Institutional Science and Security Program

Conflict of Interest

In the January 2022 Guidance issued by the Office of Science and Technology Policy in the White House, it was confirmed there should be no changes to current collection of research conflict of interest data as delineated by the various agencies policies.

The Guidance acknowledged that the federal agencies are creating some differing standards and has indicated their intent to harmonize them as much as possible.

Please see the Conflict of Interest Office’s webpages for the standard processes and any updates.

Conflict of Commitment

While the University’s definition and policy on conflict of commitment has existed for decades, it was in January 2021 when the first federal definition was issued in the NSPM 33. This memorandum was paused until January 2022.

In the OSTP January 2022 Guidance, it has been indicated that federal agencies will need to specify by Summer 2022 their parameters for this definition.

OSTP Definition

Situation in which an individual accepts or incurs conflicting obligations between or among multiple employers or other entities. Includes time and effort. Also sharing information with external or withholding info from primary employer.

The NSF has provided some indication of their interpretation.

EXAMPLE: NSF

• Capacity (time)
• Overlap (scientific)
• Duplication (dollars)

Please note the above text is pending and subject to final issuance by NSF.

Updates

On August 31, 2022, information was placed in the Federal Register and OSTP issued some common parameters for disclosure, including items which would create a conflict of commitment. Public comments are due back to the federal comment by October 31, 2022.

UNC-Chapel Hill is reviewing the OSTP draft information and will update this page when further information is available. Efforts will be led by the COI Office and the Academic Personnel Office in the Provost’s Office. Please send any questions to issp@unc.edu.

Sponsored Research Review and Reporting

The Research Science and Security Director is based in the Office of the Vice Chancellor for Research. Director Brian Collier interfaces with the following subject areas within the University.

International

Reviews conducted by the Research Science and Security Director encompass:

• Various visa requests, as needed
• All international telework requests
• All unpaid intern/volunteer/visiting scholar requests

IT Research Concerns

• Partners with ITS on research specific security concerns

Training

Leadership for campus training on Federal grant standards, with a significant focus on Other Support and BioSketch documents. Focused training has been provided in the following high-risk areas:

• NIH Other Support new requirements
• NIH Biosketch new requirements
• Data Security for Research
• International Scholars and Visitors

Export Control

Export Compliance and Science & Security

Housed in Institutional Integrity and Risk Management, the UNC-Chapel Hill Export Compliance Office is responsible for implementing effective processes and procedures that comply with U.S. export control laws. These laws govern the transfer of controlled information, items and technologies to foreign countries and foreign persons for national security purposes. The regulations also seek to further U.S. foreign policy through the administration of trade and economic sanctions.

For this reason, the Export Compliance Office commonly collaborates with those charged with managing the Institutional Science and Security Program. Areas where the Export Compliance Program and the Institutional Science and Security Program commonly overlap consist of, but are not limited to: visiting scholars, sponsored research, international licensing and various other international engagements.

International Scholars, Travel and Employment

International Scholars and Visitors

• A working group – HR, Global, Student Affairs, Research, OUC, Export and key University schools – refined the forms and process.
• Focus is reviewing visa applications sponsored by UNC-Chapel Hill and international visitors to identify and mitigate risks. Ongoing quality assessments to determine best practices. Review will always need to include intersection with funded research, conducted by the Research Science and Security area.
• See the ISSS website.

International Telework Requests

• For these requests, contact your unit’s HR representative or assigned Talent Acquisition Partner.
• Additional process to determine if foreign components or other sponsor requirements are affected. Federal regulation conflicts or other additional risks are identified by Export Control and Research Science and Security area.

International Hiring Process

• The University has contracted with a global employment firm, Safeguard Global, to minimize risks associated with new hires who will work overseas. This process is being led by the Office of the Vice Provost for Global Affairs, partnering with OHR, APO, Payroll and Purchasing.
• See Global Employment and Hiring.

International Travel

• Travel Policies and Exceptions

Cybersecurity and Physical IT Security

In 2019, an initial working group focused new cybersecurity research requirements which arose over the past four years. This working group was composed of:

• Central Research Office(s)
• Institutional Privacy Office
• Export Control Program
• Information Technology Services (ITS)
• School of Medicine IT

The group worked to enabled policies and structure to address NDAA 889 and to create University guidance.

Assessment work by ITS continues regarding cybersecurity and the development of new programs to address security concerns.

Intellectual Property

Significant concern regarding intellectual property has been stated by Congressional representatives, the federal funding agencies, such as the National Institutes of Health and the federal security agencies such as the Federal Bureau of Investigation.

Intellectual property can be in many forms, although only some can be legally protected.

For further information about the different types of intellectual property and how to safeguard your work, please contact the Office of Technology Commercialization.

Section 117

Under Section 117 of the Higher Education Act of 1965, the Department of Education has required reporting from universities. The history as explained on their website:

Over 30 years ago, Congress enacted Section 117 of the Higher Education Act of 1965 (HEA) in light of concerns about the growing financial relationship between U.S. universities and foreign sources. Congress balanced academic freedom and national security by mandating financial transparency through required reporting of contracts with and gifts from a foreign source that, alone or combined, are valued at $250,000 or more in a calendar year.

In accordance with this regulation, the University of North Carolina reports any such interests as detailed by the Department of Higher Education. The reporting of this information is coordinated under the oversight of the Institutional Science and Security Officer.