UCLA Office of the Executive Vice Chancellor and Provost
To: Deans, Directors, Department Chairs, Administrative Officers, and Faculty
UCLA values and encourages international collaborations and educational opportunities that promote openness in research, serve our research and teaching missions, and advance academic freedom. Affiliations with foreign institutions, collaborative research, and scholarly exchanges are an essential part of the academic community. At the same time, the University of California must be careful to comply with U.S. laws and regulations that govern how international engagements are managed and reported.
Members of Congress and federal agencies have recently raised concerns over whether foreign entities may be attempting to take advantage of the open nature of the research-and-development environment at U.S. universities. In August 2018, Francis Collins, the director of the National Institutes of Health (NIH), issued a “Foreign Influence Letter to Grantees (PDF)” that reminded the research community of the need to “disclose all forms of other support and financial interests, including support coming from foreign governments or other foreign entities… in accordance with the NIH Grants Policy Statement, [on] all applications and progress reports.” As Dr. Collins’ statement makes clear, transparency in this area is essential. UCLA and external funding agencies need to know about the relationships that UCLA and individual members of the research community have established with foreign organizations.
UCLA is committed to maintaining an open and robust research environment while complying with applicable laws and regulations and protecting important research. The following is a summary of some of the key disclosure obligations that govern research, gift solicitation, and outside activities that often come into play when working with international partners.
Proposals for Research Support
- Employees who receive any part of their salary through the University, or whose activities use any University resources or facilities, must submit all proposals for extramural support through campus contracts and grants offices. Awards must be made to “The Regents of the University of California.” Exceptions may be granted in unusual circumstances on a case-by-case basis. See the Requirement to Submit Proposals and to Receive Awards for Grants and Contracts through the University (PDF).
- NIH grants policy requires the disclosure of your involvement in all ongoing and proposed research projects. All financial resources, including support from foreign entities, must be included in the Current and Pending Support/Other Support section of research proposals. This includes any direct research support provided to you, even if it is not administered by UCLA.
- The National Science Foundation has similar requirements for reporting “Current and Pending Support.” All proposed and ongoing projects that require that the Principal Investigator and other senior personnel devote a portion of time must be included, even if they do not receive salary support from that project. Our Office of Contract and Grant Administration has recently issued a memo on this topic, which can be found online.
Gifts and Donations
- Only designated University personnel are authorized to accept gifts from any source. For this reason, you must disclose to the Office of External Affairs all gifts solicited from any domestic or foreign individual or organization.
- Faculty appointed at 50% time or greater must seek prior approval to engage in certain outside professional activities that might constitute conflicting commitments under Academic Personnel policies. See APM 671 for members of Health Science Compensation Plans and APM 025 for all other faculty.
- Activities that require prior approval include:
- Teaching, research, or administration of a grant at another educational institution, trust, organization, government agency, foundation, or other entity outside of the University. This includes foreign institutions of higher education, and government or quasi-governmental organizations of other countries;
- Employment outside of the University;
- Assuming a founding or a co-founding role of a company;
- Assuming an executive or managerial position outside of the University.
- Faculty governed by APM 025 and APM 671 must also file annual reports of outside professional activities, whether compensated or uncompensated. Those reports include activities for which prior approval is required, and activities such as:
- Providing outside consulting services or referrals or engaging in professional practice as an individual or through a single member professional corporation or sole proprietorship;
- Serving on a board of directors outside of the University;
- Providing or presenting a workshop for industry.
- See APM-025, APM-670, and APM-671 summaries online, and Appendix 19: Conflict of Commitment and Outside Professional Activities for policies, forms and guidance.
Disclosure of Financial Interests
- Those who are applying for external research support must also disclose personal financial interests. Disclosure processes include:
- Principal Investigators and others who share responsibility for the design, conduct and reporting of federal Public Health Service-supported research (including NIH) must disclose all personal financial interests related to the breadth of their institutional responsibilities, through the electronic Disclosure Gateway (eDGE) system. Required disclosures include income and travel reimbursement from foreign academic institutions.
- Principal Investigators must disclose any gift for research as well as any research contract or grant from a for-profit, non-profit or a Material Transfer Agreement. They must also disclose financial interests in the entity providing the support in accordance with UCLA Procedure 925.1 and UCLA Procedure 925.2.
- Principal Investigators and others who share responsibility for designing, conducting and reporting research supported by all other federal agencies (except PHS) must disclose personal financial interests in accordance with UCLA Procedure 925.3.
- The State of California Form 700-U requires disclosure of financial interests in the sponsor of the research or donor, including foreign entities.
- You may not enter into informal or unofficial agreements to restrict publication or sharing of research results. University policy prohibits acceptance of publication restrictions in research, except in the case of unusual exceptions which can only be negotiated by University officials who have delegated authority to accept contracts and grants.
- You must comply with U.S. export control regulations when doing any of the following: traveling internationally and attending conferences; participating in international collaborations; using proprietary information; working with international staff and students; hosting international visitors; shipping materials internationally; or engaging in any international transactions.
- All academic appointees, staff, and trainees should follow the guidelines for travel to high-risk countries and register their travel with the University. Familiarity with current policies and IT advisories can help ensure we protect sensitive data. Please view the UCLA Traveling Abroad video, and Insurance & Risk Management’s Travel Insurance guidelines.
- All employees are expected to promptly disclose all intellectual property and any improvements to existing intellectual property to the UCLA Technology Development Group via the Invention Disclosure web portal. Faculty should remind members of their group to do the same.
- Faculty and staff must follow appropriate procedures when inviting visitors to laboratories and offices that house sensitive and proprietary data and equipment so as to ensure our data and systems are properly used and protected. Please review the Visiting Graduate Researchers web page and Appendix 39: Visiting Scholars.
UCLA remains committed to the freedom of inquiry and innovation and we will continue to vigorously support such efforts. It is critical, however, that every member of the UCLA community make every effort to understand the policies that govern their work and be certain that all necessary steps are taken to comply.
I realize that these requirements are complex. For that reason, there are multiple individuals and offices who can assist you in understanding and complying with these obligations. Staff of the Office of the Vice Chancellor for Research, the Office of Research Administration, the Office of Contract and Grant Administration, External Affairs, and the Office of Legal Affairs are familiar with these issues and policies and can assist you.
If you have any questions about these issues, please contact Roger Wakimoto, Vice Chancellor for Research (firstname.lastname@example.org). Your help and cooperation will support our mission to continue conducting important research that betters our community and the world.
Scott L. Waugh
Executive Vice Chancellor and Provost