not hesitate to contact me. My office stands ready to assist researchers in identifying, disclosing, and appropriately managing their international collaborations following federal requirements and institutional policies.

International collaboration fuels important research and scholarship at our university. While we must all be vigilant against abuse of these relationships, such cases represent an infinitesimal fraction of the creative, compliant, and urgent work taking place here day after day by the vast majority of you. Thank you for all you do to generate new knowledge and understanding.


J. Martin Scholtz, Ph.D.

Vice President for Research


Additional Resources:

International Engagement Webpage

Conflicts of Commitment and Interest policy

Conflict of Interest Disclosure System

University of Iowa Intellectual Property Policy

Principles Governing Access to Research Information

Export Controls Management Program