alexander bustamante, senior vice president and chief compliance and audit officer, has issued a letter to colleagues regarding escalation protocols for research-related matters. president janet napolitano highlighted that federal agencies, such as the national institutes of health (nih), are increasingly scrutinizing international engagements at research universities. to address this, a systemwide investigative protocol is being developed by the office of ethics, compliance and audit services (ecas) in conjunction with the office of general counsel (ogc). the protocol aims to ensure that federal agency inquiries are appropriately tracked, escalated, and investigated. the protocol applies to matters involving foreign entities in research, including non-disclosure of foreign financial or non-financial support in grant applications, diversion of intellectual property to foreign entities, recruitment of students from foreign entities, compliance with reporting requirements from foreign sources, use of federal grant funds in research partnerships with foreign entities, and cybersecurity threats from foreign entities. a "triggering event" includes any communication from a federal agency expressing concern about a foreign entity's involvement in research or any campus knowledge or suspicion of a violation of federal policies or laws regarding foreign entities. communications include subpoenas, civil investigative demands, cease and desist letters, and requests for interviews or reviews. once a triggering event occurs, the employee receiving the communication must notify the locally designated official (ldo) within 24 hours. the ldo will enter the details into the whistleblower reporting system (navex), which will notify ecas and ogc. the ldo will typically oversee the investigation, but ecas and ogc may determine that oversight should be handled by others. the campus office of research and other departments will assist in investigating allegations. ogc and ecas will assist in handling the inquiry and reviewing communications with federal agencies. questions should be directed to bustamante. the letter is addressed to various university officials.alexander bustamante, senior vice president and chief compliance and audit officer, has issued a letter to colleagues regarding escalation protocols for research-related matters. president janet napolitano highlighted that federal agencies, such as the national institutes of health (nih), are increasingly scrutinizing international engagements at research universities. to address this, a systemwide investigative protocol is being developed by the office of ethics, compliance and audit services (ecas) in conjunction with the office of general counsel (ogc). the protocol aims to ensure that federal agency inquiries are appropriately tracked, escalated, and investigated. the protocol applies to matters involving foreign entities in research, including non-disclosure of foreign financial or non-financial support in grant applications, diversion of intellectual property to foreign entities, recruitment of students from foreign entities, compliance with reporting requirements from foreign sources, use of federal grant funds in research partnerships with foreign entities, and cybersecurity threats from foreign entities. a "triggering event" includes any communication from a federal agency expressing concern about a foreign entity's involvement in research or any campus knowledge or suspicion of a violation of federal policies or laws regarding foreign entities. communications include subpoenas, civil investigative demands, cease and desist letters, and requests for interviews or reviews. once a triggering event occurs, the employee receiving the communication must notify the locally designated official (ldo) within 24 hours. the ldo will enter the details into the whistleblower reporting system (navex), which will notify ecas and ogc. the ldo will typically oversee the investigation, but ecas and ogc may determine that oversight should be handled by others. the campus office of research and other departments will assist in investigating allegations. ogc and ecas will assist in handling the inquiry and reviewing communications with federal agencies. questions should be directed to bustamante. the letter is addressed to various university officials.