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Undue Foreign Influence Guidance

Undue Foreign Influence Guidance

Overview

Boise State University leadership values international collaboration and global engagement activities and is committed to an environment that promotes the open exchange of ideas and encourages the creation and dissemination of knowledge. Boise State University seeks to foster an academic environment in which faculty, students and staff are encouraged to engage in international collaborations and educational activities abroad. In addition, Boise State University is dedicated to creating an open and supportive learning environment on campus for its international faculty, students and visiting scholars.

University leadership also recognizes that international collaborations may present individual and institutional risks, which have been highlighted by Congress, the FBI, and other governmental entities. Federal funding agencies are issuing new policies, guidance, and proposed rules to address these concerns.

Key concerns related to inappropriate foreign influence, include (but are not limited to):

    • the failure of researchers to disclose support from outside activities or foreign organizations;
    • unlawfully sharing non-public information by researchers; undisclosed significant financial conflicts of interest;
    • unlawful transfer of U.S. intellectual property, data, or unpublished research results;
    • unlawful transfer of research materials and samples;
    • agreements with foreign entities that may impose obligations on researchers that are contrary to university policies and/or federal and state laws and regulations; and
    • data security and cyberattack vulnerabilities.

Boise State University encourages faculty and staff to ensure that their international collaborations and global engagement activities are both transparent and in full compliance with relevant policies and regulations. This webpage has been developed to provide resources to ensure that research and educational activities conducted abroad or involving foreign partners on campus are in full compliance with Boise State University procedures and applicable U.S. laws.

General Training

Boise State University uses the CITI Program for training related to Undue Foreign Influence: Risks and Mitigations. A four-part course covers the following topics:

    • Undue Foreign Influence Impacts and Concerns for Academia
    • Reporting, Research Integrity, and Effective Practices to Manage Undue Foreign Influence Risk
    • Cybersecurity and Compliance Considerations for Safeguarding Research
    • Nondiscrimination Considerations When Managing Undue Foreign Influence

Anyone who is involved in research at Boise State University is encouraged to complete this course. The course should be able to be completed in approximately 30-60 minutes.

Those With a CITI Account

Step through the following to add the Undue Foreign Influence to an account:

    • Go to the CITI homepage: www.citiprogram.org
    • Log in (there is also a link/button to reset your password)
    • Under Institutional Courses, click View Courses for Boise State
    • From the My Courses page, scroll to bottom to find Learner Tools, and click Add a Course
    • Under Question 10, select Yes and click Submit.

Need an Account

To access the training modules, the learner must first register with CITI.

    • Go to the CITI homepage: www.citiprogram.org
    • Click on, “Register” under Create an Account. DO NOT select “Log in through my institution.” Boise State does not yet have single-sign on capabilities with the CITI program
    • Type in “Boise State University” to search for your organization affiliation.
    • Complete additional registration steps 2-7.  A video tutorial on registration is also available.
    • On the Course Selection page, head to Question 10, select Yes and click Submit.

Researcher Disclosure Requirements

a. Examples

The examples below illustrate activities one would disclose to Boise State University. Note that the below list is not exhaustive, but represents the types of engagements that must be disclosed.

    • Academic, research, or administrative appointments at a foreign institution, even if the appointment is uncompensated. This includes appointments that are full-time, part-time, honorary, adjunct, visiting, or voluntary.
    • Any agreement with a foreign university for which the Boise State University researcher directs non-University students, postdocs, or other personnel affiliated with that university.
    • Any foreign affiliation that is included in any publication by the faculty member.
    • Any contractual agreement with a foreign institution, company, or government agency.
    • Any non-Boise State University agreement in which foreign funds or other resources are provided to the faculty for activities either at Boise State University or at a foreign institution.
    • Any agreement or relationship that assigns intellectual property (IP) rights to the foreign institution.
    • Any agreement or relationship with a foreign entity in which the Boise State University researcher or family member receives payments for salary, stipends, or living expenses.
    • Receiving travel, living or lodging funds or reimbursements from a foreign entity.
    • Receiving an honorarium from a foreign entity.
    • Any consulting agreements with a foreign entity.
    • Holding a position such as founder, partner, employee, or board member at a company, non-profit, governmental agency, or other foreign entity.
    • Having significant ownership interest in a foreign company related to your Boise State University role/responsibility.

If you are participating in any of these activities, it is important that you fully and accurately disclose them to federal Sponsors and the University.

b. Federal Disclosures Requirements in Sponsored Project Applications

Many sponsors request that applicants provide summaries of their current and anticipated grant and contract funding, as well as other resources that may be available for the individual’s research. Terminology varies by sponsor but usually is referred to as “Other Support” or “Current and Pending Support.” Additional disclosures are required in biosketches and other support. Currently there are not consistent requirements across federal agencies. The following disclosure matrix has been prepared to guide researchers on how and where to disclose support received in sponsored projects applications.

Types of SupportProposal Location: Other Support/Current and PendingProposal Location: BiosketchProposal Location: Facilities & Other SupportProposal Location: Disclosure Not Required

Grants, Cooperative Agreements, and Contracts awarded to Boise State University
NIH, NSF, DOD, DOE
Grants, Cooperative Agreements, and Contracts awarded to the Investigator DirectlyNIH, NSF, DOD, DOE
Consulting agreements relating to the Investigator's research endeavors NIH, NSF, DOD
All academic and professional appointments and affiliations whether domestic or foreign and whether paid or unpaidNIH, NSF, DOD
Foreign Government Talent Recruitment Programs must be specifically identifiedNIH, NSF, DOD, DOE
In-Kind Support or Other Resources1 Intended for use on the proposed projectNIH, NSF, DOD
In-Kind Support or Other Support* NOT intended for use of the proposed projectNSFNIH, DOD
PrizesNIH, NSF, DOD
Gifts
NIH, NSF, DOD
Start-up Funds provided by Boise State UniversityNIH, NSF, DOD, DOE
Start-up Funds provided by another EntityNIH, NSF, DOD, DOE
Boise State Internal AwardsNIH, NSF, DOD, DOE

*In-Kind Support or Other Resources may include: Office/Laboratory space; Equipment; Supplies; Employees, paid or unpaid; Visiting researchers paid by outside sources, including visiting students and fellows; In-Kind Support with direct time commitments should go in NSF Current & Pending document (if there is no time commitment, it should be listed in the Facilities and Other support).

(1) National Institutes of Health (NIH)

Disclosing Foreign Components

Foreign components should be disclosed on proposals, progress reports, and final technical reports. Under NIH’s Grants Policy Statement, a foreign component is defined as “any significant scientific element or segment of a project outside of the United States” whether or not NIH grant funds are expended, either by “a researcher or recipient in a foreign location or by a researcher in a foreign location employed or paid by a foreign organization.” Refer to NIH issued guidance: NOT-OD-19-114 for additional details. Other sponsors may have similar requirements to disclose foreign components. Under NIH’s Grants Policy Statement, a foreign component is defined as “any significant scientific element or segment of a project outside of the United States” whether or not NIH grant funds are expended, either by “a researcher or recipient in a foreign location or by a researcher in a foreign location employed or paid by a foreign organization.” Refer to NIH issued guidance: NOT-OD-19-114 for additional details. Other sponsors may have similar requirements to disclose foreign components.

For NIH funded research, when a segment of the research is performed outside of the U.S., the following activities would constitute a foreign collaboration that must be disclosed as a foreign component:

    • Research involving human subjects or animals;
    • Extensive travel for the purpose of data collection, surveying, sampling, and similar activities (excluding foreign travel for consulting);
    • Collaborations with investigators anticipated to result in co-authorship;
      Use of facilities or instrumentation;
    • Receipt of financial support or resources from a foreign entity.

Examples of ways to disclose a foreign component in a funding application:

    • Identifying a foreign component in an NIH grant application on the R&R Other Project Information Form (G.220):
      • Check “Yes” to Question 6, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
      • Upload a “foreign justification” document in Field 12, Other Attachments. This attachment should describe the resources or characteristics of the foreign research component (e.g., human subjects, equipment, research techniques, etc.) including reasons why the use of foreign facilities or other aspects of the project are appropriate for an international setting.
    • Listing a “non-U.S. performance site”
    • Reporting an Annual Research Performance Progress Report (RPPR)
    • Special Reporting Requirements – Section G
      • G.9 Foreign component. Provide the name, country, and description of each foreign component.

Other Support

Other Support reporting should include all your ongoing or proposed research activities. This includes any foreign sources of funding/in kind support, including equipment, supplies, lab resources and visitors to your lab supported by a foreign entity. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Most federal sponsors have guidance, for example:

NIH issued guidance: NOT-OD-19-114 clarifying “Just-In-Time” reporting for Other Support requires information about an investigator’s overall funding/resources prior to issuing an award. Reporting for senior/key personnel must include “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).” Examples include:

    • Federal contracts, non-federal research grants, cooperative agreements, institutional awards, talent program payments, in-kind support, etc.
    • Non-U.S. resource that supports the research of an investigator and/or researcher, but does not meet the definition of a foreign component because the work is being performed in the U.S.

NIH has also issued guidance that addresses different examples and the reporting requirements.

(2) National Science Foundation (NSF)

The National Science Foundation (NSF) has created a table for Pre-award and Post-award Disclosure requirements. This table identifies what pre- and post-award activities, such as academic training, appointments, current and pending support, in-kind contributions, consulting, travel, and honoraria, must be disclosed to NSF and details where to disclose if disclosure is required.

c.  Conflict of Interest and Conflict of Commitment Disclosures

Coming soon…

U.S. Export Controls and Restricted Parties

U.S. export laws regulate the shipment, transfer, or disclosure of physical exports, technical data, and software to foreign countries or to foreign persons, including our students and faculty, and entities within the U.S. These laws aim to protect U.S. national security, economic interests, and foreign policy.  Moreover, these laws restrict exports to certain entities and individuals, including some academic institutions in some countries, as well as the sharing of technologies with individuals affiliated with those entities while in the United States. 

Faculty and staff who engage in the following activities should be aware of export controls and how they apply in each case.     

    • Shipments to foreign locations
    • Procurement of goods or services from foreign vendors
    • Payments to foreign nationals and foreign companies
    • Faculty and staff travel to foreign countries
    • Contracting with a foreign source
    • Hosting foreign visitors and delegations
    • Foreign national access to controlled chemicals, microorganisms and toxins
    • Research involving specific military applications
    • Research collaboration with a third party appearing on a U.S. restricted party list
    • Hosting, attending or presenting at conferences, workshops or other similar types of events

Specific information on export controls and how to comply is available at https://www.boisestate.edu/research-export/export-controls/.

Purchasing Concerns

The federal government, through executive order, law, regulations, sanctions and other limitations, restricts or prohibits transacting with certain entities, including  Huawei Technologies, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate).

Boise State University will not enter into transactions with the above entities or other entities known to be indicted for crimes that threaten US intellectual property or economic well being. This prohibition is in addition to individuals or entities that are debarred, suspended or otherwise ineligible from receiving federal funding. 

Boise State uses a 3rd party Supplier onboarding and monitoring service provider called PaymentWorks.  PaymentWorks reviews new requested suppliers and monitors those suppliers 24×7 against any current or updated changes to executive orders, law, regulations, sanctions, denied parties and other.  If a supplier is listed in one of these areas, they are not added to Boise State vendor list and/or removed.

Boise State recently published a Supplier Responsibility Expectation document, which requires its suppliers to have a process in place to ensure all current Federal or State of Idaho laws or requirements are adhered through-out the supply chain.  

International Travel

Coming soon…

Data Security Guidelines for International Travel

Coming soon…

Protection of Intellectual Property

Coming soon…

Foreign National Visitors

Coming soon…

Peer Review

Coming soon…

Lab Tours

Coming soon…

Restricted Parties Screening

Coming soon…

Publication Guidance

Coming soon…

Case Studies

Coming soon…

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