White House Foreign Research Disclosure Guidance in the Works

By Hugh T. Ferguson, NASFAA Senior Staff Reporter

The White House, in an effort to clarify and simplify how researchers — including those at colleges and universities — disclose information to the federal government, has provided updated guidelines for providing more concrete rules for ensuring research security and researcher responsibilities, including disclosure of foreign gifts or contracts.

While additional guidance is forthcoming, the document — released by the National Science and Technology Council (NSTC) — directs a number of federal agencies to develop a common reporting form and details certain consequences for violations related to disclosure requirements that could result in the Department of Education’s (ED) suspension or denial of Title IV funds.

The guidelines, which serve as implementing guidance for federal agencies following the 2021 memorandum from former president Donald Trump’s administration, reiterate that ED would have the ability to terminate, suspend, or limit an institution’s participation in the Higher Education Act (HEA) Title IV programs, which would result in the denial of federal student financial aid to its students.

According to the document, any proposed action under this provision would be required to comply with HEA’s requirements for notice and opportunity of a hearing.

The document sets out standards for determining appropriate consequences, consistent with applicable laws and regulations, while preserving a level of flexibility for agencies and research organizations.

According to the document, federal research agencies within the next 120 days will model a grant application form on how researchers should disclose foreign research ties. ED is listed as a member of the subcommittee on research security.

“The goal is for the government to clearly describe what it needs to know and for researchers to be able to report the same information in the same way to the greatest extent possible, regardless of which funding agency they’re applying to,” wrote Wrote Eric S. Lander, the director of the White House Office of Science and Technology Policy and chair of the NSTC. “Clearly laying out the required information will ease administrative burdens on the research community.”


Publication Date: 1/6/2022

David S | 1/6/2022 9:12:43 AM

And I encourage all of my colleagues to be prepared, if necessary, to point out to their President or anyone else on campus that the words "financial aid" appearing once in a 34-page document does not mean that the Financial Aid Office is responsible for disclosures of foreign gifts or contracts. Just in case...

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