Introducing YourYale
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As one of the world’s leading research universities, Yale is strongly committed to international research collaboration. In recent months, the National Institutes of Health and other federal agencies have expressed heightened concern about foreign influence on U.S. research. Faculty and staff should be aware of those concerns and of the shared obligation to safeguard the integrity of university research and to protect the intellectual property, sensitive data, and controlled information developed or housed at Yale. Yale values its relationships with international scientists and institutions, and Yale is actively working to protect longstanding principles of openness in collaboration and scientific publication. President Peter Salovey affirmed Yale’s steadfast commitment to international students and scholars in a letter to the Yale community on May 23, 2019.
In December 2018, the NIH Advisory Committee to the Director (ACD) published a report which outlined concerns about foreign influence on research and made recommendations to the Director. Matters identified included not disclosing conflicts of interest and commitment or financial support with or from international sources. This report followed a letter in August from NIH Director Francis Collins that identified concerns about improper foreign influence in US research – specifically, that foreign entities have developed systematic programs to influence NIH researchers and peer reviewers.
The Department of Energy and the Department of Defense are also taking actions against foreign interference by issuing restrictions on interactions with certain entities abroad. One example is the National Defense Authorization Act. The Office of Research Administration monitors all agencies and will communicate new regulations as they are adopted by the agencies.
Important obligations are associated with doing research and the acceptance of external funding. It is incumbent upon the faculty and University administrators to comply fully with all requirements of our sponsors. Examples of such obligations are detailed in the FAQ. An additional resource is Guidance for Faculty Concerning Consulting and Other External Activities.
Please visit the Export Controls webpage for information or the Office of Sponsored Projects page for information on sponsor requirements. Contact the Office of Export Controls at exports@yale.edu with questions on export controls and Lisa Mosley, Executive Director, Office of Sponsored Projects, lisa.mosley.@yale.edu for questions related to sponsor requirements and visiting scientist agreements.
NIH: Under current guidance from NIH, gifts are not required to be reported as Other Support. NIH has not provided guidance on what constitutes a gift.
NSF: NSF does not require gifts to be reported in current and pending support. However, under NSF guidance, items or services (including financial support) given with the expectation of an associated time commitment are considered in-kind contributions, not gifts, and must be reported as follows:
NIH: Under current guidance from NIH, high-value materials are required to be reported as Other Support whether or not they will be used in connection with the NIH funding sought.
NSF: NSF requires in-kind support:
NIH: Out of an abundance of caution, you should include all appointments (even if honorary) on your Biosketch. If the appointment makes available in-kind resources (laboratory personnel, space, materials, etc.) that are in support of and/or related to your research endeavors (including research endeavors that do not receive federal funding), the in-kind resources should be reported as Other Support.
NSF: NSF requires all appointments be listed whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). If the appointment makes available in-kind resources (laboratory personnel, space, materials, etc.) that are in support of and/or related to your research endeavors (including research endeavors that do not receive federal funding), NSF requires in-kind support:
NIH: If these collaborations make available in-kind resources that are in support of and/or related to your research endeavors (including research endeavors that do not receive federal funding), the in-kind resources should be reported as Other Support to NIH.
NSF: NSF requires in-kind support:
For international collaborations, NIH has reminded investigators that a foreign component is 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.” NIH has described three types of activities that constitute foreign components.
NIH has stated that the following grant-related activities may, but need not, give rise to a foreign component:
If the collaboration meets the NIH definition and was not listed as a foreign component in the funded application, NIH requires prior approval to add the foreign component.
NIH and NSF: Yes, it should be disclosed as Other Support to NIH and should be reported to NSF as Current and Pending support. It should also be disclosed to Yale via the Conflict of Interest Office.
NIH and NSF: Yes, these positions should be disclosed as Other Support to NIH and as Current and Pending support to NSF.
NIH: If the graduate student’s purpose in your lab is that of a trainee, they do not need to be disclosed as Other Support unless the graduate student’s activities in your lab are in support of, and/or related to your research endeavors, in which case the student’s non-Yale funding should be disclosed as Other Support to NIH.
NSF: For NSF, mentoring activities do not need to be reported as current and pending support if those activities take place as part of the graduate student’s regular appointment at Yale. If you receive in-kind support for mentoring graduate students directly (outside of the university) or through the university from an external source, that in-kind support, including the time associated with such mentoring, should be identified your current and pending support submission.
If you have access to resources that NIH considers to be Other Support and should be reported, but you do not think there is any scientific, budgetary, or commitment overlap, you should include a brief statement explaining your rationale of why there isn’t any scientific, budgetary, or commitment overlap.
NIH and NSF: If an investigator receives remuneration or in-kind support in connection with an external professional activity, and the activity is related to or in support of the investigator’s research endeavors, it should be reported as Other Support to NIH and Current and Pending support to NSF.
In general, a remunerated external activity should not be classified as “consulting,” and should be disclosed as Other Support/Current and Pending support, if it involves or any agreement specifies one or more of the following activities:
As a reminder, all external activities must comply with the Faculty Handbook including obtaining any advance approvals and reporting to the Conflict of Interest Office.
NIH and NSF have advised that in the interest of full transparency, recipients should err on the side of disclosure.
DOE Order No. O 486-1: Department of Energy Foreign Government Talent Recruitment Programs.
Prohibits DOE employees and contractors participating in foreign talent recruitment programs from certain countries from receiving DOE funding. The extent and reach of this requirement to recipients and subrecipients of DOE funding is not yet known as the requirement is being first implemented within DOE national labs.
Actions for the Protection of intellectual Property, Controlled Information, Key Personnel and Critical Technologies
Michael Griffin memorandum, sent March 20, 2019.