July 30, 2019

Dear Colleagues:

The topic of foreign influence in federally sponsored research, including peer review, is receiving increasing attention by many federal agencies and universities across the country. This generally relates to the exploitation of intellectual capital, technologies, research investigators and research programs at universities by foreign governments and external entities for economic and technology development purposes.

This memo is intended to be sure that all are informed on this issue and to provide guidance for our university community in this area of concern.

We have posted specific guidance and resources to address this issue to provide faculty with the information, resources and support needed to navigate global engagements, particularly during today's shifting landscape. 

As awareness and scrutiny of issues relating to foreign influence on research grow, it is of critical importance that the members of our campus community understand them and implement the appropriate preventative measures. 

Steps can and should be taken to minimize the risk of foreign influence safeguarding resources, enabling technologies and intellectual property.

Failure to do so can have serious and far-reaching consequences including the loss of federal funding for the individual investigator and the institution as a whole.

Key elements and safeguard steps include the following:

• Ensure that both real and perceived domestic and international conflicts of interest or commitment are fully disclosed on annual conflict of interest and commitment disclosures. Such activities would include foreign consulting, outside business activities, appointments at other universities or course instruction at outside organizations.

• Ensure that the current and pending support section on federal grant applications includes both foreign and domestic financial resources.

• Ensure that any "foreign component" of a research and development activity is disclosed on proposals, progress reports, and final technical reports per the National Institutes of Health Grants Policy Statement. 

Foreign component is defined by the National Institutes of Health as follows:

The performance of 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 would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.

Examples of other grant-related activities that may be significant include the following.

• Collaborations with investigators at a foreign site anticipated to result in co-authorship
• Use of facilities or instrumentation at a foreign site
• Receipt of financial support or resources from a foreign entity

• Ensure that all international faculty, staff & visiting scholars hosted as part of a research program or collaborative initiatives are coordinated with the Office of International Students and Scholars.
• Ensure compliance with export control laws and regulations in accordance with the guidance provided on the export control website.
• Ensure disclosure of all inventions and related inventors, collaborators and funding sources to the Office of Technology Commercialization and compliance with the Wayne State Intellectual Property Policy 

Wayne State University remains committed to welcoming researchers, scholars, and students from around the world and cultivating international research collaborations two essential elements of our mission. 

At the same time, we must be cognizant of the challenges that may arise in this area and the responsibility that we all have to be sure that all aspects of this issue are addressed.

Please do not hesitate to contact us with any questions or further clarity on any specific item that may arise in this area and we are glad to provide additional guidance.

• Ahmad Ezzeddine, Senior Vice Provost for Partnerships, Workforce & International Initiatives, 313-577-8968 (a.m.ezzeddine@wayne.edu)
• Phil Cunningham, Associate Vice President for Research Integrity, 313-577-9064 (philc@wayne.edu)
• Gail Ryan, Associate Vice President for Sponsored Program Administration, 313-577-6595 (gail.ryan@wayne.edu)

Sincerely,

Stephen M. Lanier, Ph.D., Vice President for Research

Keith E. Whitfield, Ph.D., Provost and Senior Vice President for Academic Affairs