Summary
Ohio State University (OSU), a public university in Columbus, Ohio, has agreed to pay $2.1 million to resolve civil allegations that it failed to disclose certain employees’ affiliations with and support from the People’s Republic of China (PRC) in connection with federally funded research.
The settlement concerns National Aeronautics and Space Administration (NASA) and National Science Foundation (NSF) grants that provided funding to OSU from November 2012 through August 2023. The allegations involve required disclosures concerning foreign government support, affiliations, collaborations, and funding involving OSU employees working on federally funded research.
The United States also alleged that OSU failed to disclose information concerning affiliations with PRC universities and state-run research organizations and did not notify NASA or NSF until 2023 that a principal investigator (PI) on NASA grants had participated in the PRC’s Thousand Talents Program.
Key Details of the OSU Settlement
| Detail | Information |
|---|---|
| University | Ohio State University (OSU) |
| Location | Columbus, Ohio |
| Settlement amount | $2,100,000 |
| Nature of matter | Civil allegations |
| Federal funding agencies | NASA and NSF |
| Funding period | November 2012–August 2023 |
| Foreign government involved | People’s Republic of China (PRC) |
| Disclosure issue | Foreign affiliations, collaborations, funding and support |
| Key program identified | PRC Thousand Talents Program |
| DOJ division | Civil Division |
| Investigative agencies | NASA OIG, NSF OIG and FBI |
| Compliance measure | Settlement and accompanying compliance agreement |
Federal Research Funding Disclosure Requirements
NASA and NSF grants provided funding to OSU during the period covered by the settlement.
As part of the federal funding application process, NASA and NSF required OSU to disclose, among other information, foreign government support received by any principal investigator or co-principal investigator on a grant application.
Since 2011, federal law has prohibited the use of grant funds for collaborations with the PRC, PRC universities, or PRC-owned companies.
The settlement resolves allegations that OSU failed to disclose certain collaborations, affiliations, and funding received from the PRC by employees working on NASA and NSF-funded grants.
Why Foreign Funding Disclosures Matter
Federal agencies rely on grant recipients, including colleges and universities, to provide complete information about funding sources and personnel commitments.
The allegations against OSU therefore centered on information that the United States said should have been disclosed during the federal grant process.
The government emphasized that disclosure requirements are designed to protect:
- The integrity of the federal grant process.
- Federally funded scientific research.
- U.S. research interests.
- Taxpayer-funded research investments.
- Research security and national security interests.
Alleged Undisclosed PRC Affiliations at OSU
The United States alleged that, beginning in 2014, annual Faculty Activity Reports submitted to OSU identified affiliations between certain employees and PRC universities and state-run research organizations.
According to the allegations, OSU did not disclose this information to NASA or NSF.
The United States also identified additional OSU employees who worked on the relevant federal grants and who were affiliated with, collaborated with, or received funding from the PRC.
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Thousand Talents Program Disclosure Allegations
Another part of the settlement concerns information OSU allegedly learned in 2019.
According to the allegations, OSU learned that a principal investigator working on NASA grants was participating in the Thousand Talents Program, a program established by the PRC to recruit individuals with knowledge of or access to foreign technology and intellectual property.
Despite learning about the PI’s participation in 2019, OSU allegedly did not notify NASA or NSF until 2023, four years later.
The United States also identified other OSU personnel associated with the NASA and NSF grants who allegedly had PRC affiliations, collaborations, or funding.
DOJ, NASA and NSF Enforcement Response
Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division emphasized that universities receiving federal research support must fully disclose foreign funding in their grant applications.
Shumate stated that the Justice Department would continue holding universities accountable when they fail to comply with disclosure requirements intended to protect research security and federally funded scientific achievements.
NASA Office of Inspector General Statement
Robert Steinau, Senior Official at the NASA Office of Inspector General, said that the settlement and accompanying compliance agreement represented a significant financial recovery for the American public.
He emphasized that institutions receiving federal research funding must not conceal foreign ties in ways that could compromise national security or allow sensitive research to fall into the hands of adversaries.
NSF Office of Inspector General Statement
Acting Inspector General Megan E. Wallace of the National Science Foundation stated that the NSF invests billions of taxpayer dollars annually in research supporting American innovation and national security, including substantial funding for U.S. colleges and universities.
The NSF Office of Inspector General emphasized that federal agencies depend on grant recipients to disclose funding sources and personnel commitments, including foreign support.
According to the statement, failures to make those disclosures can undermine the federal grant process and put taxpayer dollars and U.S. research interests at risk.
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Justice Department’s Federal Fraud Enforcement Efforts
The settlement also comes as the Administration has launched the Task Force to Eliminate Fraud and the National Fraud Enforcement Division to enhance efforts against fraud, waste, and abuse in federal programs.
The Justice Department’s Civil Division described False Claims Act enforcement as an important tool for combating fraudulent schemes involving federal programs, recovering funds for taxpayers, and holding wrongdoers accountable.
The Department stated that False Claims Act matters will remain an important part of efforts to combat fraud and that the Civil Division’s False Claims Act work will support the mission of the Task Force to Eliminate Fraud and the National Fraud Enforcement Division.
Investigation and Prosecution Details
The OSU resolution resulted from a coordinated effort involving multiple federal investigative and enforcement agencies.
The organizations involved included:
- Justice Department Civil Division
- Commercial Litigation Branch
- Fraud Section
- NASA Office of Inspector General
- National Science Foundation Office of Inspector General
- Federal Bureau of Investigation (FBI)
The matter was handled by Fraud Section Senior Trial Counsel Christopher Reimer.
Investigative support was provided by NASA OIG, NSF OIG, and the FBI.
The coordinated investigation addressed the alleged failure to disclose foreign affiliations, collaborations, and funding associated with OSU employees working on federally funded NASA and NSF research.
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Compliance Agreement and Research Security
The $2.1 million settlement is accompanied by a compliance agreement.
The resolution reflects the government’s focus on ensuring that recipients of federal research funding comply with requirements concerning foreign support and personnel affiliations.
Federal officials emphasized that accurate disclosures are important for protecting taxpayer-funded research and maintaining the integrity of federally supported scientific programs.
To read the original order please visit DOJ (Department of Justice) website.