Process for Handling Allegations Related to Foreign Interference

Learn about NIH's standard procedures for handling issues related to undisclosed other support, foreign components, and financial conflicts of interest (FCOI). Please also see this Decision Matrix that further explains how NIH Assesses Potential Foreign Interference and what organizations and their researchers should know as part of our ongoing efforts to be transparent about policies and procedures.

Standard Procedure

  1. Potential issues are identified by:

    1. Institutional self-disclosure
    2. NIH Institute or Center or NIH Office of Extramural Research (OER) staff
    3. Anonymous allegations received in various ways, including through submition via [email protected]
    4. Other, including law enforcement

     

  2. Allegations/concerns are reviewed by OER staff to assess:

    1. If NIH-funded grants are involved
    2. Whether sufficient and verifiable information exists to proceed
    3. What information has been disclosed to NIH

     

  3. If NIH-funded research is involved, OER staff conduct an in-depth assessment to determine whether other support was properly disclosed. The NIH Deputy Director of Extramural Research (DDER) sends a letter to the institution (usually the Vice President of Research) regarding the issue. The letter content includes:

    1. A reminder of NIH's requirements for disclosure of other support, foreign components, and FCOI regulations.
    2. A request for the following information, as applicable:
      1. All applications, notifications of award, and progress reports related to undisclosed grants (English translation and original language)
      2. Employment documents (including all contracts or agreements) for the individual's positions at foreign institutions
      3. A request for a response within 30-60 days

     

  4. Institutional responses are reviewed to assess:

    1. Whether there is any scientific, commitment, or budgetary overlap with NIH projects
    2. Whether Significant Financial Interests (SFIs) were appropriately disclosed to the recipient institution
    3. Whether the individual adhered to Financial Conflict of Interest (FCOI) management plans
    4. Whether prior approval was obtained for foreign components on the NIH project
    5. Other factors and actions relevant to the allegation

     

  5. Appropriate actions are taken commensurate with degree of noncompliance, which may include:

    1. Coordinating with funding IC(s) on necessary grants management actions
      1. Requesting the recipient institution to identify a replacement principal investigator on an NIH award
      2. Holding pending awards associated with the PI of concern until compliance issues are resolved
      3. Fully or partially restricting funds until compliance issues are resolved
      4. Imposing specific award conditions to terms of award
    2. Working with recipient institution to recover funds
    3. Referral to the HHS Office of Inspector General (OIG) and/or referral for suspension or debarment

     

Contact

When potential issues related to disclosing other support, foreign components, and FCOI are identified, notify NIH. If in doubt, ask!

For General Questions and Concerns

NIH Office of Extramural Research
Phone: 301-435-0949
Email: [email protected]

Report Allegations

If allegation is about a specific award, contact the funding institute and/or
[email protected]

This page last updated on: September 10, 2024
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