National Institutes of Health | Research Security Program

National Institutes of Health (NIH)

Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel

Includes policy and guidance on the following:

Disclosure in Current and Pending Other Support - NIH uses this information to ensure that there is no scientific, budgetary, or commitment overlap. NIH provides examples of overlap.
International Collaborations and Foreign Components - NIH encourages international collaborations on NIH funded projects but reminds investigators that foreign components, that is international collaborations or other activities that involve substantive work on the NIH project occurring outside of the United States, must undergo prior approval (see NOT-OD-19-114 for additional information on Foreign Components)
Allowable Activities - May NOT participate in Malign Foreign Talent Rectruitment Programs (MFTRP). Generally stated, other than MFTRPs, investigators and key personnel may engage in foreign collaborations and activities that are unrelated to NIH-funded work and that do not present concerns about possible scientific, budget, or commitment overlap; financial conflict of interest; or undisclosed foreign components. NIH has posted examples of problematic activities reflecting inappropriate foreign interference.

Chart which depicts NIH Decision Matrix for Assessing Potential Foreign Intereference (page 4 of the policy memo above)

Risk Measures Include

Participation in a Malign Foreign Talent Recruitment Program (now or within previous 5 years)
Undisclosed or incompletely disclosed funding from a foreign entity (differing levels of mitigation requirements depending on whether the foreign entity is from and/or connected to Foreign Country of Concern - China, Iran, Russia, and North Korea - or other foreign country)
Undisclosed or incompletely disclosed affiliations with a foreign institution (differing levels of mitigation requirements depending on whether the foreign institution is from and/or connected to Foreign Country of Concern - China, Iran, Russia, and North Korea - or other foreign country)