Are you pursuing any activity (e.g. research collaboration, visiting scholar, grant opportunity, travel) that involves a country of concern? Fill out the International Activity Review to initiate review by the VUMC Research Security team.
The following are currently designated "foreign countries of concern" by the CHIPS and Science Act and subject to the international activity review:
- China
- Russia
- North Korea
- Iran
Vanderbilt University Medical Center (VUMC) is committed to fostering a collaborative learning environment of open scientific research, the intellectual exchange of ideas, and international academic research collaborations and engagement. VUMC is also committed to ensuring the security of this research, in partnership with federal research agencies.
There are three major categories of international research activities:
- International Collaboration
- Foreign Talent Recruitment Programs
- Malign Foreign Talent Recruitment Programs
These categories are defined by the CHIPS and Science Act and resulting Office of Science and Technology Policy (OSTP) policy guidance to help guide federal research agencies in drafting and implementing their individual policies. Available agency policies will be linked under "Resources" as they become available.
Each activity category has unique considerations and restrictions, at both the institutional- and agency-level. All VUMC personnel should carefully read the VUMC "Participation in Foreign Talent Recruitment Programs" policy. VUMC personnel should report all sources of foreign support on conflict of interest disclosures, any time a change occurs and at least annually. All VUMC personnel should also comply with individual agency requirements.
Contact Susan Meyn (s.meyn@vumc.org) or Amy Martinez (amy.f.martinez@vumc.org) with any questions about international collaborations or foreign talent recruitment programs. Connect with us for guidance before pursuing ANY collaboration with or support from a country of concern or a listed entity. Fill out the International Activity Review as a first step.
Vanderbilt University guidance on Malign Foreign Talent Recruitment Programs is found here.
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The VUMC "Participation in Foreign Talent Recruitment Programs" policy is effective as of July 2024. The policy defines Foreign Talent Recruitment Programs and outlines acceptable and prohibited international collaboration activities.
View and download the policy here.
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The following Research Agency policies have stipulations that prohibit covered individuals* from participating in Malign Foreign Talent Programs. This page is regularly updated as policies are announced and refined.
- National Institutes of Health
- NIH will adopt Common Forms for disclosures beginning May 25, 2025
- Common forms require all senior/key person to certify that they are not a party to a malign foreign talent recruitment program
- NIH policy references:
- https://grants.nih.gov/grants/guide/notice-files/NOT-OD-24-163.html
- https://nexus.od.nih.gov/all/2024/08/15/new-decision-matrix-further-clarifies-nih-processes-for-handling-allegations-of-foreign-interference/
- https://www.nih.gov/about-nih/who-we-are/nih-director/statements/nih-supports-our-valued-asian-american-asian-immigrant-asian-research-colleagues
- National Science Foundation Reporting Requirements (See "Certification Regarding Malign Foreign Talent Recruitment Programs")
- Each senior/key person must certify that they are not a party to a malign foreign talent recruitment program, prior to proposal submission and annually thereafter
- The institution must certify that each senior/key person is not a party to a malign foreign talent recruitment program
- DoD Statement "Countering Unwanted Influence in Department-Funded Research at Institutions of Higher Education"
- DoD will not fund any project in which a covered individual is participating in malign foreign talent recruitment program
- The institution must have a policy addressing malign foreign talent recruitment program
- DoD is also responsible for maintaining the list of entities of concern. The current lists include: is the 1286 list and the 1260H list.
*Covered Individuals: Per the CHIPs and Science Act (Section 10638), "the term 'covered individual' means an individual who—
- contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and
- is designated as a covered individual by the Federal research agency concerned."
Research agencies may expand upon this definition in their individual policies.
- National Institutes of Health
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Federal Guidance
- CHIPS and Science Act (PUBLIC LAW 117–167, Aug. 9, 2022)
- White House OSTP "Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs" (Feb. 14, 2024)
- DOD Lists of Institutions and Programs labeled as Malign Foreign Talent Recruitment Programs (Tables 1 & 2, July 19, 2024) - sometimes called the "1286 lists"
- DOD List of Chinese Military Companies operating in the United States (Jan. 7, 2025) - the "1260H list"
Vanderbilt Resources
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Updated Slide Deck (8/19/24)
Contains updates since the time of the town hall, including information about disclosing support to NIH on federal common forms