Foreign Government Interference in Academic Research

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We recognize an open Academy as a precious public good. Our pursuit of our academic mission depends upon upholding academic norms, including utmost discretion in handling unpublished matter and transparency regarding commitments and sources of material support.

Over the past few years, both universities and federal agencies have raised serious concerns about efforts by foreign governments to co-opt or capture academic intellectual and creative capacities. This has taken forms such as:

  • Recruiting of researchers into talent recruitment programs, including provision of compensation, research funding, facilities, and institutional positions, with individuals withholding knowledge of commitments, compensation, and material support from their home universities, colleagues, and the public.
  • Usurpation of ideas, for example by providing information from grant applications in review to governments or their agents who make private use of the information or seek patent rights based on it. Federal officials sometimes use theft of intellectual property to describe such practices.

See, for example

We recognize practices such as violations of trust in handling of unpublished information, involvement in usurpation or false attribution of ideas, and lack of transparency regarding affiliations or commitments as undermining the function of an open Academy. We are joined in this view by federal agencies that are concerned about integrity of peer review and proper use of federal funds, and also are invested in the healthy functioning of the Academy.

Shared commitments

Maintaining trust, including discretion in handling unpublished matter and other resources.  The functioning of the Academy depends upon members’ ability to generate, share, and test ideas, and to develop documents, data, samples, etc. prior to their general dissemination. Violation of trust in peer review, or in other settings in which unpublished ideas are shared in confidence, is a clear violation of expectations of all members of the Academy. Peer review of manuscripts, grant applications, academic programs, etc., require utmost discretion, lest the review process become injurious to those who originate and develop ideas or become compromised by lack of confidence in confidentiality. Similarly, researchers must be free to exchange, develop, and debate ideas, and share materials within research groups, departments, labs, etc. with confidence that these will be held in confidence. Such discretion with unpublished work is complemented by our equal commitment to open and unbiased publication of findings.

Transparency regarding commitments and sources of material support. Colleagues and stakeholders who rely upon the results of our work to inform their own endeavors and decisions have a right to know how our work is supported, and also a right to know of any personal or professional commitments and financial holdings that are relevant to our work. Good stewardship of university, public, and sponsor’s resources similarly requires such transparency. Therefore, full transparency regarding sources of support as well as relevant personal and professional commitments is expected of everyone involved in conception, planning, and conduct of research or in dissemination of results.

Communal and individual obligations

Individual actions have communal effects. In relationships with research sponsors in general and Federal sponsors in particular, a grant or contract involves a legally binding relationship between the university and the sponsor. Failure of any investigator to abide by principles of trust and transparency described here put at risk the university’s relationship with the sponsor and can therefore have effects on the entirety of the faculty, staff, student body, and university community.

Individual responsibilities

Transparency. Anyone involved in the conception, planning, conduct, or reporting of research should disclose all of their sources of support and their professional activities and commitments. Federal agencies specifically require disclosure of all professional appointments and commitments, and all sources of support for professional activities whether monetary or otherwise. When submitting proposals and accepting awards, your Contract and Grant Specialist in ORSP will provide guidance on the various proposal sections (“current and pending,” “other support,” “research environment and resources,” the biosketch, etc.) where such items need to be included.

Roles, commitments, and financial interests outside the university can present real or apparent conflicts of interest. Significant financial interests related to any research activity must be disclosed and must be managed as determined by the Conflict of Interest Review Committee.

Managing commitments. In addition to transparency with regard to the identity and nature of professional commitments, sources of support, and external financial interests, it is important that professional commitments outside the university not interfere with your commitments to your university work. The Rules and Procedures of the Faculty, Section 2.5, limits outside professional activity to those that are complementary to and noncompetitive with university duties. Within specified time limits, such complementary and noncompetitive activities do not detract from one’s ability to devote full-time effort to academic work at the university. In other cases, such as a case of having multiple academic appointments, it must be clear that the commitments are not in conflict, whether in terms of time commitments or otherwise. Federal agencies may require inspection of any contracts that an investigator has with other entities.

Related policies and procedures

  1. Required information in federal agency proposals
    1. NIH and NSF have specific requirements for disclosure of sources of material support and professional activities in grant applications. These affect what must be listed in Other Support/Current & Pending, resources/environment sections, and content of biosketches, and include resources accrued through unfunded and unpaid activities. Please consult with your Contract and Grant Specialist for support in understanding agency requirements at each stage of proposal submission.
    2. There are sponsor-specific terms and conditions limiting foreign involvement of personnel from certain countries (DOE, NASA) as well as any work conducted outside the US (DOE). There may be program-specific requirements as well.
  2. Disclosure and management of real or apparent Conflicts of Interest
    1. See the policies and guidance on conflicts of interest related to research and sponsored programs, the guidance on engagement in external business or professional activities, and the university-wide policy requiring annual disclosure of all conflicts of interest.
  3. Conflicts of Commitment
    1. The Rules and Procedures of the Faculty of Lehigh University, section 2.5, requires annual reporting to the chairperson of all faculty activities of a professional nature for which compensation is received.
  4. Foreign travel and international visitors
    1. While all University-supported foreign travel is currently suspended due to COVID-19, several specific countries remain under a comprehensive federal embargo (Cuba, Iran, North Korea, Syria, and the Crimea Region of the Ukraine). When it resumes, travel to or from these areas should be disclosed to the Office of General Counsel as soon as possible in advance of the anticipated activity to ensure appropriate clearance can be obtained.
    2. University policy generally allows for reimbursement to visiting foreign lecturers and other official visitors who are nonresident aliens, for expenses incurred in connection with their travel to the University. IRS regulations however, preclude the payment or reimbursement of travel expenses to foreign visitors who arrive in the U.S. with certain visa types. See “Payments to Foreign Visitors” in the Accounts Payable Procedures section of the Controller’s Office website. Travel arrangements through the University’s travel management company or any other vendor must be coordinated in advance through Accounts Payable. This ensures all necessary visa requirements and related documentation are accounted for prior to making travel arrangements for foreign visitors.
    3. Services for visiting scholars can be coordinated through the Office of International Affairs, Office of International Students and Scholars.
  5. Data
    1. LTS’s Information Security department protects Lehigh University’s information assets and resources through the implementation of oversight of administrative safeguards, technical safeguards, and awareness training and education. IT threats or data breaches should be reported to the LTS Information Security team.
    2. General export control issues are handled by the Office of General Counsel. Specifically, if you plan to use research data that is subject to Export Control Regulations AND you are storing that data on Lehigh's High Performance Computing (HPC) systems, research storage systems, or OSIsoft software, you must contact the Office of General Counsel to discuss whether you may need an Export Control License prior to using Lehigh's Research Computing Services.
  6. Tech Transfer
    1. All new inventions developed at Lehigh University should be promptly disclosed to the Office of Technology Transfer (OTT). OTT coordinates the efforts of the inventor/s, patent attorneys and commercial partners throughout the technology transfer/commercialization process.