Disclosing Outside Interests, Financial COIs
It is important that researchers disclose international affiliations and sources of support in funding applications to federal agencies and in OSU’s annual Conflict of Interest disclosure form. Examples of items to disclose include international research collaborations, outside financial interests, sources of support, paid travel, and positions and appointments (paid and unpaid). Disclosing outside interests protects researchers and allows OSU and Federal agencies to manage any potential conflicts and risks. Detailed guidance is found in the links below.
- Federal agency funding application disclosures: Biosketch and Current and Pending Support forms and guidance.
- Questions: contact Sponsored Programs and Award Contracting.
- Complete your annual research COI disclosure.
- Questions: contact the Research COI Office, Suzanne Billharz.
- Tips for disclosing international interests and engagements.
Foreign Government Talent Recruitment Programs
OSU prohibits participation in malign foreign talent programs
The CHIPS and Sciences Act of 2022 included a provision prohibiting participation in Malign Foreign Talent Recruitment Programs (MFTRPs) by key/senior personnel involved in research and development awards from federal funding agencies.
OSU researchers are encouraged to collaborate with international colleagues, institutions and companies. But OSU researchers are prohibited from participating in malign foreign talent recruitment programs, as defined by the U.S government.
OSU researchers are to report participation in any foreign talent program in their relevant research proposal documentation (e.g. current and pending support documents) and at least annually in a research COI disclosure if not prior to the start of participation.
What is a malign foreign talent recruitment program?
As defined by the Office of Science and Technology Policy, a malign foreign talent recruitment program is (as defined by Section 10638(4) of the Act):
(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—
(i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;
(ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;
(iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
(iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
(v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;
(vi) being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;
(vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;
(viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
(ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and
(B) a program that is sponsored by—
(i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern (see definitions in the Act, Section 10637);
(ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232); or
(iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232).
For questions regarding potential participation in a MFTRP please contact the Export Controls and International Compliance Office at [email protected] or 541-737-0647.