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International Relationships and Disclosures
Moffitt has a long history of broad and diverse collaborations, and we remain committed to continuing to build and develop valuable relationships with institutions and scientists from all countries. We know our mission is made possible by the contribution of physicians, scientists, students and staff from around the world. We work together to prevent and cure cancer while adhering to our values, obeying all laws and following the directives and guidelines of the government and the agencies that fund our research.
The United States has discovered incidents of inappropriate and illegal activities occurring in universities, academic medical centers, and corporate research environments. These activities include theft of technology, theft of patented compounds, copying university or corporate data to personal equipment, false claims of invention, plagiarism, and falsification of translated information for purposes of obfuscation, concealment, and fraud. These illegal activities have prompted the federal government to issue warnings to academic institutions to protect the integrity of our nation’s research.
One area of serious concern is the failure of federally funded researchers to disclose relationships and activities with foreign individuals and entities, including foreign institutions and foreign funding agencies. Several federal agencies, including the National Institutes of Health (NIH), Department of Defense (DOD) and the Department of Energy (DOE), have indicated that failure to disclose foreign relationships and activities may jeopardize current funding and eligibility for future federal funding for individual researchers and for the institutions that hold federal grants.
Moffitt values and embraces inclusion and diversity and continues to be committed to actively creating and supporting an environment where all can work, study, learn and create without fear of bias or discrimination on the basis of race, gender, sexual orientation, ethnic origin or nationality. The institution supports international collaborations through a variety of established programs. Importantly, Moffitt has significant experience in evaluating, developing and supporting complex international relationships that support our mission. In this context, it is imperative that all faculty and investigators be forthright and transparent about their relationships and activities with foreign individuals and entities and that we follow Moffitt’s policies and procedures in our own international relationships.
Complete transparency and full disclosure protects everyone’s interests, including our investigators, the federal government and Moffitt. Importantly, complete disclosure allows for continued state and federal funding (e.g., NIH, DOD, DOE) for research, which is a vital source of support for the institution’s mission. Complete reporting also allows for full compliance with Moffitt’s policies and procedures and protects the reputation of individual faculty members.
Failure to disclose all relationships could result in an NIH decision to terminate funding for a current grant and may lead to Health and Human Services (HHS) sanctions that may include debarment, prohibiting the researcher from obtaining further federal research funding. Failure of Moffitt to comply with federal regulations related to reporting of foreign research relationships may put the institution’s NIH and state funding relationship at risk.
Advancing science today rarely stems from a scientist working alone. Research collaborations are vital to advance scientific discovery, including partnerships with scientists and institutions from around the world.
Moffitt supports appropriately developed and properly documented research collaborations. We are committed to obeying federal and state laws and reporting requirements. We are dedicated to our core values and committed to educate and train our community to enable each person to do the right thing.
Moffitt faculty and staff are required to disclose all foreign components in any NIH grant application, all applicable sources of “Other Support” as required by federal sponsors, and financial interests received from or related to any outside entity. Additionally, Moffitt policy requires that faculty and staff receive prior approval for any consulting and/or other business activity, whether foreign or domestic, that is related to, or could appear to be related to, their Moffitt duties and responsibilities.
Foreign Talent Programs
Because of Moffitt’s world-class reputation and cutting edge research, our faculty are sought after as targets for recruitment for participation in foreign talent programs.
These foreign talent programs, such as China’s Thousand Talents Program, are under scrutiny by the federal government — particularly in situations when they are not disclosed to the U.S. institution that employs the faculty member. These foreign talent programs often are predatory in nature, and designed to siphon through our faculty, intellectual property and research data created or developed at Moffitt. This included federally funded, unpublished research data and tools, and intellectual property discovered or created by our faculty, which are legally owned by the institution.
Moffitt faculty and staff are required to disclose any involvement in a foreign talent program to both the Compliance Office and federal sponsors. These arrangements must be disclosed and approved by Moffitt before they are agreed to, regardless of whether personal compensation is offered. Depending upon an individual’s research portfolio, he or she may be advised to terminate his or her affiliation with the foreign talent program.
Operating Research Labs Outside of Moffitt
Faculty and investigators may not conduct or oversee (onsite or remotely) research for or on behalf of another entity, or operate a lab or research facility outside of Moffitt. Moffitt faculty who wish to engage in or oversee research outside of Moffitt must receive advanced approval by the Compliance Office and the center director. Relatedly, work for any laboratory or hospital owned by a foreign government requires a contract that can only be approved by Moffitt’s Office of General Counsel.
To contact the Corporate Compliance Program, please call 813-745-1869 or email email@example.com.