New Training Requirements for Recipients of Federal Funding

The topic of foreign influence in research is the focus of a new training requirement to be completed by all Principal Investigators and key personnel named on federal funding proposals.

Since early 2018, federal science agencies and the U.S. government have raised concerns that foreign entities may be using the academic research enterprise in an attempt to compromise the United States’ economic competitiveness and national security. Federal funding agencies have clarified longstanding policies and issued new guidance. Federal law enforcement agencies have increased investigative and prosecutorial activity in unison with the federal funding agencies. And, Congress has signed new legislation and sought information on how the academic research community is responding to this evolving issue.

The primary concerns of the U.S. government and federal funding agencies include:

• Failure by some researchers at National Institutes of Health (NIH)-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.
• Diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries.
• In some instances, sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.

An NIH advisory committee issued the Foreign Influence on Research Integrity report which includes recommendations to the NIH and to organizations who receive federal funding. The NIH subsequently released Foreign Interference in National Institutes of Health Funding and Grant Making Processes: A Summary of Findings From 2016 to 2021, which describes the most frequent issues identified at institutions. At CHOP, we have used these recommendations and findings to promote organizational awareness, enhance research compliance training content, and strengthen our internal controls.

One step we will take at CHOP to raise visibility about this topic and to ensure recipients of federal funding fulfill their role as stewards of research funding is to require CITI Program’s course Undue Foreign Influence: Risks and Mitigations. This course consists of four modules and must be completed by all Principal Investigators and key personnel named on federal funding proposals. Instructions on how to enroll in the course are available at https://www.research.chop.edu/services/undue-foreign-influence-in-research. The deadline for completion is Dec. 31, 2021. After Jan. 1, 2022, this training must be completed prior to utilization of funding.

A similar training requirement has been incorporated into the Responsible Conduct of Research (RCR) curriculum. We anticipate this training requirement will become an expectation of funding agencies in the future. The Research Compliance and Risk Subcommittee, which includes faculty and Principal Investigators, reviewed and approved this training plan.

If you have questions about completing this new training requirement, contact ResearchTraining@chop.edu. If you would like to learn more about the topic of foreign influence in research, please contact Michelle Lewis or Matthew Hodgson.