Foreign Influences and Its Impact on Research Integrity – A Four-Part Series | Part 3: Recent Developments in Improper Influence on Scientific Research
In this four-part series, we will discuss Part 1: What is Foreign Influence; Part 2: Federal Agencies’ Policies on Foreign Influences; Part 3: Recent Developments in Improper Influence on Scientific Research; and Part 4: Lessons Learned from the NIH Survey.
Research organizations were deluged in December and January with guidance on foreign influence from presidential directives to reports from the General Accounting Office (GAO), Office of Science and Technology Policy (OSTP), and private MITRE Corporation. Specifically, those reports are:
While each contained unique findings and recommendations, some common themes emerged that provide insights on where the federal agencies may be headed in this complex area of regulatory compliance.
GAO-21-130 The five agencies examined by the GAO (DoD, DoE, NASA, NIH, and NSF) collectively issued almost 90 percent of the federally funded research at universities. In addition to reviewing mechanisms and enforcement utilized by those five agencies to monitor and enforce their policies to prevent the failure of researchers to disclose financial and non-financial conflicts, the GAO examined the policies of and interviewed administrators and researchers from 11 universities. Their findings were categorized into five categories of reform: harmonization of agency policies, consideration for minimizing administrative burdens, communication of and training on the risks, and disclosure by researchers of involvement in foreign government talent recruitment programs. The recommendations clearly indicate we can expect revised and or expanded policies from all five agencies.
MITRE Report The MITRE report inferred a broader problem by using the term “improper influence.” The MITRE Corporation is a not-for-profit organization chartered to work in the public interest. MITRE Interviewed 157 individuals in 65 sessions conducted last summer with representation from 19 universities and eight federal agencies. The report noted barriers to improvement and gray areas of uncertainty, mostly linked to the lack of consistency among the agencies in their policies.
The findings of the report underscore the importance of openness in US federally funded fundamental research and that attracting scientists globally should remain a top priority; however, they caution that must be balanced against compliance with regulations. The report acknowledged that universities lack access to information to ensure compliance. Not surprisingly, researchers interviewed cited two troubling perceptions: 1) that the federal granting agencies do not value foreign collaboration; and 2) that there is a lack of clarity that should be considered in weighing opportunities to collaborate internationally.
The report urged agencies and universities to shift the approach from rules and compliance to one of risk reduction and acknowledged this area of compliance requires consideration across the entire life cycle of a project. Alignment of policies across all federal agencies should be the paramount goal for the agencies and universities should focus energies on educating researchers to understand what poses risk.
NSPM-33 This memorandum was issued by President Trump in January directing enhanced information sharing and coordination and standardization of disclosure processes, definitions, and forms among federal agencies. Greater outreach to and the development of education and training resources for universities and other recipients of federal funds in support of research and development. The memorandum further orders universities to establish and operate research security programs and to require review of foreign government talent recruitment program contracts for their researchers.
Although President Biden has overturned many of the directives issued under the Trump administration, he has not, at this time, reversed this presidential directive. Given that changes in leadership of the OSTP have occurred, it would seem likely that the new administration might choose an alternate approach.
JCORE Report This report is a companion piece to NSPM-33. The Joint Committee on the Research Enterprise (JCORE) of OSTP comprised of representatives from federal granting and national security agencies enlisted inputs from across the research enterprise: universities, companies, associations, and scientific societies. Their findings were consistent with these other reports. This report focused on the role of universities and other organizations that conduct federally funded research and development.
The JCORE stressed that an organization’s compliance culture is set at the top and urged organizations to ensure the highest levels of governance e.g., trustees understand this obligation. It also cited the need for universities to appoint a chief research security officer but recognized that ensuring research security and integrity will take oversight from a larger working group. This is not a siloed approach to compliance and requires a centralized approach for evaluating research partnerships, especially those with international collaborators. One unique recommendation was that universities should track the “sum of all appointments” for researchers inclusive of those commitments that fall outside institutional responsibilities and appropriate consequences for failure to comply.
Common Themes There were some commons themes that emerged across all of these reports. Greater harmonization and standardization across the federal agencies are critical to removing the ambiguity created by individual agency requirements. Education and sharing of information to facilitate a risk-based and less reactive approach will support the desired end result where administrative burden is minimized, compliance is achieved, and research can be conducted with global cooperation and respect.
President Biden issued his January 27, 2021, Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking, directing OSTP to convene an interagency task force review of the effectiveness of agency scientific integrity policies with the goal of ensuring scientific independence by enforcing those policies. The focus will be on preventing improper political influence on the conduct of research. Coupled with the MITRE report which introduced the term “improper” influence in its title, it now seems time to change the narrative from “foreign influence” to “improper influence.”
The term improper influence does not in any way negate or diminish national security concerns but recognizes that the reason for bias in research can be multicausal and can arise from outside influences both domestic and foreign. The federal agencies have been slow to revise their policies, rather issuing guidance and procedures that enforce their policies that were always stated in this broader context which is inclusive of foreign influence. Foreign and foreign-born researchers at our institutions have felt maligned and targeted by the inference that the only threat of concern comes from foreign governments and foreign players. Citing improper influence rather than foreign influence appropriately characterizes the real or perceived threat to research integrity and shifts the vernacular from a term that is too narrowly interpreted and proliferates the notion that the only threat to scientific integrity comes from foreign governments.
Authored by Dr. Susan Wyatt Sedwick, CRA, Senior Consulting Associate
SRAI Distinguished Faculty