Research Integrity Newsletter

On June 8th, the U.S. Department of Defense (DoD) released its updated Section 1260H List of Chinese Military Companies Operating in the United States.

Historically, this list focused on traditional heavy defense, state-owned aviation, and specialized surveillance entities. The latest update represents a significant expansion into mainstream commercial technology, e-commerce, electric vehicles, and biotechnology.

Because federal agencies, most notably the DoD, restrict funding, collaboration, and procurement involving 1260H-listed entities, all UCSB researchers should review their current international collaborations and equipment procurement pipelines immediately.

 

Key Highlights Relevant to UCSB Research

 

The new list adds several large parent corporations and broadens the number of subsidiaries. Critical additions impacting academic research include:

 

• Alibaba Group Holding: Open-source AI collaborations, cloud data storage, or software licensing.
• BYD Company, CALB Group: Clean energy research, battery testing, and advanced material procurement.
• BOE Technology Group: Semiconductor research, specialized cleanroom displays, and optoelectronics.
• Autel Intelligent Technology: Autonomous systems, environmental surveying, and field research hardware.
• BGI Americas Corporation, Complete Genomics, Inc., Forensic Genomics International, GBI Diagnostics, Inc., Innomics Inc., and STOmics Americas Ltd.: Genetic sequencing services, collaborative clinical datasets, and biotech hardware.

While a Section 1260H designation is not an outright Commerce Department export ban, it serves as a major federal "red flag." Researcher groups should proactively identify any involvement of these companies or their products in their research due to the following:

 

• DoD Funding & Proposal Restrictions
  Under current DoD policy, the Pentagon prohibits the direct involvement of these companies in DoD-funded research. They review all fundamental research proposals for "covered individuals" (PIs, Co-PIs, and senior personnel) who have active associations, funding, or collaborations with 1260H entities. The presence of these entities can result in funding delays and/or mandatory mitigation requirements.
• Strict Procurement Bars
  Federal procurement restrictions prohibit purchasing end-products or services from these entities with federal funds. Do not purchase hardware, drones (e.g., Autel), or sequencing services from these listed groups using federal funds.

 Next Steps for PIs

 

Ensure no upcoming lab purchases involve Autel drones, BYD components, BGI-affiliated genomic services, or any other company on the 1260H list. If you are unsure whether a prospective international collaborator, vendor, or material supplier is impacted by today’s expansion, please contact the UCSB Export Control Officer at exportcontrol@research.ucsb.edu for assistance.

 

As we head towards the end of the academic year, ensuring your disclosures are up-to-date is key to keeping your research funding on track. There are different requirements in what must be reported to Office of Research via our Conflict of Interest (COI) disclosure system (ORCOI) and reporting requirements to Academic Personnel via the Outside Activity Tracking System (UC OATS). As you know, ORCOI is for research-related financial interests while UC OATS is for outside professional activities (Category I, II, III).

 

For Public Health Service (PHS) & Department of Energy (DOE) sponsored research, or for research sponsored by agencies that follow similar COI requirements, financial interests related to an investigator’s institutional responsibilities (institutional responsibilities are those directly related to the credentials expertise, licenses, achievements, publications and patents upon which your UC Santa Barbara appointment was and is currently based) must be disclosed if they meet certain thresholds.

 

For National Science Foundation (NSF) & National Aeronautics and Space Administration (NASA) sponsored research, or for research sponsored by agencies that follow similar COI requirements, financial interests that would reasonably appear to be affected by an investigator’s funded or proposed research and educational activities require disclosure if they meet specific thresholds.

 

When to file or update your COI Disclosure:

• At the time of proposal submission
• Annually throughout the period of the award
• As new investigators are added to the project
• As investigator's financial interests change (within 30 days of those changes)

 

If your affiliation with an outside entity meets the COI reporting thresholds, please log into ORCOI to update your COI disclosure(s), as applicable.  To access the disclosure system, please follow these steps:

• Login to the ORCOI system with your UCSB credentials.
• View the "My Disclosures" page to submit a disclosure.
• You can find guidance on using ORCOI in the PI User Guide.

Per Academic Personnel policy, activities that fall within categories I and II must be reported in UC OATS. Category I activities require prior approval. Category III activities generally do not require reporting or approval, unless students are involved in the activity. 

 

Please keep these reporting requirements and timelines in mind so activities are reported to the correct office at the proper time.

 

Please email coi@research.ucsb.edu if you have any questions or concerns about Conflict of Interest reporting requirements.

 

For questions regarding UC OATS or Academic Personnel policies, please contact helly.kwee@ucsb.edu.

 

Informed Consent for Human Subjects Research - Website Templates

Informed consent is a cornerstone of ethical human subjects research, but it’s also one of the most common places where small omissions can delay HSC approval. A clear, complete consent form not only supports participants, it helps your study move through review more efficiently.

 

At a basic level, consent materials should help participants clearly understand what they’re being asked to do. That means explaining that the activity is for research purposes, why you’re doing it, what participation will look like (including time commitment), and any reasonably foreseeable risks or discomforts. If there are potential benefits, those can be described too (though compensation or course credit doesn’t count as a “benefit” in this context).

 

There are a few areas that are easy to overlook. One is confidentiality: participants should know how their information will be handled, including whether identifiable data will be kept and whether de-identified data or biospecimens could be used for future research. Another is contact information; you’ll need to include both your own contact details and information for the HSC so participants know who to reach out to about their rights. And, of course, it should be clear throughout that participation is voluntary and that people can opt out at any time without penalty.

 

The good news is that the HSC provides a variety of sample consent forms that help to ensure you include all the necessary information (https://www.research.ucsb.edu/forms). There are templates for different types of studies (online surveys, interviews with or without recording, social/behavioral projects, biomedical procedures, and more) as well as some add-on language for international studies.

 

Starting with the template that best fits your study is one of the simplest ways to ensure your consent form is complete, compliant, and easy for participants to understand, while also minimizing revisions during HSC review.

Interested in hosting a human subjects webinar for your department, class, or research team? We can present on a variety of topics from recruitment to informed consent. Contact us at hsc@research.ucsb.edu to schedule a webinar today!

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