Disclosure, transparency and data security in research
Since the University of Alabama at Birmingham’s inception as an independent university in 1969, achievements in research would not have been possible without collaborations of all kinds, including those with our international colleagues.
UAB is proud of its strong tradition of global engagement, with faculty, staff and students from more than 100 countries represented on campus. We are committed to our shared values of collaboration, integrity, stewardship and accountability in the way that we handle the nearly $600 million in extramural funding that helps to power our world-changing research enterprise.
Over the last year, Congress and several federal agencies, including the National Institutes of Health, the National Science Foundation, the U.S. Department of Defense and the U.S. Department of Energy, have expressed growing concerns about foreign influence on academic research.
This site will help to make you aware of how federal sponsors are requiring greater transparency in declaring international collaborations. It also will guide you to what actions you personally must take to ensure compliance, as well as the actions that UAB’s research enterprise is taking.
Although there is a lot of attention on foreign aspects of research collaborations, the changes cover all collaborations, domestic and international.
Preserving the integrity of biomedical research
Some of you may be aware of the letter to research institutions and an official statement in August 2018, in which NIH director Francis Collins, M.D., Ph.D., noted several threats to the integrity of U.S. biomedical research, including:
- “failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments”;
- “systematic programs to influence NIH researchers and peer reviewers” by “some foreign entities”;
- “diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries”; and
- “sharing of confidential information on grant applications by NIH peer reviewers with others, including in some instances with foreign entities.”
COGR Summary Recommendations for NIH Other Support (as of Dec. 5, 2019) (pdf)
Dr. Collins indicated that NIH and government agencies would be working with NIH-funded institutions to improve “accurate reporting of all sources of research support, financial interests and relevant affiliations.”
He also noted an expectation that institutions will work with faculty and administrative staff “to make sure that, in accordance with the NIH Grants Policy Statement, all applications and progress reports include all sources of research support, financial interests and relevant affiliations” and that all institutions are expected and encouraged “to notify us immediately upon identifying new information that affects your institution’s applications or awards.” In July 2019, NIH released NOT-OD-19-114 and an associated FAQ clarifying these expectations.
Other funding agencies are following the NIH’s lead. For example, recent communications include a Department of Energy talent policy notification in January 2019 stating the department’s intent to mandate that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment plans” and Department of Defense memos in March 2019 stating disclosure requirements and protection of intellectual property.
What has UAB done and who does this affect?
In response to these concerns, UAB has established a Taskforce on Productive International Partnerships with membership consisting of faculty and senior administrators involved in international programs, research administration, information security and compliance. The taskforce is evaluating the guidance and communications from federal sponsors, academic consortia and peer institutions to identify areas of highest risk to assist those UAB investigators and administrators most directly impacted.
In addition, there have been several discussions among campus leadership groups to build awareness of the issue of foreign influence and reiterate institutional commitments to transparency and integrity, and the Office of the Provost launched workshops for department chairs on “Managing Your International Risks.”
These changes affect all of UAB’s federally funded investigators, those with pending projects, and/or those planning to submit. We recognize this will require a significant culture change and the institution will need to work together to achieve this.
What do you need to do?
There are immediate steps that can be taken to adhere to UAB expectations for transparency and data security.
- Disclosure of support: All current and pending support (i.e. Other Support, Biosketch, etc.), including
all foreign-sourced support, all affiliations and resources, whether internal, in-kind or external, must be disclosed in grant applications, JIT and progress reports, as required by the sponsor. The inclusion of a foreign component (e.g. sub-awards, consultants, and funded or unfunded collaborations with investigators located at a foreign site) in a project must also be disclosed in grant applications and reports. Click here to see NIH’s definition of foreign component. - Disclosure of External Activity: Obtain advance approval for all external activities with foreign entities, including affiliations and appointments with foreign institutions, and disclose financial interests, as appropriate, under the UAB Enterprise Conflict of Interest and Conflict of Commitment Policy. External activities performed by UAB faculty and staff must meet UAB standards.
- Observing Appropriate Security Precautions when Traveling: Before traveling outside the U.S. or Canada on UAB business – regardless of what entity is paying for the travel – complete UAB-related International Travel Registration Form and review the UAB IT Guidelines for International Travel to safeguard data and devices you are carrying with you. This registry helps the university to respond and assist in the event of individual or group emergencies.
- Work through the UAB Office of International Student and Scholar Services when sponsoring visiting international scholars on campus, and avoid unsolicited, unscheduled or unsupervised on-site visits to UAB.
- Contact the Office of Compliance & Risk Assurance if your work involves shipment, transfer or transmission of export-controlled items or information.
Your important work is appreciated. Further questions may be directed to Michael Matthews at