It is very common for researchers to engage in professional activities outside of WashU. Most of these activities do not present concerns for the university or funding agencies, provided they are properly structured and disclosed.
It is important to be fully honest in all disclosures. Even if an activity does not feel relevant to disclose, it is relevant to the university and funding agencies.
External Professional Activities and Interests
Requirements for disclosing to the university are covered in the External Professional Activities Policy, Prior Approval Guidance, and Financial Conflicts of Interest training.
- External Professional Activities associated with any international entity (government, non-profit, for-profit, university/academic), must be disclosed.
Funding agencies typically have their own reporting and disclosure requirements. These commonly include:
Documents such as the Biosketch and Current and Pending (Other) Support
Report external activities, research activities, and international activities. For more information, visit the NIH and NSF disclosure pages.
Certifications of no engagement in maligned foreign talent programs
Review the Guidance for Foreign Talent Programs page on the COI website.
Foreign components
Activities that contribute to a specific aim of your grant. Examples (adapted from the NIH):
- Collaborations with investigators at a foreign site anticipated to result in co-authorship
- Using facilities or instruments at a foreign site
- Receiving financial support or resources from foreign entity
- Involving human subjects or animals
- Extensive foreign travel for the purpose of data collection, surveying, sampling, etc.
Funding agencies may use disclosed information to perform risk assessments to identify and counter foreign influence.
Personal Agreements with an External Entity
The University does not formally review and approve your personal agreements/contracts; however, the External Professional Activities Policy requires prior approval for these activities. There are aspects of an agreement you should be mindful about when partnering with a foreign entity that you may not experience with a domestic entity. Refer to Guidance for Personal Agreements for a list of examples and best practices.
Some entities may be considered a restricted party, which could prohibit or limit certain activities with an entity (or country or person). A consolidated screening list search engine available online. The University can also provide a more comprehensive screening by contacting the export control office at ovcrexportcompliance@wustl.edu.
Key Factors in Risk Assessments
- Countries of concern: Collaborations with individuals or entities within countries of concern.
- Foreign affiliations and appointments: Any formal relationship with a foreign institution or government.
- Financial support from foreign entities: Receiving funding, gifts, or other forms of support from foreign sources.
- Participation in foreign talent recruitment programs: Involvement in programs that may pose a risk to national security.
- Sharing of sensitive research data or technology: Transferring information or materials that could be subject to export control regulations.
- Information on emerging technologies, such as AI, quantum computing, and hypersonics.
- Authorships: Foreign co-authorships may be considered, depending on the sponsor.
What Should Researchers Do?
Understand agency-specific policies as each agency has its own unique policies and procedures. Researchers should understand the specific factors considered in a risk assessment prior to submitting a funding application:
- NIH Decision Matrix
- NSF TRUST Risk Assessment/Mitigation Framework
- DOD Academic Research Security webpage including the DOD Component Decision Matrix to Inform Fundamental Research
- DOE Approach to RTES Risk
- DARPA Risk Matrix/Rubric
Federal agency policies and risk assessment processes are dynamic and subject to change. Researchers should consult the official agency websites for the most current information.
Questions?
If you are ever unsure if something should be disclosed, it is best to ask the Conflicts of Interest (COI) office.