To protect U.S. investments in scientific research from undue foreign influence, federal agencies should have conflict of interest policies and require researchers to disclose foreign interests.
Two of the 5 agencies we reviewed do not have agency-wide financial conflict of interest policies, and none of the 5 have non-financial policies (e.g., for researchers with multiple professional appointments). But all require researchers to disclose some non-financial interests in grant proposals—like foreign-provided lab space.
We recommended that agencies develop agency-wide conflict of interest policies to help them assess risks of foreign influence.
What GAO Found
U.S. research may be subject to undue foreign influence in cases where a researcher has a foreign conflict of interest (COI). Federal grant-making agencies can address this threat by implementing COI policies and requiring the disclosure of information that may indicate potential conflicts. GAO reviewed five agencies—which together accounted for almost 90 percent of all federal research and development expenditures at universities in fiscal year 2018—and found that three have agency-wide COI policies, while two do not (see figure). The three agencies with existing policies focus on financial interests but do not specifically address or define non-financial interests, such as multiple professional appointments. In the absence of agency-wide COI policies and definitions on non-financial interests, researchers may not fully understand what they need to report on their grant proposals, leaving agencies with incomplete information to assess the risk of foreign influence. GAO found that, regardless of whether an agency has a conflict of interest policy, all five agencies require researchers to disclose information—such as foreign support for their research—as part of the grant proposal that could be used to determine if certain conflicts exist.
Elements of Conflict of Interest (COI) Policies at Agencies with the Most Federal Research Expenditures at Universities
Based on a review of university documents, GAO found that all 11 of the universities in its sample have publicly available financial and non-financial COI policies for federally funded research. These policies often align with the financial COI policies or requirements of the grant-making agencies.
All five agencies have mechanisms to monitor and enforce their policies and disclosure requirements when there is an alleged failure to disclose required information. All agencies rely on universities to monitor financial COI, and most agencies collect non-financial information such as foreign collaborations, that can help determine if conflicts exist. Agencies have also taken actions in cases where they identified researchers who failed to disclose financial or non-financial information. However, three agencies lack written procedures for handling allegations of failure to disclose required information. Written procedures for addressing alleged failure to disclose required information help agencies manage these allegations and consistently apply enforcement actions.
In interviews, stakeholders identified opportunities to improve responses to foreign threats to research, such as harmonizing grant application requirements. Agencies have begun to address such issues.
Why GAO Did This Study
The federal government reportedly expended about $42 billion on science and engineering research at universities in fiscal year 2018. Safeguarding the U.S. research enterprise from threats of foreign influence is of critical importance. Recent reports by GAO and others have noted challenges faced by the research community to combat undue foreign influence, while maintaining an open research environment that fosters collaboration, transparency, and the free exchange of ideas.
GAO was asked to review federal agency and university COI policies and disclosure requirements. In this report, GAO examines (1) COI policies and disclosure requirements at selected agencies and universities that address potential foreign threats, (2) mechanisms to monitor and enforce policies and requirements, and (3) the views of selected stakeholders on how to better address foreign threats to federally funded research. GAO reviewed laws, regulations, federal guidance, and agency and university COI policies and requirements. GAO also interviewed agency officials, university officials, and researchers.
GAO is making nine recommendations to six agencies, including that grant-making agencies address non-financial conflicts of interest in their COI policies and develop written procedures for addressing cases of failure to disclose required information. Five agencies agreed with GAO's recommendations. The National Science Foundation neither agreed nor disagreed with GAO's recommendation, but identified actions it plans to take in response.
Recommendations for Executive Action
|Office of Science and Technology Policy||1. The Director of the Office of Science and Technology Policy should work with the Executive Office of the President to issue the guidance that is pending review and expedite the issuance of any additional forthcoming guidance on addressing foreign threats to federally funded research. (Recommendation 1)|
|Department of Defense||2. The Secretary of Defense should develop an agency-wide policy on conflict of interest for grants, to address both financial and non-financial conflicts. (Recommendation 2)|
|Department of Defense||3. The Secretary of Defense should document procedures, including roles and responsibilities for addressing and enforcing failures to disclose required information, both foreign and domestic.(Recommendation 3)|
|Department of Energy||4. The Secretary of Energy should develop an agency-wide policy on conflict of interest for grants, to address both financial and non-financial conflicts. (Recommendation 4)|
|Department of Energy||5. The Secretary of Energy should document procedures, including roles and responsibilities for addressing and enforcing failures to disclose required information, both foreign and domestic. (Recommendation 5)|
|Department of Health and Human Services||6. The Secretary of Health and Human Services should instruct the Director of the National Institutes of Health to update the agency's conflict of interest policy to include a definition on non-financial conflicts, such as the one developed by OSTP, and address these conflicts, both foreign and domestic. (Recommendation 6)|
|National Aeronautics and Space Administration||7. The Administrator of the National Aeronautics and Space Administration should update the agency's conflict of interest policy to include a definition on non-financial conflicts, such as the one developed by OSTP, and address these conflicts, both foreign and domestic. (Recommendation 7)|
|National Aeronautics and Space Administration||8. The Administrator of the National Aeronautics and Space Administration should document procedures, including roles and responsibilities for addressing and enforcing failures to disclose required information, both foreign and domestic. (Recommendation 8)|
|National Science Foundation||9. The Director of the National Science Foundation should include a definition on non-financial conflicts in their agency policies, such as the one developed by OSTP, and address these conflicts, both foreign and domestic. (Recommendation 9)|