The document presents a detailed analysis of evolving institutional research disclosure practices amid heightened concerns over foreign influence on U.S. research. Drawing on survey data from Council on Governmental Relations (COGR) member institutions, the presentation highlights key themes including the multiplicity of disclosure pathways and institutional units involved, the growing emphasis on verification and monitoring, the establishment of training programs (albeit with room for improvement), and the introduction of additional scrutiny—particularly for foreign-linked activities and talent programs. The data reveal widespread adoption of policies related to conflict of interest, current and pending support, and external activities, with notable developments in processes that enable cross-checking of disclosures and monitoring compliance. Institutions are also increasingly asking specific questions about participation in foreign talent programs, though practices vary.
Further, the discussion underscores the risks associated with non-compliance—citing federal enforcement actions, legal liabilities, and high-profile cases of inadequate disclosure—while illuminating the operational challenges posed by complex international collaborations, visiting scholars, and evolving government guidance. Both the University of Louisville and MD Anderson Cancer Center detail their respective approaches to enhancing disclosure, supporting compliance, and addressing issues ranging from data security to international agreements. The document concludes by raising unresolved questions about the scope of fundamental research exemptions, the definition of research misconduct concerning undisclosed support, and the challenges in demarcating legitimate collaboration from undue foreign influence, calling for ongoing adaptation and vigilance in institutional practices.
