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Science & Security

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Introduction to Guidance on Science and Security

Collaborations are often the cornerstone of success in the research community and the University remains strongly committed to that idea by encouraging and supporting collaborative efforts worldwide. Concerns have been raised by Federal entities that certain international activities have begun to threaten the integrity of the U.S. research enterprise and they are taking steps to ensure more transparency and better security of confidential information and scientific data.

These concerns are commonly referred to as “Science and Security”. Another name you may have heard, used often by the media, is “Foreign Influence”. It is important that all faculty and staff understand these concerns and the impact on the research efforts at the University. To that end, the Office of Sponsored Programs has provided the following information.

Last updated: 06/23/2021

General
UNC Specific
Sponsor Specific

National Institutes of Health (NIH)

National Science Foundation (NSF)

Department of Defense (DoD)

Department of Energy (DoE)

National Aeronautics and Space Administration (NASA)

Last updated: 04/01/2020

Primary Concerns

  • Perceived Failure by Researchers to Fully Disclose Available Resources
  • Sharing of Confidential Information in the Peer Review Process
  • Loss of Intellectual Property

Direct Impacts to Research Enterprise

  • Increased scrutiny of university and researcher activities by Federal agencies
  • Various Federal agencies are coming out with their own guidelines regarding Science and Security
  • Lack of detail in the new or clarified Federal guidelines, particularly those from NIH

Current Impacts to Proposals / Projects

  • Clarified Requirements for NIH Other Support documents
  • Increased Expectations for capturing updated information on RPPR’s
  • Greater scrutiny over the use of foreign components and the requirement to get prior approval if award is active
  • Greater scrutiny of intellectual property terms during negotiations involving international sponsors

Targeted or Sensitive Research Areas

The following areas of research have been identified by the Federal Government as areas facing potential security threats:

  • Information technology
  • Energy-efficient and new-energy automobiles
  • Computer numerical control machine tools and robotics
  • Electric power equipment
  • Aerospace Equipment
  • New and Advanced Materials
  • Marine engineering equipment and high-tech ships
  • Biomedicine and high-performance medical instruments
  • Advanced rail transportation equipment
  • Agricultural equipment
  • Artificial intelligence and machine learning technology
  • Position, navigation, and timing (PNT) technology
  • Microprocessor technology
  • Advanced computing technology
  • Data analytics technology
  • Quantum information and sensing technology
  • Logistics technology
  • Additive manufacturing (e.g. 3D printing)
  • Brain-computer interfaces
  • Hypersonics
  • Advanced surveillance technology

Last updated: 06/23/2021

National Institutes of Health (NIH)

Other Support Documents

UPDATE: NIH has new requirements and templates for Other Support and Biosketch information that will be required beginning January 25, 2022. We encourage you to begin using them now. To view the latest training update, please review Updated Guidance on NIH Biographical Sketch and Other Support Documentation and Format Page (PDF).

NIH has clarified the requirements for Other Support. They include ALL resources made available to a researcher in support of and/or related to ALL their research efforts.

Financial Resources

  • Your externally funded active and pending awards, including those made directly to UNC-Chapel Hill by a Federal agency or made by another entity using Federal funds (e.g. active and pending direct awards, incoming subcontracts, pilot project funding provided by NC TraCS Institute, etc). Be sure to include both domestic and foreign awards and use TOTAL budget.
  • Funded service agreements to the University that involve you, because the funding organization must report these to the federal government through Open Payment disclosures.
  • Your funded external activities that directly impact your research or are research related. Federal guidance in this area continues to change so we recommend including research-related funding, even if the funds aren’t used to directly support your research, to be fully transparent.
  • Financial resources provided to another party in support of your research or research project (e.g. a grant to another University who donates some of the funds to you for specific use in your project).
  • Your startup funds provided by an entity other than UNC-Chapel Hill.

NOTE: NIH no longer requires gifts to be reported but you MAY report them if you want, especially if the gift directly subsidizes your research in some way. NIH also no longer requires you to report training grants or prizes.

In-Kind Resources

  • Lab or office space that you use outside of UNC-Chapel Hill to conduct research (e.g. a lab at a pharmaceutical company or other University). UNC-Chapel Hill resources should be placed in the Facilities and Other Resources section of your application.
  • High value scientific materials that are not publicly available and are given to you or your project for use in your research (e.g. drugs, mouse lines, assays, etc.). NIH has not defined “high value” so err on the side of caution. This includes materials provided to another party in support of your research or research project (e.g. free drugs provided to one of your collaborators who then provides them to you).
  • Collaborators whose efforts support your research in some way. If you have many collaborators, you may use a summary statement to describe them. See the example in the FAQ section on the OSR Science and Security webpage noted in the links section of this presentation.
  • Visiting Faculty/Scholars/Scientists/Post-Docs whose efforts support your research, regardless of funding sources, and undergraduate and graduate students whose efforts directly support your research but whose salary isn’t paid by your projects or who aren’t paid at all.

NOTE: Any domestic or international position you hold, including honorary, adjunct, or others should be placed in your biosketch, including those related to external activities.

Resources provided to another party in support of your research or research project(s)

The responsibility for the accuracy of your Other Support lies with YOU and you alone.

NOTE: Per the new NIH requirements that take effect on January 25, 2022, you will have to certify your Other Support document via signature, provide supporting documentation in certain situations, and alert your central research administration when your Other Support information changes so they can notify NIH.

UNC Templates and Resources

National Science Foundation (NSF)

General

NSF has officially issued its Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 22-1) opens in a new tab, which includes new Biosketch and Pending and Current Support (aka Other Support) requirements, increases the biographical sketch page limit to three and adds the NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support (PDF). This new PAPPG will become effective on October 4, 2021.

NSF has designated the National Institutes of Health’s SciENcv (Science Experts Network Curriculum Vitae) opens in a new tab as an NSF-approved format for submission of biographical sketch(es) and is encouraging its use to prepare a biographical sketch for inclusion in proposals to NSF. More information can be found here opens in a new tab.

NSF released the JASON Report in December 2019 (PDF), which provides a comprehensive overview of fundamental research security risks and makes recommendations for ways to improve security without compromising the inherent goals of fundamental research.

Due to the COVID pandemic, NSF has chosen to delay the new PAPPG requirement to use their designed Biosketch and Current and Pending Support formats until October 1, 2020. All other requirements outlined in the June 1 PAPPG release remain in place.

Current and Pending Support

Your NSF Current and Pending Support document now needs to include ALL resources made available to you in support of and/or related to ALL your research efforts. Responsibility for the accuracy of your Current and Pending Support lies with you and you alone.

Financial Resources

  • Your externally funded active and pending awards, including those made direct to UNC Chapel Hill by a Federal agency or made by another entity using Federal funds (e.g. incoming subcontracts). Be sure to include both domestic and foreign awards and use TOTAL budget.
  • Funded service agreements to the University that involve you, because the funding organization must report these to the federal government through Open Payment disclosures.
  • Your funded external activities that directly impact your research or are research related. Federal guidance in this area continues to change so we recommend including research-related funding, even if the funds aren’t used to directly support your research, to be fully transparent.
  • Your startup funds provided by an entity other than UNC-Chapel Hill.
  • Gifts given to you or UNC Chapel Hill that are used to support your research and require specific obligations and staff time commitments.

In-Kind Resources

  • The same types of in-kind resources listed in your NIH Other Support should also be used in your NSF Current and Pending Support though where they are placed in the NSF Current and Pending Support differs depending on how the resource is used. See below:
    • If the In-Kind contribution is NOT specifically related to the proposed project AND has associated staff time commitment, you must report it in the Current and Pending Support section.
    • If the In-Kind contribution IS specifically related to the proposed project, regardless of staff time commitment, you must report it in the Facilities, Equipment & Other Resources section.

NOTE: Any domestic or international position you hold, including honorary, adjunct, or others should be placed in your biosketch.

Department of Energy (DoE)

On February 1, 2019, DOE issued a memo (PDF) mandating that “DOE federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.” These requirements (italicized and underlined), as listed below, are excerpted directly from the DOE terms:

  • Individuals that worked on project, with the following information:
    1. Provide the name and identify the role the person played in this project.
    2. Indicate the total number of months (including partial months) (Calendar, Academic, Summer) that the individual worked on this project.
    3. Identify the person’s state, U.S. territory, and/or country
    4. Have other collaborators or contacts been involved?
Department of Education (DoED)

The Department of Education is currently updating their Section 117 guidance and receiving feedback from various organizations. No release date for the updated guidelines has been announced yet. These guidelines apply to organizations, not individuals.

The Department of Education has released new guidance regarding their Section 117 reporting that organizations must complete. For those interested, more details can be found here opens in a new tab.

Last updated: 05/25/2021

General

What steps is the University taking in response to the Science and Security issue?


The Vice Chancellor for Research Office has issued guidance to campus and established a dedicated website. A National Security Working Group has also been convened with cross-university membership. OSP has also issued guidance to campus and established a dedicated website dedicated to their area of responsibility.

I’ve been hearing a lot about China’s Talent Recruitment Plans. What exactly are they? [Updated: 1/28/2020]


China’s aim is to be the world’s leader in science and technology (S&T) by 2050. To achieve its goal, China has implemented a government campaign to recruit talent and foreign experts from around the world. One way they do this is through approximately 200 different talent recruitment plans that have recruited over 7,000 participants. These participants are often foreign-trained scientists and experts who provide China access to know-how, expertise, and foreign technology, often before this knowledge and technology is ready to be released or published by the participants themselves.

Is the Thousand Talents Plan one of China’s talent recruitment plans? [Updated: 1/28/2020]


Yes, the Thousand Talents Plan is China’s largest and most successful talent recruitment program and is the one under the heaviest scrutiny by U.S. Federal Government agencies, including national security agencies. It is also of great concern to many other world governments.

Why does the government consider the Thousand Talents Plan a risk? [Updated: 1/28/2020]


Thousand Talents Plan (TTP) targets U.S.-based researchers and scientists, regardless of ethnicity or citizenship, who focus on or have access to cutting-edge research and technology. In addition, TTP contracts have language that differs from U.S. research values in many ways that can raise concerns. A few examples of this are:

  • they require the individual to observe relevant laws of China, which are often at odds with the laws of the U.S.;

  • they often indicate that all intellectual property rights are owned by China;

  • they encourage shadow labs in China where the researchers work can be performed by others;

  • they require the individual to serve in a prominent position within their research field;

  • they require the individual to recruit postdoctoral students into their labs;

  • they often require the individual to not disclose the relationship or contract to unrelated parties;

  • they often require the individual to not reveal the financial aspects of contracts to their U.S. employers;

  • they often require comingling the results of research they do as part of the talent plan vs the research they do in the U.S. creating overlap situations;

  • they require a significant time commitment and create conflicts of commitment.

I’ve been approached by a possible international visiting scholar who would like to work in my lab for a bit. What kind of information should I consider before submitting a request for approval? [Updated: 1/28/2020]


There are several questions that should be asked to help determine if a visiting scholar would be appropriate to work in a UNC lab. They include, but are not necessarily limited to, the following:

  • What country is the visiting scholar coming from?

  • What is the source of funding for the visiting scholar?

  • Is the visiting scholar or their organization on the Federal restricted list?

  • What activities in the UNC lab(s) are of interest to the visiting scholar?

  • What would the official scope of work be for the visiting scholar and how does it relate to projects already underway in the UNC lab(s)?

  • Will any UNC or UNC researcher intellectual property be used, shared with, or licensed to the visiting scholar’s University?

  • Will the UNC researcher be sharing materials, compounds, or data from their lab with the visiting scholar?

  • Will the visiting scholar bring any intellectual property, materials, or data with them?

  • Will the visiting scholar bring proprietary or controlled materials with them?

  • Will the visiting scholar have access to any proprietary or controlled information while here?

  • Will the visiting scholar have access to any specialized facilities on campus?

  • What agreements are needed to manage any of the exchanges noted in questions 6 through 11?

  • Are joint publications with the visiting scholar anticipated? If so, are all parties clear on that?

  • Which offices at UNC need to be informed of this relationship – e.g. who needs to approve the appointment, a visa, use of intellectual property, use of facilities, etc.

  • Are there UNC policies on visiting scholars and if so, is this request within the bounds of those policies?

  • What visas or other government approvals are required?

  • What training/orientation should be provided for the visiting and the lab regarding UNC policies? Regarding the role of the visiting scholar in the laboratory?

  • Is any research being done in in the UNC lab(s) that has restrictions on foreign nationals, publications, export control, etc.? Be sure to consider both internal and external-funded research when answering this question.

  • Will the visiting scholar be working on any NIH awards? If so, OSP needs to clear it through NIH first per their new requirements.


Also keep in mind that, under current NIH requirements, if the visiting scholar comes the UNC researcher will need to report that on their Other Support and may also have to report them on other Federally-funded proposal documents.

If I have questions about visas, should I talk to OSP or another UNC office?


Any questions regarding visas for students or scholars should be directed to the International Student and Scholar Services, a unit in UNC Global.

Are the talent programs run by the Chinese government the only talent programs that exist?


No, many countries offer various types of talent programs. One example is Russia, which offers what they call a Mega-Grant competition.

What is the definition of a data steward?


Current policies identify several different roles within data security, and data steward is one of those. This is someone who is assigned to oversee particular types of data within the University, for example, Lauren Grazia is the data steward for FERPA data.

Where is the social security number/information saved?


On the safe computing site, under protect University data you find the Data Protection purchasing guide. At the bottom of that page is a listing of the different data types; click on Social Security numbers and then it will list those that have been approved.

Is it true that there may be more federal requirements for Universities related to Science and Security?


Yes. Currently there are several Congressional legislative acts working their way through the process that may affect Universities. The OVCR and Federal Affairs office are monitoring these carefully and will provide updates to campus when appropriate.
National Institutes of Health (NIH)

Other Support

A PI has transferred institutions and is bringing equipment with them that were bought with startup funds at their previous institution, would we consider that to be in-kind?


OSP would not consider that to be in-kind, because once the equipment is transferred it becomes UNC property. It could be put under the facilities and resources section instead of the Other Support, because once it’s absorbed into the University then it becomes a University resource.

Who can I ask about what needs to go into an Other Support document?


You can consult with OSP or the Sponsored Programs Office (if you’re a School of Medicine employee).

When I should I notify NIH that my Other Support information has changed?


That depends on the timing of your Other Support changes. If the changes occurred shortly after a JIT request was received for one of your applications, you should work with OSP or SOMSPO to send an updated Other Support to NIH as soon as possible. If it occurred during an active award period, you can update it when you submit your RPPR unless the changes are significant.

If there is an unpaid intern on the agreement who only works for a specific time, how long should they be reported on the RPPR?


OSP recommends going back one to three years for students and collaborators of that nature. But we’re allowing the researcher to make the final determination because we don’t have definitive guidance from NIH.

Will an updated version of the Other Support sample be available to the campus community via the OSP web site?


Yes, a sample of the completed template and the official NIH template, that takes effect on January 25, 2022, is available on the OSP Forms and Tools webpage in the Other Support and Biosketch section. While the new template is not required until January 25, 2022, we encourage individuals to transition to the new template now.

How many years of collaborative support should be listed on an Other Support document?


NIH has not given us a defined timeline. We recommend including ONLY ACTIVE collaborations. The definition of “active” in this case can be determined by the faculty member but if in doubt, please consult either SOMSPO or OSP.

Foreign Components

Do I need NIH prior approval to add a foreign component to an active award?


Yes. You’ll need to submit a prior approval request to OSP who will review it and send it to NIH. Work cannot begin on the foreign component until NIH approves it.

Do I need NIH prior approval before a foreign visiting scholar/scientist/faculty/post-doc can work on my NIH funded project?


It depends. NIH has requested that we discuss it with your Grants Management Officer first. In these cases, you should reach out to OSP with relevant information on the visitor and they will contact NIH on your behalf.

Financial Conflict of Interest (FCOI)

How does the NOT-OD-19-114 impact the FCOI policy?


There has been no change to the FCOI policy. NOT-OD-19-114 serves as a reminder to the extramural community of the requirements that are outlined within 42 CFR Part 50, Subpart F, Objectivity of Research (the FCOI regulation), which specifies the requirements for investigators to disclose to their institution their significant financial interests. The requirement to disclose includes financial interests received from a foreign institution of higher education or the government of another country. This requirement is distinct from other support and foreign components.

Department of Education (DoED)

As a researcher, do I have to file a report in response to Section 117?


No, the U.S. Department of Education's Section 117 requirements are organization-specific requirements. The University has to file reports related to it but individual researchers do not.
National Science Foundation (NSF)

Do we need to report internal awards for NSF?


Yes, you should report internal awards. NSF adopted the NIH definition and says that current and pending support should include all resources in support of all research, which includes both internal and external.

Last updated: 05/25/2021

To further assist researchers and research administrators in remaining informed about our shared responsibility to safeguard the security of our science and comply with federal requirements, OSP will begin a series of informational trainings on several topics in this area.

Format

OSP will provide a combination of computer based training (CBT) and live webinars to share information on Science & Security opens in a new tab at UNC. This will include major areas of impacts, sponsor specific information and best practices.

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