Stanford University: The Funding Missing From Grant Applications

Stanford University agreed to pay $1.9 million over allegations of outside research support omitted from grant applications. The government alleged that the university knowingly left foreign funding out of proposals, including support its researchers had received or expected to receive. For someone who works with research proposals, the point is familiar: what the university knows about a researcher’s funding can differ from what the agency sees when deciding whether to award more money.

The Justice Department announced the settlement on October 2, 2023. It covered grants Stanford received from 2015 through 2020 from the National Aeronautics and Space Administration, the National Science Foundation, the Army, the Navy and the Air Force.

What Stanford Allegedly Left Out of Grant Applications

The government alleged that Stanford omitted current and pending foreign research funding that its grant applications required it to disclose. The disclosure requirement covered support received by the institution, its principal investigators and its co-principal investigators. It reached resources from any source, including foreign governments, made available in support of or related to their research.

The National Science Foundation’s inspector general explained in the settlement announcement that federal funding agencies rely on recipients to track their personnel’s commitments and disclose all funding sources.

This is where the alleged omission affects the competition for research money. The U.S. Attorney’s Office for the District of Maryland said knowing failures to disclose support skew the grant-awarding process in the applicant’s favor. Researchers making complete disclosures put their commitments in front of the agency. An applicant concealing support asks the same agency to decide with part of that picture missing.

We expect a university seeking public research money to disclose who else is paying for that research. Taxpayers should not have to fund a guessing game.

Sixteen Proposals and the Researchers Behind Them

The settlement covered submissions involving twelve Stanford faculty members. The United States alleged that Stanford knowingly failed to disclose foreign funding on sixteen grant proposals involving eleven principal investigators and co-principal investigators. Those proposals went to NASA and the National Science Foundation as well as the Army and Navy. The alleged omissions concerned money those investigators had received or expected to receive in direct support of their research.

Proposal after proposal. The allegation of knowing omissions makes the university’s handling of the information important. We examine what was known when it submitted each application, what the support disclosure said and which agency received it. A researcher who understands an outside commitment and an administrator who understands the submission may be able to explain different parts of the same omission.

The Fudan Employment and Research Funding Allegation

The government separately alleged that Stanford failed to disclose a professor’s research funding connected to employment at Fudan University, a foreign public university, and funding from a foreign government’s national science foundation. The National Science Foundation was among the federal agencies receiving the allegedly incomplete disclosures, alongside the Army and Air Force.

Someone familiar with an outside appointment may know a part of the funding arrangement that is hard to see from the submitted proposal. We connect that knowledge to what the appointment provided, how it related to the research and what the university told the funding agency.

The Undisclosed Appointment Also Committed Research Time

The settlement agreement supplies more detail about the Fudan allegation. It identifies employment under a university talent initiative and a separate grant from the National Natural Science Foundation of China. The United States alleged that Stanford failed to disclose funding the professor received or would receive from those arrangements while the federal grants were in place.

The government also alleged that the professor was overcommitted during part of the period because of the undisclosed appointment, research funding and other foreign support. The problem described in the agreement therefore involved both funding and time. An outside appointment could commit a researcher’s effort while the federal proposal presented the agencies with an incomplete account of those commitments.

That connection makes the appointment agreement relevant alongside the funding disclosure. The proposal told a federal agency what support the investigator had; the outside arrangement described obligations attached to other support. The government’s allegation joined those records when explaining why the omission mattered to the awards.

What Stanford Agreed to Change

Stanford agreed to work with the National Science Foundation’s Office of the Chief of Research Security Strategy and Policy on best practices in the areas the government identified.

The agreement identifies the planned work more specifically as best practices for gifts funding research projects and for current and pending support disclosures. These were the areas of concern identified by the United States. Stanford’s agreement to work with the research-security office addressed those institutional practices; the settlement expressly states that it is not an admission of liability.

How Other Grant Cases Expose the Same Information Gap

Other civilian grant fraud cases show why support disclosures and personnel commitments belong together. In the Cleveland Clinic Foundation’s foreign-support settlement, the government alleged that applications and progress reports omitted a principal investigator’s pending or active foreign financial research support and already committed research time.

How Omitted Research Support Connects to a Whistleblower Case

A grant-disclosure case connects what the university told the agency to the support known inside the institution. Like other false statements used to obtain federal funding, the Stanford allegations concerned information the government needed when deciding where its money should go.

Proposal drafts, support disclosures and records of outside funding give us different parts of that comparison. We work with your knowledge of the research to identify the representation, who knew about the other support and the award it affected. The connection between those facts is what gives a grant-fraud case its strength.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. Our discussion of a possible whistleblower reward starts with the grant conduct you can explain and the evidence connecting it to federal money.

You Know the Funding Behind the Proposal

If you know about research support that disappeared from a federal grant application, talk with our whistleblower experts about what the application left out. We build the grant-fraud case with you and bring in federal grant fraud whistleblower lawyers who understand support disclosures, research commitments and the institution’s responsibility. We stay beside you throughout the case, bringing your knowledge of the funding into every decision about how to pursue it.