Overview of the Decision Matrix
The National Institutes of Health (NIH) has unveiled a new decision matrix to enhance transparency and compliance in handling potential foreign interference in research. This tool acts as a decision tree, offering detailed guidance on how NIH assesses allegations of foreign interference and determines when to contact institutions for additional information.
Enhancing Transparency and Compliance
The decision matrix is an extension of existing resources and aligns with NIH’s longstanding policies focused on proper disclosure and transparency throughout the grant process. The matrix provides a clear framework for institutions and researchers to follow, reinforcing the importance of transparency and accountability.
Support for International Collaborations
NIH continues to support well-conducted international collaborations that are crucial for maintaining the competitiveness of the U.S. in the global scientific arena. The matrix is designed to ensure these collaborations respect the integrity of the scientific process, with a particular focus on avoiding scientific or budgetary overlap, overcommitment, and nondisclosure of financial conflicts of interest and foreign components.
Guidance on Routine Academic Activities
The decision matrix also clarifies acceptable activities for researchers involved in international collaborations. Scientists may:
- Write letters of recommendation for foreign colleagues
- Serve on peer review or advisory panels for foreign funding agencies
- Co-author scientific publications (with prior approval if related to NIH-funded work)
- Lecture, teach, and receive foreign honors
- Participate in foreign research grants or employment (excluding malign foreign talent programs), with the requirement to disclose these agreements to NIH and their institutions
Commitment to Fair and Objective Oversight
Dr. Monica Bertagnolli, NIH Director, emphasized ensuring that NIH’s compliance and oversight efforts remain objective and discrimination-free. NIH is committed to conducting these reviews without stigmatizing or unfairly treating members of the research community, especially those from ethnic or racial minority groups. Dr. Bertagnolli reiterated that targeting, discrimination, and harassment are unacceptable in any oversight.
Alignment with Key Policies
The decision matrix is consistent with important NIH and federal policies, including the NIH Grants Policy Statement, the Implementation Guidance for National Security Presidential Memorandum-33, and federal regulations outlined in 2 CFR 200.206. NIH believes this tool will strengthen the ability of research organizations to comply with these policies while fostering robust scientific collaborations.
Conclusion
NIH anticipates that the decision matrix will serve as a valuable resource for research organizations and their scientists, clarifying compliance requirements and supporting international collaborations that uphold the highest standards of scientific integrity. Researchers are encouraged to consult NIH program staff with any questions regarding foreign collaborations to ensure full compliance with NIH policies.
