Foreign Government Interference on UIC Research and Scholarship

The University of Illinois system is driven by the guiding principles Globalization and Immigration, Excellence with Integrity, and Freedom of Speech, among other guiding principles. The mission of the University of Illinois at Chicago (UIC) is to create knowledge that transforms the world and, through sharing and application, transforms the world. As one way to accomplish this, UIC, through the Office of Global Engagement, strongly encourages international engagement and collaboration. UIC welcomes more than 6,000 international students and scholars to our campus each year. UIC also houses a number of internationally recognized and globally engaged research centers in urban studies, architecture, public health, social work, medicine, and engineering. International collaborative research and scholarly exchange is at the heart of high-impact scholarship, and UIC research must continue to be internationally engaged.

UIC must also adhere to the principles of research integrity and transparency. UIC will continue to support open and transparent scientific inquiry. To that end, our faculty, staff and students should understand the current regulatory landscape and be aware of responsibilities to:

  • adhere to research security policies and procedures, including cybersecurity training, export control training, and reporting of all international travel through the OGE travel roster;
  • safeguard university resources and intellectual property;
  • fully disclose external financial interests, affiliations and activities; and,
  • follow export regulations.

Faculty and staff are directed to the January 21, 2021 Presidential Memorandum on United States Government-Supported Research and Development National Security Policy and the Guidance For Implementing National Security Presidential Memorandum 33 (NSPM-33) On National Security Strategy for United States Government-Supported Research and Development for more information regarding federally mandated changes to outside activity disclosures and changes to sponsored project applications and reporting.

Always obtain pre-approval from your unit head, department chair or dean for all non-university activities. This includes outside professional activities as well as relationships and foreign talent recruitment programs. Submit a Pre-Approval Request and update your Disclosure Profile in UIC Research COI to report these activities and affiliations.

Please review the UIC COI Guidance for Disclosing Foreign Interests for information on reporting foreign interests as part of required conflict of interest reporting.

Remain cognizant of whether or not your international travel, research, foreign engagement, visiting scientists and collaborators may be subject to U.S. export regulations.  If so, be sure to review UIC resources on managing export compliance, or contact the Export Compliance Officer at uicexport@uic.edu.  Please be aware that social media applications in certain countries may be monitored by law enforcement officials.

Ensure that any transfer of intellectual property, proprietary data, material or technical information to foreign entities is covered by an appropriate agreement such as a material transfer agreement (MTA), data use agreement (DUA) or nondisclosure agreement (NDA) negotiated by the Office of Technology Management and/or the  Office of Research Services in the Office of the Vice Chancellor for Research.

Some sponsors like the Public Health Service (PHS) require investigators to disclose significant financial interests and non-UIC sponsored travel that could reasonably be related to your university responsibilities. This includes financial interests with foreign entities, including foreign institutions of higher education or the government of another country.  PHS Disclosure information may be found here.

This includes all foreign or domestic grants, cooperative agreements, contracts and institutional awards. You should also note any planned collaborations (foreign or domestic) and the scope of the collaboration, including the exchange of information, material or data.

According to the Office of Science and Technology Policy (OSTP), a foreign government-sponsored talent recruitment program is an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.

If required, be sure to disclose your activities, affiliations and relationships when speaking, teaching or publishing with outside organizations, including in scientific journals and professional societies.

It is the responsibility of the departments and units, and specifically the Department Head, to know in which outside activities faculty are engaged beyond their university responsibilities. Department Heads, during annual reviews, outside activity reviews (currently the RNUA disclosures), and when requests for new outside activities are brought, should be comparing the activities with the faculty’s CV and sponsored program submission documents.

Departments and units should also be aware of faculty and staff publications and understand that the affiliations listed on the publications as well as the cited funding . Federal sponsors are actively questioning Universities and researcher in regard to the undisclosed international support overlap, foreign components (e.g. NIH) and International Activities (e.g.NSF). If any part of a project being sponsored by a federal sponsor is being conducted at an international site, the foreign component or international activities must be pre-approved by the sponsor. Citation of a research award in a manuscript that includes (1) authors that have only an affiliation at another institution and/or (2) funding from international governments and/or agencies has been flagged by federal sponsors as being international activities or foreign components and, at times, unreported other support available to the researcher. Researchers are encouraged to seek pre-approval of all foreign components and international activities from federal sponsors. Researchers are also encouraged to report all other support, including research support to any collaborators on the project. The NIH includes as a foreign component “collaborations at a foreign site anticipated to result in co-authorship”, therefore, proper requests for pre-approval of a foreign component and proper acknowledgement of support only when research is the product of a specific award is needed. Departments and

Please contact the Office of Research Integrity (ori@uic.edu) with any questions or concerns.