What Do Researchers Need to Do?
The best way for researchers to mitigate concerns regarding inappropriate foreign influence are by educating themselves, their staff, and their students about relevant regulations and policies, completing all federal, state, and UCF disclosure requirements, and providing ongoing communications regarding any new or changing relationships with foreign entities.
UCF has policies and procedures in place to assist with meeting the above requirements, but in general researchers should:
- Meet sponsor disclosure requirements.
- Disclose financial interests and outside activities to UCF.
- Ensure that they and their staff are current with Export Control policies and procedures.
- Disclose Inventions and Other Intellectual Property.
- Limit engagements with High Risk Entities.
Meet Sponsor Disclosure Requirements
When seeking federally funded research, many federal agencies have added or reiterated reporting requirements related to outside activities and financial interests with foreign entities. Please note that federal and state agencies may release further guidance over the coming months, so be aware that information and requirements may change at any time.
Multiple federal agencies including, but not limited to, DOE, DOD, NSF and NIH have reporting requirements related to foreign activities when seeking federally funded research.
- For DOE, DOD, and NSF, foreign activities should be disclosed within Current and Pending Support and/or the Biosketch.
- For NIH, foreign activities should be disclosed in Other Support, Foreign Component, Facilities and Resources, and/or the Biosketch.
- What is required to be disclosed depends on the particular agency. To identify disclosure requirements related to a particular funding opportunity, individuals seeking federal funding for research should review:
- The individual agency announcement,
- The funding notice, the agency guidebook, and
- The award terms and conditions.
Please note, the failure to fully disclose foreign activities to federal agencies can have serious consequences on the ability of individuals and UCF to obtain future federal funding.
If you have questions regarding particular disclosure requirements, please work with your proposal manager and/or contract manager.
Disclose Financial Interests and Outside Activities to UCF
In addition to the federal requirements mentioned above, Florida State Statute 1012.977 was enacted on July 1, 2020, to also address the concerns related to inappropriate foreign influence. To assist faculty, staff, and students in meeting these reporting requirements, UCF amended the online AA-21 disclosure to include a new question, Question 12. Question 12 only applies to individuals engaged in research at UCF.
The purpose of obtaining responses to this question is to provide employees the mechanism to comply with the federal and state disclosure requirements and allow UCF to evaluate whether there is a potential inappropriate foreign influence risk that requires additional review by UCF.
For more information about what and how to disclose to UCF, please visit compliance.ucf.edu/conflict-of-interest/.
For questions regarding the AA-21 Form and process, please contact: PCA@ucf.edu.
Ensure that You are Current with Export Control Policies and Procedures
In general, export controls are federal laws that govern the export of controlled items and technical data to foreign countries and foreign nationals. While inappropriate foreign influence does not just target export-controlled technologies and data, the UCF community can help mitigate the risks of inappropriate foreign influence by making sure to comply with all applicable U.S. export control regulations, UCF export policies, and project-specific plans (if applicable). For more information on export control compliance, please see www.research.ucf.edu/ExportControl/index.html.
For questions regarding export control compliance, please contact: Ashley.Guritza@ucf.edu.
Disclose Inventions and Other Intellectual Property
Another way to help mitigate the risks of inappropriate foreign influence is to disclose intellectual property to the UCF Technology Transfer Office in accordance with UCF policy. For more information on intellectual property protection and UCF policies, please see tt.research.ucf.edu/
Limit Engagements with High Risk Entities
The U.S. Government prohibits U.S. entities from engaging in activities with parties that are identified on the U.S. Denied Parties Lists. Separate from these lists, certain entities have been identified through publicly available information as entities known to target U.S. technology and/or have affiliations that are counter to U.S. National Security interests (High Risk Entities). At this time UCF faculty, staff, and students should consider the risks associated with engaging in activities with High-Risk Entities. For more information, on High-Risk Entities click here https://www.research.ucf.edu/ExportControl/GuidanceEngagingInActivitiesWithHighRiskEntities.html.