The following message is being sent on behalf of Vice President for Research Gregory F. Ball.
- Interim Policy: University of Maryland Policy on Malign Foreign Talent Recruitment Programs (MFTRP)
- New Kuali Research Proposal Certification Requirements
- Launch of Integrated Disclosure System “InTERP”
Dear Colleagues:
I hope this finds you well. I am writing to announce some important updates to University policies and processes related to the disclosure of outside activities and also to provide additional background context to help our faculty and staff understand the impetus for these changes.
As a leading research institution and a trusted steward of federal research funding, we have an important obligation to ensure that our research is conducted with maximum objectivity. Therefore, all individuals involved in the conduct, reporting, and administration of research must be transparent regarding all of their external research activities, consulting, relevant equity holdings, and other external affiliations.
Research transparency requirements often originate in federal laws that are then implemented in funding agency policies and requirements for research institutions and individuals. The general objectives of transparency rules can be summarized as follows:
- Promoting objectivity in the conduct and reporting of research;
- Protecting U.S. technology from misappropriation; and
- Protecting taxpayer funding from misuse.
As many of you are aware, the federal government has become increasingly concerned that certain foreign governments have been exploiting the open U.S. research enterprise in ways that conflict with the objectives of transparency described above. In an effort to protect the research enterprise, the Executive branch and Congress have mandated that federal research funding agencies update and enforce transparency requirements. National Security Presidential Memorandum - 33 (NSPM-33), first released in January 2021, and expanded by the National Science and Technology Council in January 2022, is both a mandate and a framework for federal agencies to strengthen policies designed to protect the research enterprise. As a result of NSPM-33 and other federal laws, including the Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act of 2022 (Public Law 117-167), and National Defense Authorization Acts, research funding agencies have and continue to update policies and requirements related to transparency and disclosure of all sources of funding and outside professional activities (i.e., current and pending (other) support, gifts, consulting biosketch, etc.). The University’s Research Security Office has consolidated informational resources on its website to help University employees understand and navigate the complex and changing requirements.
Over the last few years, the Division of Research has invested in expanding our research support infrastructure to help our faculty and staff navigate various federal requirements. We have also implemented a series of policy and process changes to ensure the University’s alignment with these requirements. Our goal with all of these changes is to minimize the burden whenever possible; however, the research security and compliance landscape has been evolving rapidly since NSPM-33 was released, making it challenging to create a single policy or process that is responsive to all of the new requirements. Therefore, we will be revising additional University policies in the coming months to ensure alignment with these requirements. We ask for your cooperation and patience as we roll out these important changes. We will continue to refine and streamline our processes based on your constructive feedback.
Within this context, I will briefly describe recent changes below and provide links and contacts that offer additional information.
- New Policy: IV-7.00(A): Interim University of Maryland Policy on Malign Foreign Talent Recruitment Programs (MFTRP) Effective August (Approved on an interim basis by the President, August 9, 2024): https://policies.umd.edu/research/university-of-maryland-policy-on-malign-foreign-talent-recruitment-programs
This policy, originating from Public Law 117-167 (the CHIPS & Science Act), prohibits University Employees from participation in “Malign Foreign Talent Recruitment Programs” (“MFTRPs”). Our Research Security Office has provided a more comprehensive description of the background and legal basis for this policy here: research.umd.edu/rso/advisories-and-resources/foreign-talent.
We do not anticipate that this Policy will have any additional impact or administrative burden on University employees because such activities were already subject to our conflict of interest (COI) and proposal disclosure processes, and involvement in an MFTRP would be deemed an unmanageable COI. We strongly encourage University employees to seek guidance from our Research Security Office (researchsecurity@umd.edu) if they are unsure whether a contract or consulting agreement with a foreign party may constitute a restricted MFTRP, as such involvement could disqualify them from U.S.-funded research activities.
- Updated Kuali Research Proposal Certification Requirements (Effective 5/10/2024)
In May we announced a change to the Kuali Research proposal process to comply with new proposal requirements mandated in the CHIPS Act and implemented by the National Science Foundation (NSF) and other federal agencies. Institutions are now required to certify with every proposal that all Senior/Key Personnel have certified that they are not involved in a MFTRP. To implement this requirement, we added a new certification statement to the Investigator Certification Questionnaire in Kuali Research (KR) and now require that all UMD PI(s) and Senior/Key Personnel sign the certification statement before the proposal can be routed. Our May 3rd announcement includes more details on this change.
- New Integrated Disclosure System (inTERP) for Tracking Conflicts of Interest and Commitment
On July 24, 2024, I announced the pending launch of inTERP (inTegrated External Relationship Portal). This new system consolidates the Conflict of Interest, Conflict of Commitment, Outside Professional Activity, and Consulting MOU reporting requirements. Unlike the University’s previous OPA system, which had an annual reporting requirement, disclosures of all Outside Professional Activities, including Consulting, will now be made in the inTERP system on a rolling basis, before a commitment is made. This will allow our COI Office and Research Security Office to help researchers identify activities, such as MFTRPs, that could conflict with their U.S.-funded research obligations before a commitment is made. The University will rely on an up-to-date inTERP disclosure (or null disclosure), and certifications in KR to make the required institutional certifications on federal contract and grant applications. After the inTerp system is launched and we have worked through the first round of disclosures, we will require all individuals identified as PI(s) and Senior/Key Personnel, who submit proposals to ensure that their COI disclosure has been updated within the last 12 months before they can certify new proposals. We will provide updates and additional guidance on the launch of this new system in the coming weeks but in the meantime, you can reach out to the COI Office (inTERP@umd.edu) if you have questions about disclosures.
Sincerely,
Gregory F. Ball
Vice President for Research