Disclosure and Reporting of Foreign Support
Louisiana State University (LSU) strongly supports and encourages international collaboration in research and scholarly activities. International collaborations are critical to fulfilling LSU’s commitment and vision to be a leading research-extensive university and to the mission of the generation, preservation, dissemination, and application of knowledge and cultivation of the arts. To support our continued international collaborations and grow new opportunities worldwide while protecting LSU and LSU personnel from undue foreign influence that threatens scientific and academic values and research integrity, it is important for all personnel to understand the concerns being raised at the federal level and be reminded of our existing obligations for disclosure and transparency.
NIH Letter to Grantees
Recently, the federal government and federal sponsors have issued documents expressing concern about foreign influence in funded research. The Director of the National Institutes of Health (NIH), Francis Collins, issued a “Foreign Influence Letter to Grantees,” which outlines specific concerns regarding threats to the integrity of US biomedical research, including diversion of intellectual property, sharing of confidential information with foreign entities, and failure by some researchers to disclose substantial support from foreign governments. As a result, institutions of higher education are more aware of the possible impact of these foreign relationships on all funded research, not just in the biomedical domain.
Current Disclosure Obligations for Foreign Support
As the federal agencies and government officials finalize requirements for additional disclosure regarding foreign support, we want to remind you of the following current obligations regarding disclosure:
This includes all foreign or domestic grants, cooperative agreements, contracts, and institutional awards. You should also note any planned collaborations (foreign or domestic) and their scope, including the exchange of information, material, or data.
Disclose all outside employment by completing the required PM-11 Disclosure of Outside Employment. This requirement applies to both US and international outside employment.
LSU PS-98 (Policy on Financial Conflicts of Interest in Research) requires all investigators who are applying for or currently holding active externally funded projects to have a current Significant Financial Interest (SFI) disclosure on file. A disclosure is submitted and updated annually or when any changes to the disclosure take place.
Disclose travel reimbursed or paid for by a third party. This is required of all investigators (includes all individuals who are responsible for the design, conduct, or reporting of all externally funded research or proposals). Refer to PS-98 for additional information.
Be knowledgeable of your responsibilities to comply with US export control laws and regulations related to publication restrictions in research, traveling internationally (including international conferences), engaging in international collaborations, shipping materials internationally, working with international faculty and students, and participating in any international transactions. Review LSU’s export control policy (PS-119) and resources.
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) or nondisclosure agreement (NDA). These agreements are negotiated by the Office of Innovation and Technology Commercialization (ITC)
If required, disclose your activities, affiliations, and relationships when speaking, teaching, or publishing with outside organizations, including in scientific journals and professional societies.
The LSU GeauxGrants system is used for all PM-11 Outside Employment and PS-98 Significant Financial Interest and travel disclosures. Links and relevant help materials for GeauxGrants click here.
Any concerns or questions you may have about a specific situation relating to foreign support should be addressed to exportcontrol@lsu.edu.