New Decision Matrix Further Clarifies NIH Processes for Handling Allegations of Foreign Interference

Originally posted on the NIH Open Mike Blog

Today NIH issued a decision matrix for assessing potential foreign interference as part of its ongoing efforts to be transparent about its policies and procedures. The decision matrix builds on the detailed information already available on our site, including the process we take to handle new allegations of foreign interference, and also offers additional detail as to how NIH considers whether to contact institutions to request additional information.

The resource acts like a decision tree consistent with our efforts to remind institutions and researchers about what they should know when navigating relevant long-standing grant policies. Such policies center around proper disclosure and transparency throughout the grants process. We appreciate that the vast majority of the research community understand these requirements, as evident by fewer allegations of inappropriate foreign interference arising in recent years. That said, our case studies do describe some problematic behaviors and activities to be aware of.

We strongly support properly conducted and principled international collaborations that are integral for our country to remain competitive. As we have said before, these collaborations must respect the integrity of the scientific process. Routine academic research activities can be done in the absence of scientific or budgetary overlap, overcommitment, and nondisclosure of financial conflicts of interest and foreign components. This means scientists may:

• Write a letter of recommendation for a foreign scientist
• Serve on a peer review or other advisory panel for a foreign funding agency
• Co-author scientific publications (though if directly related to NIH-funded work, recipients need to secure prior approval for foreign components)
• Lecture or teach
• Receive foreign honors
• Participate in foreign research grants and/or foreign employment (aside from malign foreign talent programs); however, they must provide copies of foreign employment agreements and/or grants to their institutions and to NIH.

NIH’s grant compliance and oversight efforts have been and will continue to be based on objective behaviors. NIH Director, Dr. Monica Bertagnolli, reiterates this as well in her statement released today, while also emphasizing that targeting, discrimination, and harassment are unacceptable when conducting oversight. We will continue to ensure that these 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. Echoing one of her sentiments, “with these actions, I hope to ensure that NIH-funded institutions cultivate a welcoming and supportive environment for Asian researchers, as well as researchers from all other backgrounds.”

We anticipate the decision matrix will help strengthen what research organizations and their scientists are already doing to comply with NIH policies. This is because the matrix is based on what is found in the NIH Grants Policy Statement, the Implementation Guidance for National Security Presidential Memorandum-33, the White House Office of Science and Technology Policy’s common disclosure forms for biosketches and other support (announced earlier this year), and federal regulations described in 2 CFR 200.206.

We hope this tool is helpful to further clarify our efforts to ensure accountability, stewardship, and transparency throughout the grants process while fostering robust scientific collaborations. If you are planning foreign collaborations and activities and have questions, please do not hesitate to contact relevant NIH program staff for assistance.