Research Security
Research Security

Disclosure Management

Georgetown researchers should understand the risks, prohibitions and disclosure and reporting requirements associated with formal and informal international engagements and collaborations.

Key points:

  • Federal research agencies, and Georgetown as a recipient of federal research funding, prohibit federally funded researchers’ involvement in malign foreign talent recruitment programs (MFTRPs). A one-page resource on MFTRPs is available here.
  • Federal research agencies have placed restrictions — and in some cases prohibitions — around engagement and collaboration with entities (and individuals associated with such entities) designated by the U.S. government as presenting national security risks and engaging in activities that jeopardize national or economic security, violate research integrity or involve foreign government interference.
  • The current U.S. government list of known MFTRPs and entities of concern from a research security perspective is accessible here. Note that other U.S. government agency lists (e.g., BIS) are relevant and may be associated with restrictions and/or prohibitions. Visual Compliance screenings performed by Georgetown can flag entities and individuals designated by the U.S. government as presenting research security concerns.
  • New federal agency certifications in “Other Support and Biographical Sketch” forms, as well as reporting obligations related to foreign components and budget justifications, relative to outside affiliations, collaborations and support, have significant repercussions for non-compliance.
  • Complete and accurate disclosure by researchers to Georgetown and federal agencies in accordance with applicable requirements, policies and processes is crucial to protect Georgetown researchers and Georgetown’s research enterprise. Additional documentation related to formal or informal foreign arrangements (e.g., agreements, contracts, appointment letters) may be required to be provided to JORA and/or ORO upon request.

Foreign Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs
Foreign Talent Recruitment Programs (FTRPs) are programs in which foreign governments aim to recruit talented professionals and students in targeted fields for the purpose of benefiting from or appropriating knowledge and expertise. These programs often utilize funding through grants and research fellowships to encourage researchers to relocate to the foreign country or share information with the foreign country.  

A FTRP (as defined in OSTP Guidelines) is “…any program, position, or activity that includes compensation in the form of cash, in-kind compensation, or other types of remuneration directly provided by a foreign country at any level (national, provincial, or local) or an entity based in, funded by, or affiliated with a foreign country…”. The definitions of “in-kind” compensation and “other types of remuneration” are broad, so Georgetown researchers should be cautious and seek advice from the Office of Research Oversight (ORO) or the Joint Office of Research Administration (JORA) if approached about any arrangement that could qualify as an FTRP. Participation in an FTRP must be disclosed and may be prohibited.

Malign Foreign Talent Recruitment Programs (MFTRPs) (defined in Section 10638(4) of the Chips and Science Act, are programs with characteristics that encourage, or even require, unethical behavior, and/or contain requirements that may conflict with the terms of federal research or development awards and university policies (e.g., requirements relative to the transfer to the foreign entity of intellectual property, information, materials or data owned by a federal agency or developed with federal funds). 

The risks of participating in an MFTRP include impacting national or economic security by exposing U.S. research to increased risk of intellectual property theft or diversion, and potential disqualification from participating in federally funded research. 

Involvement in MFTRPs by federally funded researchers is prohibited. MFTRPs most often involve “countries of concern” (currently China, Iran, North Korea and Russia, but this list may change). The current U.S. government list of known MFTRPs and entities of concern from a research security perspective is available here. 

Contact JORA at jora@georgetown.edu or ORO at researchsecurity@georgetown.edu with any questions relative to arrangements that might qualify as an FTRP or MFTRP, or to request a consult or screening in advance of agreeing to engage in an international activity or collaboration (formal or informal) with a currently-designated country of concern (China, Iran, North Korea or Russia).

Pending and Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. 

Federal research sponsors require that researchers disclose “other support” to ensure there is no scientific, budgetary or commitment overlap. 

Other support is a broad term that includes financial or in-kind resources that may support individuals or labs conducting sponsored research. It can include consulting engagements, collaborations (paid or unpaid), support from foreign entities for individuals in a lab, participation in foreign talent recruitment programs or in projects and activities that provide personnel, materials, space, equipment, data and more. 

A Biographical Sketch (“biosketch”) documents an individual’s qualifications and experience for a specific role in a project, and requires inclusion of academic, professional or institutional appointments.

Federal research sponsors require that researchers submit a biosketch to aid in their assessment of ensuring that individuals included on the application are equipped with the skills, knowledge and resources necessary to carry out the proposed research.

New certifications for researchers in the context of research security have been added to the federal research sponsor “Other Support and Biosketch” forms. 

Additional details on “other support” and biographical sketch disclosure, and reporting obligations related to foreign components and budget justifications can be found here. Researchers should consult with JORA if they have questions regarding “other support” disclosures.

A conflict of commitment can occur when an individual’s external activities, whether paid or unpaid, interfere with or appear to interfere with their ability to fulfill their primary obligations to their employer or institution, including federally funded research. When the federal government funds a research grant or contract, it wants assurance that researchers supported by federal funds are willing and able to devote the portion of their time that is charged to the grant or contract. Federal sponsors also want assurance that federal funds are not supporting work already funded by another research organization or entity. 

In general, a conflict of commitment is an outside engagement or activity to which a researcher devotes time, whether or not they are compensated, and may include interests or relationships that could compromise objectivity, judgment, willingness or ability to meet and perform their obligations for Georgetown. 

Disclosure of outside engagements and activities is important, and Georgetown researchers should discuss any outside activities with their managers and ORO. Full-time Georgetown faculty are required to make conflict of commitment disclosures under the Outside Professional Activities Policy, which requires prior approval for certain outside activities, including those activities that do not contribute to fulfilling a faculty member’s research, teaching, and service responsibilities to the University, and/or that involve serving as a PI, co-PI, or in any other role listed as committing effort to a sponsored research, service or education grant or contract awarded through another institution or entity without a subcontract to Georgetown.

All university employees must disclose external commitments that could impact their primary Georgetown responsibilities, both to their supervisor and through the university’s COI disclosure process, as applicable. This disclosure promotes transparency, protects research integrity and upholds the university’s mission by maintaining a fair balance between external engagements and institutional obligations.

Researchers should consult with ORO if they have questions regarding outside professional activities or conflict of commitment.

Georgetown’s financial conflicts of interest policy underscores the fundamental expectation that our work will be conducted with objectivity and integrity. It seeks to identify potential, actual or apparent conflicts of interest and provides processes for disclosure of interests that may create such conflicts as well as processes for eliminating or, when appropriate, managing them. 

Researchers participating in federally funded research are required to disclose external financial interests and relationships that relate to their institutional responsibilities. 

More information about the University’s conflict of interest policy can be found on ORO’s  Financial Conflict of Interest Policy website.  Researchers should consult with ORO if they have questions regarding COI disclosures.

In order to ensure the university can identify individuals with access to laboratories, research facilities and research information and systems, an academic visitor onboarding portal, housed in GU360, has been created to allow for pre-arrival review of non-Georgetown-employed academic visitors. This review utilizes a risk-based approach of pre-visit disclosure, verification and other applicable requirements to individuals operating in academic or research capacities, based on the duration and nature of their visit to Georgetown. Visitors are categorized by risk category in the following ways:

Category 1: Visit duration less than two weeks with no laboratory, clinical or other high-risk activities;

Category 2: Visit duration two weeks or longer, with no laboratory, clinical or other high-risk activities; and

Category 3: Visit including laboratory, clinical or other high-risk activities, regardless of duration.

All Category 2 and Category 3 visitors must be onboarded using the academic visitor onboarding portal, as well as Category 1 visitors coming from countries identified as high-risk “countries of concern” (currently China, Iran, North Korea, Syria, Cuba and Russia, but this list may change).

Two hands holding a packet of papers with the title "All Things Ignatian Grants."