Update: Required Disclosure of Foreign Engagements Must be Complete and Timely

***The National Science Foundation name was corrected; an example and contact information was added to the Conflict of Interest section.

UC San Diego is committed to sustaining an environment that attracts and retains the brightest scholars and most exciting scholarship. This is embodied by our commitment to the University of California's principles of academic freedom. Our talented population of scholars and students, from across California, the United States, and the world, are essential to the research and education enterprise on our truly global campus. We value your collective contributions beyond measure.

The International Research and Engagement webpage provides policies and best practices to help ensure that your work, reputation, and efforts in association with the work and reputation of the university are as unassailable as possible. This begins with proper documentation and reporting procedures.

Like all other institutions of higher education, our university and its faculty and researchers must adhere to federal reporting and disclosure requirements. Not doing so could result in loss of federal funding, not only for the individual who failed to report something, but for the institution as a whole.

Federal government agencies, including the Office of Science and Technology Policy (OSTP), the National Institutes of Health (NIH), the National Science Foundation (NSF), and other frequent federal sponsors of UC San Diego research, have issued guidance on research security in an effort to safeguard “the U.S. research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference.”

Research security remains a prominent and growing source of concern. Specifically, there is a heightened concern that certain foreign entities may be seeking to influence U.S. research at all levels including peer review, diversion of intellectual property, sharing of confidential information and the use of resources originating outside the United States. Critical to UC San Diego's success and impact, federal research funding is the largest share of our $1.64 billion research enterprise. We must comply with existing and new research security policies and regulations, including those related to full disclosure of foreign engagements, conflicts of interest and conflicts of commitment.

Again, we reiterate our commitment to academic freedom and international collaborations. Our work is grounded in principles of equity, diversity, and inclusion as instantiated in UC San Diego’s EDI Strategic Accountability Framework. Actions reflecting xenophobia or prejudice are contrary to UC’s principles and will not be tolerated.

ACTIONS:

1. It is your professional responsibility to completely and accurately disclose all applicable external financial interests and support, affiliations, activities and relationships with outside entities, including foreign entities. The University of California requires all faculty to submit an annual Conflict of Commitment (COC) report indicating whether or not they have engaged in outside activities during the fiscal year. Disclosure must occur through the UC OATS system.

Disclosure forms are required even if faculty members have nothing to disclose. Deans are responsible for ensuring that all faculty members submit an annual disclosure and that the disclosures are accurate.

Outside professional activities are separated into three categories: Categories I and II include activities that must be reported. Category I items require approval before the faculty member engages in the activity. Examples of Category I activities include:

Faculty or research appointments at other institutions (even if uncompensated)
Directorships of labs, centers or programs at other institutions (even if uncompensated)
Teaching, research or administration of a grant

Read more about COC requirements on Blink.

2. Conflict of Interest (COI) policies require all university employees who are conducting research or other related activities to disclose certain financial interests, whether domestic or foreign. Financial interests include anything of monetary value (whether that value can be easily determined or not) held by the employee, a spouse or registered domestic partner, and dependent children. Examples include:

Income or payments for salaries
Consulting or honorariums
Holding a position such as founder, partner, employee or board member
Having ownership interests such as stocks, bonds or stock options
Any royalties from non-UC inventions
Travel funds or reimbursements

New financial interests should be disclosed within 30 days of their acquisition. All conflict-of-interest disclosures must occur through Kuali COI. For questions, please contact the COI office at info-coi@ucsd.edu.

Read more about COI disclosures on Blink.

3. Applicants for federal grants must appropriately disclose foreign affiliations (biosketch) and "other support" prior to award and are required to identify any changes in each annual progress report, per a federal agency’s guidelines.

NIH, UC San Diego’s largest federal sponsor, “requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards.”

NIH’s policy covers research contracts and grants, cooperative agreements and organizational awards, including any from foreign governments or entities (e.g. affiliations; collaborations; foreign patents; and exchange of information, materials or data) as defined in the NIH Grants Policy Statement.

NSF and other federal agencies have similar disclosure requirements. Please ensure that you carefully review your sponsor’s requirements prior to submitting this information.

With the implementation of National Security Presidential Memorandum-33 (NSPM-33), federal science agencies are streamlining and aligning these requirements.

4. Export Controls: If you are or will be engaged in any of the following, please consult with the UC San Diego Export Control Office at export@ucsd.edu.

Teaching foreign nationals about the use or design of export-controlled equipment, tools, or related technologies
Disclosing or shipping third-party controlled proprietary information or items to a foreign national in the U.S. (even if in a UC San Diego laboratory) or to anyone outside the U.S. as part of a research project
Receiving any export-controlled information or controlled proprietary information or items specified in non-disclosure agreements, contracts, grants, material transfer agreements, or purchase orders
Providing any service or anything of value to a sanctioned country or region (e.g., Cuba, Iran, North Korea, Syria, Sudan, or the Crimea Region of Ukraine)

RULE OF THUMB
Any external support or engagement that you would acknowledge in public presentations or publications is something that you must also disclose in grant applications, annual reports and closeout summaries and in university-related COI and COC disclosure forms (as required).

SUMMARY
It is essential for you to be transparent about any affiliations with foreign entities when applying for federal grants. Only by your full disclosure will UC San Diego be in compliance with University of California regulations and therefore able to advise, assist and protect you and your work.

This situation is fluid so there will likely be additional guidance in the future. If you have any questions or concerns, please contact your department chair or the university’s Office of Research Compliance and Integrity, rci@ucsd.edu.

More resources:

University conduct requirements are available at International Research and Engagement.
Review the President’s Update on Research Security: Streamlining Disclosure Standards to Enhance Clarity, Transparency, and Equity.

Elizabeth H. Simmons
Executive Vice Chancellor

Corinne Peek-Asa
Vice Chancellor of Research