Research Grant Disclosures & Foreign Influence
In the wake of requests for information from the White House Office of Science and Technology Policy (OSTP), updated guidance from various agencies, and recent Senate Testimony, there is a clear message that issues related to foreign influence are some of the highest-profile research grant priorities for this administration.
For example, the OSTP's Joint Committee on Research Environments (JCORE) recently published a Request for Information (RFI) outlining the Committee's priorities and seeking input on ways to maximize the quality and effectiveness of the American research environment. The RFI foreshadows potential changes to both pre- and post-award requirements and suggests a focus on four key areas of compliance, including concerns around foreign influence in research.
In addition, in July 2019, the National Institutes of Health (NIH) issued guidance related to the disclosure of “other support,” “foreign components,” and “financial conflicts of interest” for NIH grantees. While framed by NIH as reminders or clarifications of existing policy, the new guidance reflects an increasing focus on the disclosure of foreign activities when applying for and receiving NIH grants and arguably expands grantee obligations to collect and disclose more information from their researchers about potential foreign involvement or influence in NIH-funded research. Failure to properly disclose may result in significant consequences, including: award conditions, disallowing costs, terminating current awards or withholding future awards, or even an investigation by the Department of Justice under the False Claims Act.
On this webinar, we will discuss current best practices based on the latest cases and guidance from the government to help you identify and mitigate the highest risk areas, including:
- Financial conflicts of interest
- Sources of other support
- Protection against foreign exploitation of US research
- Research Grant Administrators
- Business Officers
- Compliance Officers
- Sponsored Research Leadership
After this webinar, you will be better able to:
- Evaluate the latest approaches to policies and procedures related to research grant disclosure;
- Implement compliance operations in the highest risk areas; and
- Discuss the potential statutory and/or regulatory changes in 2020.
Serving as Senior Counsel in the firm’s Federal Grants, Health Law, and Litigation & Government Investigations practice groups, Kristen represents universities, non-profit and for-profit organizations facing legal actions under Federal health care and grant regulations in addition to the False Claims Act and Civil Monetary Penalties Laws. Prior to joining the firm, Ms. Schwendinger served for nearly eight years as an attorney and senior counsel in the U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG). [Full Bio]
As of May 2020, Derek is no longer with the firm.
Derek Adams is a former Trial Attorney with the Department of Justice and a partner in the firm’s Litigation and Government Investigations Practice group. Mr. Adams serves as practice lead of the firm’s False Claims Act defense practice, representing universities, health care organizations, and others facing False Claims Act investigations and litigation.
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