RESPONSIBLE CONDUCT IN RESEARCH

The Office of Research Integrity Assurance (ORIA) is a unit of University Research Services & Administration (URSA) under the Office of the Vice President for Research & Economic development. The foundation of scientific and research endeavors is the integrity of the process. Georgia State's ORIA supports faculty, students and staff in meeting the highest levels of research integrity in proposing, conducting, and reporting research. We address all issues related to the Responsible Conduct of Research including conflicts of interest and commitment, and assist with export control regulations.

Conflicts of Interest

Overview

Georgia State University is fully committed to maintaining objectivity in research and upholding the highest scientific and ethical standards. The Policy on Financial Disclosures in Sponsored Research promotes objectivity in University research by establishing processes that provide a reasonable expectation that the design, conduct, and reporting of sponsored research are free from bias resulting from financial conflicts of interest of the University employee involved in the research. The Policy complies with the Public Health Service's revised regulations on the “Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought” (see PHS FAQs).

Disclosure of Significant Relations and Financial Interests

The Policy on Financial Disclosures in Sponsored Research promotes objectivity in University research by establishing processes that provide a reasonable expectation that the design, conduct, and reporting of sponsored research are free from bias resulting from financial conflicts of interest of the University employee involved in the research.

Prior to proposal submission, all investigators must demonstrate compliance with Georgia State’s commitment to ensuring objectivity in research by:

Completing the CITI training module within the last four years
Completing a Significant Financial Interest Disclosure form identifying the specific project for which the proposal will be submitted. Each investigator/key personnel identified on the project must complete and submit this form separately.

NOTE: An investigator is any individual, regardless of title or position, who is capable of influencing the outcome or results of the sponsored project.

Disclosure of Significant Financial Interest Form

Disclosure of Significant Financial Interest Form Guidance

Investigator means any individual, regardless of title or position, who is responsible for the design, conduct, performance or reporting of a Sponsored Project. An Investigator may include full-time and part-time faculty; staff; students; consultants; collaborators; and evaluators. For clarification, “responsible for” means that the individual is capable of influencing the outcome or results of the Sponsored Project.

Significant financial interest means a Financial Interest consisting of one or more of the following interests of the Investigator and those of the Investigator’s Immediate Family that reasonably appears to be related to the Investigator’s University Responsibilities:

With regard to any publicly traded entity, any Remuneration received from such entity in the twelve (12) months preceding the disclosure and the value of any Equity Interest in such entity as of the date of disclosure that, when aggregated, exceeds $5,000;
With regard to any non-publicly traded entity:
1. any Remuneration received from such entity in the twelve (12) months preceding the disclosure that, when aggregated, exceeds $5,000, or
2. any Equity Interest regardless of value;
intellectual property rights (e.g., patents, copyrights), where income related to such rights and interests has been received;
reimbursed or sponsored travel, excluding travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a institution of higher education.

Significant Financial Interest does not include the following types of Financial Interests: (1) salary, royalties, or other Remuneration paid by the University to the Investigator if the Investigator is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the Georgia State University Research Foundation and agreements to share in royalties related to such rights; (2) income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; (3) income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, or an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or (4) income from service on advisory committees or review panels for a federal, state, or local government agency, or an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Equity interest means any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.

Financial interest means anything of monetary value, whether or not the value is readily ascertainable.

Immediate family means an Investigator’s spouse and dependents.

Remuneration means any payment for services including, but not limited to, salary, consulting fees, honoraria, and paid authorship.

University responsibilities means an Investigator’s professional responsibilities on behalf of the University including, but not limited to, activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels.

In accordance with the Georgia State University Policy on Individual Conflict of Commitment and Conflict of Interest, University Employees must obtain written approval from their supervisor to engage in Outside Activities. Use the University Outside Activity Disclosure Form to provide written notification of the proposed activity to your supervisor and upload the approved form to SFI.GSU.EDU when disclosing the relationship on a proposal.

Additional resources regarding compliance with the Disclosure of Significant Financial Interest can be found in the documents below.

- Georgia State University Policy on Conflicts in Research and Sponsored Projects

Research Integrity & Foreign Interference

Georgia State University is committed to openness in research, freedom of expression, the free exchange of scholarly ideas and fundamental research and appropriate international collaboration. We support and welcome international students, faculty members and collaborators who make invaluable contributions to our university and enrich the academic environment.

At the same time, we must work to ensure national security and economic prosperity. Without proper safeguards, foreign actors can exploit the open nature of the university environment, and it is our responsibility to secure the scientific integrity of the research we conduct on behalf of taxpayers.

Georgia State policies are thoughtfully implemented to balance our institution's values and interests and to comply with all federal requirements. These policies are also designed to protect Georgia State faculty and staff from unwittingly violating applicable laws and regulations.

Understanding Foreign Interference

Federal agencies that sponsor research, federal intelligence agencies, federal security agencies and members of Congress have expressed concern about foreign interference at U.S. research universities. Of particular concern are the diversion of intellectual property developed using federal funds to foreign governments or corporations, the sharing of confidential information on grant applications or otherwise influencing funding decisions and the failure by grant funded researchers to disclose foreign support, faculty positions or laboratories. Federal agencies that support research, including the National Institutes of Health (NIH) and the National Science Foundation (NSF), are strengthening their attention to disclosure and urging universities to do the same.

Understanding NSPM-33: A Federal Security Mandate

NSPM-33 is a mandate to recipients of more than $50 million per year in total federal research funding to have a strong research security program across these four elements:

Cybersecurity
Foreign travel security
Research security training
Export control training

GSU is evaluating its research security programs across these areas. For our current compliance operations, our assessment methodology will compare current GSU practices against federal guidelines to: 1) document current state, 2) determine whether our current operations meet federal guidelines, 3) identify areas for improvement and 4) provide risk-based recommendations for improvement to university leadership

Generally, we have identified project areas:

Disclosure Requirements and Standardization – Disclosure requirements are being standardized across government agencies. GSU will evaluate guidance requirements as they evolve.
Digital Persistent Identifiers –Sponsors will require researchers to use a digital identifier (e.g. ORCID iD) that distinguishes them from other researchers and provides a record that supports automatic links among all their professional activities.
Consequences for Violation of Disclosure Requirements – As agencies provide guidance, we will review and update GSU policies to meet federal policies and enforce consequences for non-compliance.
Research Security Programs –Design processes and training for the GSU’s federally funded researchers. This includes the following areas: hosting foreign visitors, foreign travel security, research security, export control, insider threat awareness, cybersecurity, etc.
Communications – Project updates and important changes will be regularly communicated to the GSU research community.

As we evaluate GSU’s programs, research administrators, associate deans for research and federally-funded investigators may be asked to participate in interviews about current practices in these areas as we work to improve our processes in anticipation of the final guidance from sponsors.

As we continue to strengthen existing international collaborations and pursue new opportunities that benefit our faculty, students and research objectives, we ask that the university research community remain mindful of the requirements detailed below.

Transparency in Disclosure of Other Support, Foreign Components, Financial Conflicts of Interest and Outside Commitments

Due to continued concerns of the United States government related to the potential for undue foreign influence overall federally funded research, it is important to remind the GSU research community of its disclosure obligations.

Whether foreign or domestic, all outside financial interests, compensated or uncompensated professional activities, relationships and affiliations related to research must be disclosed in the SFI System; and all outside compensated activities that relate to a faculty member’s GSU responsibilities must be disclosed to and approved by the faculty member’s Chair or Dean as detailed in the University’s Conflict of Interest and Conflict of Commitment Policy.
The Request for Approval form
Appropriate disclosure allows the University and government funding agencies to properly identify, assess and manage potential conflict or overlap issues related to research.
For GSU Researchers, guidance on what, where and when to disclose foreign components and other support to federal sponsors can be found in the tables in the document How to Disclose Foreign Affiliations in Research.

Additional information about specific areas of disclosure:

Other Support

Be thorough and complete in accounting for all forms of research support, including from foreign sources and gifts, in the NIH's Other Support, the NSF's Current and Pending and similar documentation submitted to other sponsors. Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at Georgia State. This includes resource and/or financial support from foreign and domestic entities, including but not limited to, financial support for laboratory personnel and provision of high-value materials that are not freely available (for example, biologics, chemical, model systems, technology, etc.). Projects or activities requiring a portion of the time of the principal investigator and any other senior personnel must be included, even if they receive no salary support from the project(s). The NIH has specific requirements regarding reporting Other Support. More can be found in our guidance document. Contact the Office of Sponsored Programs at Office of Sponsored Programs with questions about Other Support.

Foreign Components

The NIH requires NOT-OD-19-114 recipients to determine whether activities it supports include a foreign component such as (a) performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or (b) performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended. If a portion of the activities will be conducted outside the U.S., the recipient will need to determine if the activities are considered significant. If both criteria are met, there is a foreign component that must be disclosed. Contact the Office of Sponsored Proposals & Awards at Office of Sponsored Programs with questions about Foreign Components.

Outside Commitments

Faculty must discuss any invitation for any academic appointment or position at another domestic or international institution (visiting, honorary or other), whether paid or unpaid, with their Dean's Office prior to accepting an appointment. Faculty must also disclose to their Dean's Office involvement in any foreign recruitment or "talent" programs. These programs are of particular interest to the federal government, because they are seen as presenting a uniquely high risk of undermining U.S. economic and security interests. The dean may refer faculty to the Office of Legal Affairs for further assistance.
Faculty should also follow the disclosure requirements set forth in the University Policy on Individual Conflict of Commitment and Conflict of Interest.

Financial Conflicts of Interest

The NIH recently reminded the research community of the importance of disclosing foreign financial interests. University investigators must complete the Disclosure of Significant Financial Interest Form annually during September. Investigators must disclose financial interests received from a foreign institution of higher education or the government of another country (which includes local, provincial or equivalent governments of another country). See the University Policy on Disclosure of Financial and Other Interests in Research and Sponsored Projects or contact the Associate Vice President for Research for more guidance on what to disclose.

Export Controls

Regulations around export controls are complex and constantly evolving, and there are several issues to be considered before engaging in international activities. When collaborating with international partners, making financial transactions, shipping materials, transferring technology, traveling abroad or using restricted materials for research, you are responsible for complying with export control regulations. Visit the export controls webpage or contact the Office of Legal Affairs or 404-413-0500) if you are unclear on how export controls apply to you. A university researcher involved in research that includes a foreign component should complete the Export Controls CITI Training.

Security of Materials, Data and Confidential Information

When materials or data will be shared with other institutions, foreign or domestic, it is in most cases required to have an agreement, such as a material transfer agreement (MTA), data use agreement (DUA) or nondisclosure agreement (NDA). governing the use of those materials or data. Having an agreement allows the university to complete required internal controls and checks. Contact the Office of Legal Affairs for assistance with these agreements. All agreements must be reviewed and signed by institutional officials with appropriate signature authority. Accepting sensitive or controlled information may require heightened cybersecurity requirements. Always consult with the Office of Legal Affairs to confirm these requirements are properly managed.

Intellectual Property

To ensure intellectual property is protected and, when required, appropriately reported to sponsors, promptly disclose any potential inventions or other intellectual property to the Panther Innovations (PI). If you are involved in a startup based on licensed technology from Georgia State, the company should disclose investments, partnerships or sub-licenses made with foreign entities.

Visiting Researchers

Visiting researchers are an asset to the university's research program. In the coming year, the Office of the Vice President for Research & Economic Development and the Office of Legal Affairs will issue policies and procedures to ensure foreign visitors are properly vetted, and that their access to university space and systems is appropriate for the proposed work. In the meantime, work with your Dean's Office prior to inviting a visiting researcher to campus.

Peer Review

Information gained through peer review processes - whether reviewing grant applications or publications - is confidential and should never be shared. NIH reminds the research community to adhere to the confidentiality of these processes.

Foreign Travel

Agencies and other entities that fund your work may require advance approval and/or disclosure of foreign travel or domestic travel sponsored by foreign entities. Check the requirements associated with your specific funding sources. When traveling to high-risk countries, make use of clean loaner devices to protect information. If you have questions about foreign travel, contact the Office of International Initiatives or email [email protected].

Policies & Procedures

Quick Summary of Investigator Responsibilities

Why is Georgia State University implementing a revised policy on financial disclosures in sponsored projects?

In August 2011, the Office of the Secretary of the U.S. Department of Health and Human Services and the Public Health Service (PHS) issued revised regulations on the “Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought.” These regulations establish new standards that must be followed by all institutions, including Georgia State, that apply for or receive research support from PHS agencies, including the National Institutes of Health (NIH).

The revised regulations are intended to increase accountability, add transparency to the disclosure of significant financial interests, enhance regulatory compliance and management of financial conflicts of interest, and strengthen governmental compliance oversight. Georgia State implemented its revised policy on Aug. 24, 2012 to be in full compliance with all of the regulatory requirements.

Who is considered an “Investigator”?

An Investigator is any individual, regardless of title or position, who is responsible for the design, conduct, performance or reporting of a Sponsored Project at Georgia State. An Investigator may include full-time and part-time faculty, staff, students, consultants, collaborators and evaluators. For clarification, “responsible for” means that the individual is capable of influencing the outcome or results of the sponsored project.

What must an investigator do to comply with the Georgia State policy?

All investigators must complete training on financial conflicts of interest in research via the CITI module. The training is required by the Georgia State Policy prior to the expenditure of any research and must be repeated at least every four years.

To access the training, all Investigators should go to CITI and log in or, if a new CITI user, follow the “Register Here” link. Click “Add a course or update your learner groups.” Answer, “Yes” to the question: “Would you like to take the Conflict of Interest course?” Click “Continue” then “Conflict of Interest” will appear under “My Courses.” Be sure to complete all four modules.

At the time of training, and thereafter annually, all Investigators must complete a Georgia State Financial Disclosure Form. Investigators must submit the Disclosure Forms. For each proposal submission to the Office of Sponsored Programs (OSP), Investigators must complete a Financial Disclosure Form. Proposals for funding will not be submitted until all Investigators on the proposal have submitted a Financial Disclosure Form.

Georgia State Policy requires all proposals for funding be submitted to OSP five (5) business days prior to the submission deadline. This lead time will be essential to meet the requirements of the new policy. Please plan submissions according to this deadline.

Who can I contact with questions?

Please contact the University Research Services Administration at 3-3500 or the Office of Legal Affairs at 3-0500.

Frequently Asked Questions

Will OSPA submit a proposal if the disclosure of significant financial interest form has not been completed?

A proposal for funding from a PHS agency will not be submitted until each investigator has completed a disclosure. The individual departments and colleges/deans should ensure the disclosures are completed before the proposal reaches OSPA.

If no information has changed from an Investigator’s last submitted disclosure form, does the Investigator have to complete a new disclosure form to submit a proposal? If so, what proposal information do they need to include?

The disclosure must be re-submitted with each new proposal and must be updated with the new proposal-specific information.

What if information in my disclosure changes and requires updating?

Those changes must be done by the investigator directly and should be made within 30 days of the change.

What happens if an Investigator fails to submit an updated disclosure form within 30 days of a change (i.e. acquiring a new significant financial interest, discovering a previously undisclosed significant financial interest)?

Changes should be reported as soon as discovered (within 30 days if possible). If changes are not reported within 30 days, Georgia State may be required to conduct a retrospective review depending on the funding agency (e.g. PHS agencies). If the review determines the research was biased by the failure to timely disclose, Georgia State may be required to notify the funding agency and provide a mitigation report. Additional action may be taken by the University and the funding agency.

How is the PI held accountable for failure to report changes to their disclosure within 30 days?

Possible sanctions for violation of the Policy by an investigator include administrative intervention, withholding funding or preclusion from participation in government funded programs, or termination of employment.

Do resubmissions or noncompeting continuations require disclosures?

Yes, this Policy applies to each grant or cooperative agreement.

What Sponsored Travel must be reported?

All investigators must report the occurrence of any reimbursed or sponsored travel paid on behalf of the investigator that is related to their institutional responsibilities, regardless of the value. The monetary value does not need to be reported, however the purpose of the trip, sponsor, destination and duration of the trip must be disclosed. This may be disclosed prospectively for the year. For example: “Purpose: Board of Trustees meeting—Sponsor: American Heart Association—Destination: Texas—Duration: 4 trips in 2012 for 2 days each.” Travel sponsored or reimbursed by institutions of higher education, academic medical centers and research institutions affiliated with academic institutions does not need to be disclosed. Travel reimbursed or sponsored by other non-profit organizations must be reported.

Does sponsored travel funded through foreign governments have to be reported?

Yes. If foreign governments are providing the funding for the travel it needs to be disclosed. U.S. government funded travel, including funding from state and local governments does not have to be disclosed. Also, travel funded by institutions of higher education, academic medical centers and research institutions affiliated with academic institutions within the United States does not need to be disclosed.

Malign Foreign Talent Recruitment Programs (MFTRPs)

Participation in Malign Foreign Talent Recruitment Programs (MFTRP)

The CHIPS & Science Act of 2022 (P.L. 117-167, Subtitle D-Research Security, Sections 10631-10632):

Prohibits covered individuals involved in research from taking part in Malign Foreign Talent Recruitment Programs (MFTRP).
Applies to all covered individuals including lead researchers and key personnel participating in sponsored research at Georgia State University, whether Federally and non-Federally funded.
Covered individuals are required to disclose any participation in foreign talent recruitment programs, even if they’re not part of a prohibited MFTRP.
Failure to comply with this rule or providing false information can lead to serious legal consequences.

MFTRP Highlights:

These programs are backed by specific foreign governments (currently China, Iran, North Korea, or Russia) and involve activities that may pose a risk to U.S. research.
Not all foreign talent programs are restricted—only those deemed as malign.

If you’re unsure whether a specific program falls under this category, please reach out to the Office of Research Integrity Assurance for guidance ([email protected]).

Important Deadlines:

May 2024: NSF required certification from researchers that they are not involved in an MFTRP.
August 2024: The Department of Defense (DOD) implemented similar requirements.
January 2025: NIH will implement similar requirements.

DEFINITIONS AND DETAILS:

What is a covered individual?

A covered individual is someone who:

a) Contributes, in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from any sponsor (Federally and non-federally funded);
or

b) is designated as a Covered Individual by a Federal research funding agency.

Note: The definition of a Covered Individual is based on their contribution to the project as defined above and is not related to the title of the individual. At Georgia State University (GSU), a Covered Individual could be a faculty member, research scientist, researcher, visiting scientist, consultant, student (undergraduate or graduate), post-doctoral fellow, etc., regardless of whether they are paid or unpaid. Similarly, Congressional Legislation and Federal Agencies use different terms such as PI, Co-PI, Investigator, Project Director, Project Co-Director, “Key performer”, “Key personnel”, “Senior personnel”, “Named Researcher”, “Named Individuals”, “Sponsored Researcher”, etc.

What is a Malign Foreign Talent Recruitment Program?

Malign Foreign Talent Recruitment Program defined by The CHIPS Act:

If a program meets at least one criterion in Part A and B above, it is a Malign Foreign Talent Recruitment Program and covered individuals are prohibited from participating in it under federal law and University policy.

Part A.

Any program, position or activity compensated with cash or in-kind compensation such as complimentary foreign travel, honorific titles, career advancement opportunities, where the compensation is in exchange for one or more of the following:

Unauthorized transfer of intellectual property, materials, data products, or other nonpublic information developed through U.S. federal funding to a foreign government or entity affiliated with a foreign country;
Being required to recruit trainees or researchers to participate in the program or activity;
Establishing a lab or company or accepting a faculty position or other employment if these activities are in violation of standard terms and conditions of a federal award;
Being unable to terminate the contract except in extraordinary circumstances;
Requiring commitments that limit the capacity to carry out a U.S. federal award or would result in substantial overlap or duplication;
Being required to apply for or successfully receive funding from the sponsoring foreign government’s funding agencies, with the foreign organization as the recipient;
Being required to omit acknowledgment of the recipient institution (i.e., Columbia University), or the U.S. federal research agency sponsor, contrary to institutional policies or standard award terms and conditions;
Being required to withhold information about participation in the program and not to disclose it to the U.S. funding agency or to Columbia; OR
Having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the award.

and

Part B.

A foreign country of concern (“FCOC”) or an entity based in a FCOC, whether or not directly sponsored by the FCOC;

Foreign Country of Concern - the term “foreign country of concern” for the purpose of this Policy is as defined in Section 10638(2) of CHIPS and Science Act of 2022 and currently includes the countries indicated on the Particular Concern, Special Watch List Countries, Entities of Particular Concern per the U.S. Department of State. The most recent Countries of Particular Concern designations were made by the Secretary of State on December 29, 2023:

Burma, People’s Republic of China, Cuba, Eritrea, Iran, the Democratic People’s Republic of Korea, Nicaragua, Pakistan, Russia, Saudi Arabia, Tajikistan, and Turkmenistan.

An academic institution on the NDAA 2019 Section 1286(c)(8) List; or
A foreign talent recruitment program on the NDAA 2019 Section 1286(c)(9) List.

Some international activities are permitted under the CHIPS Act if they don’t involve foreign programs or institutions on certain government watch lists.

Examples include:

Presenting research at conferences.
Publishing scientific papers.
Advising foreign students.
Engaging in approved international research collaborations.

If you’re unsure whether a program is allowed, feel free to contact the Office of Research Integrity Assurance at [email protected] for clarification.

Who do I disclosure this information to?

Disclosure to Georgia State University

Individual Disclosure and Certification: All Covered Individuals, whether paid or not, are required to disclose their participation in Foreign Talent Recruitment Programs, including Malign Foreign Talent Requirement Programs, through Georgia State University’s significant financial interest and outside activities disclosure (SFI) reporting system and to await approval from the ORIA Office before participating in such a program. Covered Individuals must also certify annually that they are aware of and compliant with this requirement, even if they have nothing to disclose.

All Covered Individuals must disclose participation in any FTRP in the (SFI) system within 30 days of the participation and in the Biographical Sketch, Current and Pending (Other Support), and other proposal documents as required by the sponsor.

Covered Individuals not included in the proposal budget will be required to provide their disclosures during the SFI annual disclosure period.

Disclosure to Sponsor

All Covered Individuals must utilize the Science Experts Network Curriculum Vitae (SciENcv), which is currently mandated by the National Science Foundation (NSF) and recommended for use by other funding agencies, or the Biographical Sketch Common Form recommended by the Office of Science and Technology (OSTP), that both include the recommended certification (“I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program”)(see here for NIH)**.

Covered Individuals are strongly encouraged to use SciENcv for generating all their biographical sketches for all their proposals.

The Biographical Sketch Instructions are here for NIH and the Common Form Template is here for the other federal agencies.

Office of Sponsored Programs (OSP) must certify that Covered Individuals, whether employed by Georgia State University or not, are aware of and compliant with the requirement to disclose their participation in an FTRP and the prohibition on participating in a MFTRP at time of proposal.

What am I responsible for?

PIs/PDs and other Covered Individuals

Covered Individuals must disclose their participation in FTRPs and attest that they are not participants in MFTRPs. They must also attest to their awareness of and compliance with these requirements annually.

PIs/PDs must ensure that each Covered Individual, whether paid or not, certifies (see Implementation of Policy above) that they are not actively participating in a MFTRP at proposal submission and annually thereafter for the duration of the award in accordance with the Policy and Federal funding agency requirements.

Enforcement

Failure to comply with sponsor requirements may cause awards to be rescinded or terminated or result in restrictions on future contracting for Georgia State University.

Where can I find additional information?

Related Policies and Guidance

GSU Foreign Talent Recruitment Policy

Disclosures of Financial and Other Interests in Research and Sponsored Projects

Guidance on Research Integrity and Foreign Influence

NSPM-33 Definitions

CHIPS and Science Act of 2022

OSTP Guidance

National Security Presidential Memorandum (NSPM-33): Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs

Guidance for Implementing NSPM-33

National Institutes of Health (NIH) Foreign Interference Guidance

National Science Foundation (NSF) Proposal and Award Policies and Procedures Guide (PAPPG); Disclosure Requirements

GSU Research Protect Your Idea

Who do I contact with questions?

Feel free to contact the Office of Research Integrity Assurance at [email protected] with any questions.

Export Controls

The Office of Legal Affairs provides oversight, assistance, and training in complying with the federal export control regulations regarding access by foreign nationals to or the transfer abroad of information, materials, and technologies.

If you have questions about export controls, contact:

Kathy McGinn, MA
Research Associate - Export Control Officer
Office of Research Integrity Assurance
404-245-8051
[email protected]

What are Export Control Laws (ECLs)?

Export Control Laws broadly describe a comprehensive series of regulations enforced by the federal government concerning the transfer of certain controlled items to foreign nationals, foreign countries, and entities for reasons of national security and foreign policy. ECLs require certain items to be controlled most often because:

The nature or type of technology has potential military applications
The nature or type of technology raises some sort of trade/economic protection issue
There are concerns about the country, organization, individual or “end user” of the technology requiring control

What is considered an export?

The term export when used in the context of ECLs is much broader than the standard notion of a tangible item being shipped out of the United States. Under ECLs, an export includes:

Actual shipment of any covered goods or items
The electronic or digital transmission of any covered goods, items or related goods or items
Any release or disclosure, including verbal disclosures or visual inspections, of any technology, software or technical data to any foreign national
Actual use or application of covered technology on behalf of or for the benefit of a foreign entity or person anywhere

What is a deemed export?

A deemed export is the release or disclosure of information or technology to any foreign national within the United States. Deemed exports are treated as exports to the foreign person’s home country. Deemed exports are a primary area of export control in the university setting. Persons with permanent resident status or U.S. citizenship, and persons granted status as a “protected individual” are exempt from the deemed export rule.

Who is a foreign national?

A foreign national is any person who is NOT a:

U.S. citizen or national
U.S. lawful permanent resident
Person granted asylum
Person granted refugee status
Temporary resident

Foreign nationals include:

Persons in the U.S. with non-immigrant status (for example, H-1B, H-3, L-1, J-1, F-1 practical training)
Persons unlawfully in the U.S.

Why have export controls and why is compliance important?

Export controls are necessary to protect the foreign policy and national security goals of the United States. Export controls:

Restrict exports of goods and technology that could contribute to the military potential of adversaries
Prevent proliferation of weapons of mass destruction (nuclear, biological, chemical)
Prevent terrorism
Assure compliance with U.S. trade agreements and trade and economic sanctions against other nations

It is important that faculty and other researchers understand their obligations under the regulations and follow them. The consequences of violating the regulations can be severe and include loss of research funding, fines, and/or prison time. Faculty can be held personally liable for failure to comply with the ECLs.

What is the impact on your work and Georgia State University?

If the research involves specified technologies, the ECLs may require that the Georgia State obtain prior federal approval before allowing foreign nationals to participate in the research, before partnering with a foreign company, or before sharing research results in any manner (including by publication or presentation at conferences) with persons who are not U.S. citizens or permanent resident aliens. Specifically, ECLs may restrict the ability to:

Ship, take, or transfer items out of the U.S.
Travel internationally with equipment/laptops
Collaborate with foreign colleagues/institutions
Allow participation of foreign students or researchers in research activities
Provide services (including training) to foreign persons, both in the U.S. and abroad
Conduct research freely without having to apply for an export license and/or implement security access controls

Who administers export control regulations?

The following U.S. government agencies administer the primary export control regulations:

The Department of Commerce administers the Export Administration Regulations (EAR)
The Department of State administers the International Traffic in Arms Regulations (ITAR )
The Treasury Department administers the Office of Foreign Assets Control (OFAC)

Find Training

Access training and instructional resources for conducting research at Georgia State.

VIEW TRAINING OPPORTUNITIES

Research Misconduct Policy

These policies and procedures apply to sponsored or non-sponsored research.

VIEW THE POLICY

Report Compliance Issues

Georgia State promotes a culture of research compliance and integrity.

SUBMIT A REPORT

Contact Us

General Inquiries
[email protected]

Jeff Steltzer, JD
Director, Office of Research Integrity Assurance
University Research Services & Administration
404-413-3505
[email protected]

Ravi Gandhi, MA
Compliance Officer - Conflict of Interest
Office of Research Integrity Assurance
404-413-3547
[email protected]

In Person
58 Edgewood Avenue
Room 308
Atlanta, GA 30303

Hours of Operation
8:30 a.m. – 5:15 p.m.

Main navigation

RESPONSIBLE CONDUCT IN RESEARCH

Conflicts of Interest

Understanding Foreign Interference

Understanding NSPM-33: A Federal Security Mandate

Transparency in Disclosure of Other Support, Foreign Components, Financial Conflicts of Interest and Outside Commitments

Other Support

Foreign Components

Outside Commitments

Financial Conflicts of Interest

Export Controls

Security of Materials, Data and Confidential Information

Intellectual Property

Visiting Researchers

Peer Review

Foreign Travel

Quick Summary of Investigator Responsibilities

Why is Georgia State University implementing a revised policy on financial disclosures in sponsored projects?

Who is considered an “Investigator”?

What must an investigator do to comply with the Georgia State policy?

Who can I contact with questions?

Export Controls

What are Export Control Laws (ECLs)?

What is considered an export?

What is a deemed export?

Who is a foreign national?

Why have export controls and why is compliance important?

What is the impact on your work and Georgia State University?

Who administers export control regulations?

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REPORT COMPLIANCE ISSUES

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