Policies and Regulations

In addition to Emory University’s Research Security policy, investigators are also subject to the policies of their federal research sponsors.  


Emory is recognized globally for its groundbreaking research in all areas of inquiry. Our success is often the result of domestic and international research collaborations. We strongly support collaborations and exchanges with our research partners across the globe. Emory, however, recognizes that such success can potentially cause the University to be targeted by individuals or entities seeking to leverage or misappropriate our research portfolio, intellectual property, and other assets. Emory is not alone in this landscape: in the competitive international science and technology arena, all higher education institutions are being called on to help protect U.S. science and technology through responsible and careful stewardship. That means updating our internal policies and processes related to research security while emphasizing the value of a global workforce, international scientific collaborations, and academic freedom. Aside from simply being the right thing to do, the downside consequences of failing to protect our research responsibly could be significant, including federal debarment, fines and penalties, and potential reputational harm to Emory.
Thus, we are committed to ensuring compliance with federal rules and regulations while maintaining a research environment that fosters excellent research collaborations.


Per NIH Grants Policy Statement Section 2.5.1, Senior/Key Personnel must disclose Other Support as part of the Just-in-Time procedures. This includes all active and pending 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 the institution the researcher identifies for the current grant.  


Per NSF Proposal & Award Policies & Procedures Guide Chapter II, Senior Personnel must disclose Current and Pending Support as part of the proposal. Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value, including in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students).  


Per DOE Order 486.1,   

  • In 2019, DOE issued DOE Order 486.1 that prohibited individuals performing work under a DOE contract to participate in foreign government talent recruitment programs of countries designated by DOE as a foreign country of risk.   
  • On December 13, 2019, DOE issued DOE Order 142.3A Chg 2 to remove an exemption from prior approval requirements for certain foreign nationals participating in DOE funded fundamental research projects at universities. The full implications of this change are not yet known, and UC Office of the President staff are currently in discussions with DOE officials. In May 2020, UCOP issued guidance to the contracts and grants staff at the UC campuses on awards containing this Order. If any UCLA investigators are recipients of such an award, the cognizant OCGA officer will contact them to determine what actions may be necessary in order to achieve compliance with UC policy concerning nondiscrimination on the basis of citizenship. 
  • On September 4, 2020, DOE issued DOE Order 486.1A and an FAQ concerning the participation of DOE employees, contractors, and certain subcontractors in foreign government talent programs and other activities in "foreign countries of risk." The list of these countries is subject to change. At present it includes China, Russia, North Korea, and Iran. It is our current understanding that this Order does not apply to DOE financial assistance awards to universities. With regard to DOE laboratory subcontracts to universities, it normally applies only to university staff if they come on to a DOE site to perform R & D work. If you have any questions on this requirement, please contact your cognizant OCGA Officer. 


The National Defense Authorization Act for FY 2019 stated that DOD shall "establish an initiative to work with academic institutions...to support the protection of intellectual property and controlled information...and to limit undue influence, including through foreign talent programs, by countries to exploit United States technology." 

DOD issued a memo on March 20, 2019 that outlined disclosure requirements for Key Personnel on research and research-related educational activities supported by DOD grants and contracts. 


Since 2011, NASA has prohibited the use of any its funding to enter into agreements "to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement." On February 27, 2020 a faculty member at the University of Tennessee Knoxville was arrested for failure to disclose his affiliation with a Chinese university.