The FBI, federal lawmakers, and sponsoring agencies have raised concerns regarding undue foreign influence on federally funded research. As a result, there are several actions that faculty need to take to ensure that all required disclosures are made and avoid exposing their projects, themselves, and the University to risk.
What do I need to do?
- Disclose All Sources of Support: All current and pending support of your research endeavors, whether this effort is though Cornell, through an outside entity, or a personal venture, must be disclosed to external research sponsors as required by their guidelines and regulations. This includes both foreign and domestic sources of support. See Disclosing International Partnerships to Cornell and External Sponsors. Researchers who hold support that is not managed by Cornell cannot rely solely on research administrators to complete their current and pending support reports. Research administrators will not have access to this information through Cornell systems.
- Disclose All Appointments and Affiliations: All academic professional, or institutional appointments held by investigators must be disclosed in applications for external funding. This includes those that are domestic or foreign, paid or unpaid, or full/part-time/voluntary (including adjunct, visiting or honorary). See Disclosing International Partnerships to Cornell and External Sponsors.
- Disclosure of Consulting Activity: All time spent working for or consulting with foreign entities or institutions must be reported to the university in your Financial Conflict of Interest disclosure regardless of whether such activity is conducted in your professional or personal capacity, and whether such effort is paid or unpaid. See Disclosing International Partnerships to Cornell and External Sponsors. If this activity is in support of and/or related to your research efforts, it must also be disclosed under your current and pending support in your proposals to federal agencies.
- Foreign Collaborations in Sponsored Projects: Collaboration with a foreign entity (e.g. subawards, consultants, funded or unfunded collaborations with investigators located at a foreign site, etc.) in a project must be disclosed in funding applications and project reports. Additionally, adding a foreign collaboration to an existing award may require prior approval from the sponsor. See Disclosing International Partnerships to Cornell and External Sponsors.
- Foreign Travel: Observe the appropriate security precautions when traveling. Register your travel in the Cornell travel registry and follow the international travel guidelines from Cornell’s CIT. See Travel and International Activities and Export Controls and International Travel.
- Negotiating Unfunded Research Collaborations with Foreign Entities: All unfunded collaboration agreements and non-sponsored revenue-generating agreements must be initiated by your unit's contract administrator and include standard language to protect academic freedom, intellectual property, and non-discrimination. See Exploring an Academic Collaboration.
- Reporting Foreign Gifts and Contracts: Cornell University is committed to complying with reporting requirements for foreign gifts and contracts, as outlined in Section 117 of the Higher Education Act of 1965 and in Section 207-a of the New York State Education Law. See Reporting Foreign Gifts and Contracts.
- Screen and Monitor Visitors: Working with foreign collaborators on Cornell University grounds is often vital and productive to the research enterprise. If you are bringing a visitor to campus, whether a fellow scientist, student, or funder, make sure that you have properly vetted them and provide adequate supervision. See Export Controls in Research and Education – Visiting Scholars.
Who Can Answer my Questions?
- For externally sponsored research projects, OSP oversees international collaborations and funding. See Find my GCO to contact your assigned Grant & Contract Officer.
- For other international contracts, including the formalization of collaborations with foreign institutions, please reach out to OVPIA’s Global Operations team at email@example.com.
- For questions regarding export controls or restricted party screening, see the information provided on the Export Controls webpage or email firstname.lastname@example.org.
- For advice and assistance with bringing international researchers and faculty to the U.S., see International Services in the Office of Global Learning.
- For additional guidance regarding work with China, see Engagement with China: FAQ.
- For questions regarding conflict of interest disclosures, see Conflict of Interest or contact email@example.com.
Where Can I Find More Information?
- January 25, 2022 NIH Changes to Other Support and Biosketch
- February 4, 2021 Update on International Research and Engagement: Guidance for the Cornell Community
- March 24, 2020 University Industry Demonstration Partnership (UIDP) presentation “ Managing Foreign Influence.”
- November 21, 2019 OSP Roundtable “Disclosing Foreign Relationships and Activities” presented by the Office of Sponsored Programs.
- November 14, 2019 “Guidelines on Ethical International Engagement” from Mike Kotlikoff, Provost and Wendy W. Wolford, Vice Provost for International Affairs.
- May 28, 2019 Dear Colleague Letter “Guidelines for the Cornell University Faculty on Academic Integrity and Undue Foreign Influence” from Emmanuel P. Giannelis, Vice President for Research and Innovation and Wendy W. Wolford, Vice Provost for International Affairs.