The U.S. federal government is concerned that foreign affiliations – particularly those that are associated with government-supported foreign talent programs – are being used by foreign governments to acquire, legally and illegally, U.S. government-funded scientific research in order to dominate high technology sectors currently led by U.S. entities.

Even if you are not actively collaborating with a foreign entity, any participation in a talent program (i.e., an active contract) must be disclosed within applications to federal sponsors as Other Support. Faculty with past participation in a Foreign Talent program should proactively reach out OSP to determine if there are any disclosure requirements for federally funded research.

1.  Prior Approval & COI Disclosure for Outside Activities

Faculty are reminded that, per the University on Faculty Consulting and Outside Activities policy, they are required obtain prior approval from their Department Chair for all Outside Activities (i.e., non-academic activities in their area of professional expertise, whether paid or unpaid). This includes, but is not limited to, participation in talent plans, foreign teaching appointments or any contractual relationship with a foreign entity. Any Outside Activity involving a Significant Financial Interests (i.e., exceeding $5000 in income/travel support) must also be reported in the Conflicts Disclosure System. Note that disclosures of foreign-source financial interests below the Significant Financial Interest threshold may not trigger in depth review, but given current scrutiny faculty are encouraged to disclose all foreign financial interests. When in doubt – DISCLOSE.

2. Participation in foreign government-sponsored talent programs

Researchers are reminded that participation in a foreign government sponsored talent program may jeopardize your ability to receive future federal funding for research or your ability to collaborate with U.S. government agencies. Any current participation by faculty members must be disclosed via the Conflict of Interest System, and any prospective participation must be approved by the Provost prior to engaging in such activity.

Please note that federal agencies do not have a unified definition of what constitutes a foreign talent program. As such, you are encouraged to contact the Director of International Support Services (Teresa Zash), to discuss offers for research which will be awarded to you as an individual (not through UMass Chan) which may require frequent travel to or extended stays in the foreign country from which the offer of research support originated since these are possible indicators that the activity could constitute a government-supported foreign talent program.