The Clemson University research community should be aware of several federal policy notices issued this summer related to co-authorship, travel, talent recruitment, foreign collaboration, data protection, AI use and other matters.
The Division of Research has published numerous updates to its Regulatory Alerts webpage, which includes timely updates about changing regulations and policies affecting sponsored research. Brief synopses are below, and additional details are published on the Regulatory Alerts webpage.
Report foreign co-authorship.
The National Institutes of Health (NIH) reminds award recipients to report foreign co-authorship to the funding Institute or center as soon as they become aware of it, so NIH can determine whether additional steps are needed. Faculty should also ensure NIH-funded publications accurately acknowledge federal support, avoid attributing publications to awards that did not support the work and review “Notice of Funding Opportunity” restrictions carefully because some NIH programs do not permit foreign components. For questions, contact the Office of Sponsored Programs.
Consult with Research Security on foreign collaborations.
The U.S. Department of War released an updated Section 1286 list of foreign institutions identified as engaging in activities that increase the risk of unauthorized technology transfer and other research security concerns. Investigators with foreign collaborations, proposal activity or other research engagements should review the list and consult the Office of Research Security at researchsecurity@clemson.edu for guidance. The complete updated list, which includes 130 academic and research institutions in China, Russia and Iran, is available in the Department of War announcement: Department of War FY25 Section 1286 announcement.
Reminder: Participation in malign foreign talent recruitment programs is prohibited.
Federal research security requirements prohibit participation in malign foreign talent recruitment programs (MFTRPs). The U.S. Department of Energy recently highlighted these restrictions as part of its research security communications. Faculty should carefully review any foreign appointment, affiliation, consulting arrangement, talent program, sponsored position, laboratory appointment or similar offer before accepting or continuing participation.
Clemson University’s Foreign Talent Recruitment Programs Policy requires annual certification by all research personnel as part of the Conflict-of-Interest disclosure process. The policy also prohibits research personnel from participating in Malign Foreign Talent Recruitment programs. Faculty with questions about a foreign affiliation or talent program should contact the Office of Research Security before signing or participating.
Avoid carrying sensitive information when traveling internationally.
Faculty, staff, and students traveling to or transiting through Hong Kong should be aware of recent changes to Hong Kong’s National Security Law implementation rules. According to a recent security alert from U.S. Consulate General Hong Kong, individuals in or transiting through Hong Kong, including U.S. citizens, may face criminal penalties for refusing to provide passwords or decryption assistance for personal electronic devices such as laptops and cell phones.
Clemson personnel should avoid carrying unnecessary sensitive information and should consult the Office of Research Security before international travel involving research, university data or other sensitive information. When possible, travelers should use loaner devices, limit access to Clemson systems and data to what is necessary for the trip and follow University guidance regarding secure remote access while abroad.
Safeguard research data, intellectual property and technology.
A joint federal publication, Safeguarding Our Data, Intellectual Property, and Technology from Non-traditional Collectors, warns that foreign governments may seek to acquire U.S. technology and intellectual property by using academics, students, researchers, business professionals or technology professionals as “non-traditional collectors.” The publication explains that these individuals may not have a direct relationship with a foreign intelligence service, but may still acquire intellectual property, proprietary information, sensitive technology, research data or personally identifiable information to support a foreign government’s economic, military, technology or national development goals.
Recommended mitigation steps include vetting individuals with access to sensitive work, protecting important data with encryption and strong authentication, limiting access to sensitive research and information systems, providing clear guidance on device and travel security, and reinforcing reporting mechanisms for suspicious activity. For questions, contact the Office of Research Security.
NIH streamlines data sharing plans.
The National Institutes of Health (NIH) issued Notice NOT-OD-26-046: Updated Elements of an NIH Data Management and Sharing Plan, which updates the required format and elements for Data Management and Sharing (DMS) Plans. Under the revised format, investigators will respond to a series of structured yes/no questions addressing data sharing, sharing timelines, data availability, protections for human participant data, and, where applicable, genomic data sharing requirements. The format also includes a brief explanation section for any limitations on data sharing and a concise table identifying anticipated data types and established or proposed repositories.
For more information about DMS plans, please visit the library resources or additional context from the Office of Sponsored Programs.
Verify Institutional Review Board (IRB) approval.
NIH issued a reminder Notice NOT-OD-26-043: Reminder of Requirement for Certification of IRB Approval to remind the extramural research community of the requirement to provide certification of Institutional Review Board (IRB) approval for all nonexempt human subjects research as part of Just-in-Time requirements. Pending, conditional, interim, or expired IRB approvals do not satisfy this requirement.
The notice also reiterates that NIH funds may not be used to conduct nonexempt human subjects research without current IRB approval. While NIH may, at its discretion, issue an award before IRB certification is received, any resulting award will include restrictions on conducting human subjects research activities until the required IRB approval documentation has been provided and accepted.
For questions, contact the IRB Office at irb@clemson.edu.
Use AI safely and appropriately
In a NIH Extramural Nexus article, Helpful Reminders to Ensure Integrity of NIH-Supported Research When Using AI, NIH reminded the research community that investigators remain responsible for the accuracy, integrity and confidentiality of all research activities when using artificial intelligence (AI) tools.
The article highlights some helpful reminders on the appropriate use of AI tools when applying, managing awards and conducting the research process. NIH emphasizes that AI tools may be appropriate to assist with application preparation for limited aspects or in specific circumstances, but researchers should be aware that using AI carries its own risks. Applications that are either substantially developed by AI or contain sections substantially developed by AI are not considered the original ideas of applicants and will not be considered by NIH.
To learn more about responsible AI use at Clemson, visit Clemson’s Generative AI Guidelines, Academic and Research AI Usage Quick Guide, AI Tool and University Data Use Guide and AI Resources and Training page.
Reminder: Certain agreements require review by the Office of Sponsored Programs
Faculty members who receive a Data Use Agreement (DUA), data access agreement, Non-Disclosure Agreement (NDA), Material Transfer Agreement (MTA), confidentiality agreement or similar document from an outside organization should not sign it individually or begin accessing the data before institutional review. These agreements may create legal, regulatory, security, privacy, export control or sponsor-compliance obligations for Clemson, even when the data appear routine or the project is already underway.
These agreements should be routed to the Office of Sponsored Programs (OSP) before signature or acceptance. OSP will coordinate with the appropriate Clemson offices as needed to determine whether the agreement requires additional review, such as data security planning, privacy review, export control review, controlled data handling requirements or use of an approved secure computing environment. Faculty should contact OSP before signing, downloading, receiving, storing, sharing or analyzing data under a DUA.
