Stanford University Pays $1.9 million to US Government for Failure to Disclose Support from Foreign Sources

On October 2, 2023, the Department of Justice (“DOJ”) announced that it reached a settlement agreement with Stanford University in which Stanford agreed to pay $1.9 million dollars to resolve allegations it violated the federal False Claims Act by failing to disclose certain support in a number of research grant proposals.  Stanford also agreed to work with the National Science Foundation (“NSF”) on best practices in the areas of gifts funding research projects and other areas identified by the government.  Of note, the settlement was with Stanford, not with individual faculty members, and Stanford agreed to cooperate with the government in its investigation of individuals and other entities. 

The DOJ alleged that Stanford failed to disclose support that 12 Stanford faculty members were receiving from foreign sources in research grant proposals to five federal agencies: the Departments of the Army, Navy and Air Force, NASA, and the NSF.  The DOJ alleged that in 16 applications for 12 different principal investigators (“PIs”), Stanford knowingly failed to disclose current and pending foreign funding that the PIs had received or expected to receive in direct support of their research. At least some of the undisclosed research funding came from gifts. The DOJ further alleged that one Stanford professor failed to disclose to three agencies that he was employed at Fudan University, a foreign public university, via a talent program (these talent recruit programs in China have come under scrutiny and restrictions by the United States government because they are perceived by law enforcement authorities as a means for China to illegally acquire information, technology and intellectual property from the United States), and that he received research funding from the Chinese National Natural Science Foundation of China and other unnamed sources.  The DOJ alleged that this faculty member was overcommitted during a portion of the period of US federal grant funding.

For more information, see the DOJ press release.   

Given the government’s continued close attention to disclosures, it is important that PIs understand their obligations.  MIT has various resources available to researchers to assist with disclosure obligations.  Contract administrators in Research Administrative Services can provide detailed guidance and will elevate to the research compliance team as needed. Online information is available at https://ras.mit.edu/grant-and-contract-administration/sponsor-information and https://coi.mit.edu/sponsor-specific-guidelines and questions may always be sent to research-compliance-help@mit.edu or coi-help@mit.edu.