The current regulatory landscape informing the research enterprise includes serious growing concerns by the U.S. Government concerning inappropriate influence by foreign entities over federally funded research. As a result, academic research institutions have a heightened interest in understanding the affiliations and dealings faculty members may have with foreign governments and entities. The University of Kentucky encourages international collaboration, and recognizes it is important for investigators to be transparent about their foreign relationships and activities.
Research Security
Background
Federal agencies have issued statements expressing growing concerns over the potential for foreign influence in the following areas:
- failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments;
- diversion of intellectual property to foreign entities;
- sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.
Required Research Security Training
To comply with National Security Presidential Memorandum 33 (NSPM-33) and the CHIPS and Science Act of 2022, UK is requiring all investigators currently engaged in research on a federally funded award or submitting a federally funded proposal to complete research security training by October 1, 2025.
Covered Individuals—principal investigators (PIs), Co-PIs, key/senior research personnel or anyone meeting the definition of “Investigator”—are required to complete Research Security Training as a condition of federal research funding. This is an annual requirement and must be completed prior to submitting a proposal to a federal funding agency. UK has contracted with CITI Program to offer a one-hour online training course, “Research Security Training (Combined).” Advanced courses in CITI on Risk Mitigation, Cybersecurity, International Collaborations, International Travel, Foreign Interference, Federal Funding & Foreign Gifts and Contracts, and Disclosures and Transparency are also available and will be used as annual refresher training.
To access Research Security Training (Combined):
- On the ORI Training & Education page, click the “UK CITI Access” link.
- Once you have logged into your UK CITI account, scroll to the bottom of the page and click on “Add a Course.”
- On the UK CITI Select Curriculum page, check the box for Research Security and click “Next.”
- On the next page, check the box for “Research Security Training (Combined)” and click “Next.” You have now enrolled in the course.
- On the UK CITI course page and under Courses Ready to Begin, press “Start Now” in the box titled “Research Security Training (Combined).”
- Under Required Modules, click “Start” for the module called “Research Security Training (Combined) (ID 21604)” to complete the training.
Please reach out to Sara Poll in UK SECURE at researchsecurity@uky.edu with questions.
This training fulfills the requirements outlined by the NIH Sept. 11: Implementation of NIH Research Security Policies, NOT-OD-25-154.
Disclosure of Foreign Relationships and Activities
All investigators on sponsored projects should check the sponsor’s current disclosure requirements carefully and, if in doubt, contact Sara Poll in UK SECURE at researchsecurity@uky.edu for disclosure assistance or further guidance. In addition, investigators should take the following actions:
- Review and update Other Support and Current and Pending Support information in proposals
- Review and update biosketches
- Ensure appropriate disclosure of foreign components for NIH-supported projects
- Review COI disclosure and update as necessary
- Report all reimbursed or sponsored travel related to PHS-supported projects
- Reach out to UK SECURE's Export Control Specialist for guidance related to export control regulations
- With the assistance from Technology Commercialization, enter into a material transfer agreement or nondisclosure agreement when sharing or exchanging materials or information
Guidance regarding the types of relationships and activities that University of Kentucky investigators are expected to disclose are explained below.
Transparency in Disclosure
Disclosure to Sponsors
- Foreign components of federally funded research should be disclosed in proposals, progress reports, and final technical reports in compliance with sponsor requirements.
Researchers should be thorough and complete in accounting for all forms of research support, including from foreign sources and gifts, in NIH’s Other Support, the NSF’s Current and Pending and similar documentation submitted to other sponsors.
Under the NIH Grants Policy Statement, a Foreign Component is defined as “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.” The definition of foreign component includes “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.” Other sponsors have similar requirements to disclose foreign components.
There are multiple ways in which foreign components should be disclosed, including
- Identifying a foreign component in an NIH grant application
- Listing a non-U.S. performance site
- Identifying foreign relationships and activities in a biosketch
- Answering “yes” to the question on the R&R Other Project Information Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.
Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed.
- All ongoing or proposed research projects and sources of support should be included in Other Support, Current and Pending Support or Just-in-Time response as required by federal sponsors.
"Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Such support should be disclosed on an Other Support or Current & Pending form, as required by the sponsor. Sponsor guidelines typically specify that all sources of support be disclosed, regardless of whether they are awarded by another sponsor or provided by the University of Kentucky (e.g., department/college or faculty start-up funds).
NIH’s most recent guidance can be found at NOT-OD-19-114 and its FAQ encourages full transparency and advises recipients to “err on the side of disclosure.”
NSF’s current Proposal and Award Policies Guide (PAPG) requires that “the proposed project and all other projects or activities requiring a portion of time of the PI and any other senior personnel must be included, even if they receive no salary support from the project(s).”
Participation in foreign talent programs, such as China’s Thousand Talents Program, must be disclosed to federal sponsors.
PIs should review all pending proposals and active awards to ensure that all Other Support has been disclosed.
Disclosure to the University
- Significant financial interests received from any foreign entity, including governments and universities, must be disclosed, per University of Kentucky Administrative Regulation AR 7:2 Financial Conflicts of Interest (COI) in Research.
AR 7:2 applies to Investigators on any sponsored agreement that is in preparation, has been submitted to a sponsor or is currently funded, and to Investigators involved in research funded by the University. Investigator includes the project director or principal investigator/program director, co-investigator, collaborator, senior/key personnel, faculty associate, and any other person, regardless of title or position, who is responsible for the design, conduct, reporting, or proposing of research or other activity that is sponsored by an extramural agency. Postdoctoral scholars and fellows may be considered investigators if designated as such by the Principal Investigator on a case-by-case basis.
Investigators who apply for or receive funding through a Public Health Service, should disclose reimbursed travel and travel paid on behalf of the Investigator that reasonably appears related to their institutional responsibilities within 30 days of the completion of such travel.
Effective July 15, 2019, all COI disclosures include questions specifically related to affiliations with foreign entities, including appointments or positions at entities outside of the United States, incentives, gifts or money from any entity or agency outside of the United States as well as any promises in exchange for work from a non-US entity or agency. In the updated COI disclosure, faculty are asked to provide a description of any of work performed at or on behalf of a non-US entity or agency that is similar to work at the University of Kentucky.
All Investigators are required to file annual COI disclosures and promptly provide updated disclosures within thirty (30) days of changes in their COI status. The COI-Smart system can be accessed at https://uky.coi-smart.com/ using your LinkBlue ID and password.
Export Controls
See the UK SECURE Export Controls page at https://research.uky.edu/secure/export-controls-sanctions-compliance.
Intellectual Property
When materials or data will be shared with foreign institutions a material transfer agreement (MTA) or nondisclosure agreement (NDA) should be in place, governing the use of those materials or data. Having an agreement allows the University to complete all required internal controls and checks. Technology Commercialization provides guidance on these agreements. Additional information is available at https://research.uky.edu/uk-innovate/technology-commercialization/transfer-agreements.
Malign Foreign Talent Recruitment Programs
As required by federal law, UK issued a policy concerning participation in foreign talent recruitment programs (FTRPs) effective August 9, 2024. The CHIPS and Science Act required federal research funding agencies (e.g. NSF, NIH, DOE) to establish policies that require “covered individuals” to (a) disclose all participation in foreign talent recruitment programs and (b) certify that they are not a party to a malign foreign talent recruitment program (MFTRP) at the time of project proposal submission and annually thereafter for the life of an award issued by those agencies. As a recipient of federal research funding, UK must certify that such individuals have been made aware of the requirement. As part of the policy, UK prohibits covered individuals from participating in malign foreign talent recruitment programs. Individuals at UK may check their MFTRP response by reviewing their personal profile on research.gov.
- University of Kentucky Policy on Disclosure and Participation in Foreign Talent Recruitment Programs (PDF)
- Federal definition: Malign Foreign Talent Recruitment Program
See below for agency-specific requirements.
NSF
- To confirm compliance with this requirement, NSF requires each principal investigator certify their lack of participation in such a program by logging into research.gov. A prompt will appear when you log in.
NIH
- 9/1/25: NOT-OD-25-154
- Individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.
- NIH will require MFTRP certifications from applicants and individuals identified as senior/key personnel with its implementation of the Common Forms for Biographical Sketch and Current/Pending (Other) Support.
DOD
- The Department of Defense (DoD) has published the 2025 Decision Matrix to Inform Fundamental Research Risk Decisions. These updates will be effective for all proposals submitted on or after May 9, 2025. These include the removal of the requirement for institutions to have a policy prohibiting participation in a malign foreign talent recruitment program (researchers are still prohibited from participation in such a program by statute, only the institution policy piece has been removed.) DoD added a prohibition included in Section 238 of the FY 2025 NDAA: “Collaborations for the specific purpose of fundamental research between institutions of higher education and academic institutions that are included in the most recently updated list developed pursuant to section 1286 of the NDAA for FY 2019, as amended, or employees of such institutions.” The updated matrix also changes some of the dates that would trigger expected or suggested mitigation measures and removes the distinction between “associations” and “affiliations.” Finally, the language of the matrix has been clarified as to the treatment of co-authorships with institutions on various entity lists or with persons in malign foreign talent recruitment programs. Co-authorships with listed entities should not be the basis for the denial of an award but may result in mitigation measures being requested on a project-by-project basis. As noted in the matrix, international collaboration is an important mechanism for participating in the global scientific commons and promoting progress in fundamental research. View the most recent matrix here.
DOE
- Prohibition on Malign Foreign Talent Recruitment Program Participation
- Senior/key personnel will need to certify that they are not participating in a malign foreign talent recruitment program as part of their current and pending support disclosure. Additionally, DOE has restricted participation in foreign talent recruitment programs of countries designated by DOE as a foreign country of risk, currently China, Russia, Iran, and North Korea.