This document presents a case study involving a major public university that faced scrutiny after receiving letters from the NIH regarding undisclosed foreign funding and faculty commitments. The case centers on a professor with significant NIH and NSF funding who engaged in a longstanding, unpaid research collaboration with a foreign institution (UU) and subsequently received an unsolicited honorary appointment there, which unexpectedly included a paid, full-time employment contract and intellectual property (IP) stipulations. Upon the university’s revision of its conflict of interest (COI) disclosure processes to capture both paid and unpaid external appointments, the professor realized the undisclosed appointment and self-reported it. This prompted internal investigations, media attention, and inquiries from policymakers, raising concerns about institutional oversight and the handling of foreign engagements.
In response, the university updated its COI policies to clarify reporting requirements for outside interests, including unpaid appointments, thresholds for reporting, and the valuation of non-financial research support. The document emphasizes the importance of transparent communications with funding agencies, timely self-disclosure, and navigating IP and foreign component issues, such as delineating between collaboration and significant foreign involvement. At the state level, legislative action followed, mandating broader disclosure and investigation mechanisms for university employees. The case highlights the need for robust, cross-institutional responses to complex global engagement risks, proactive relationships with regulatory bodies, and a culture of trust but verification. Supporting resources are provided for further best practices on research security and compliance.
