International Research Relationships and Activities
Guidelines, requirements, and information on international research relationships and activities
As a university community, we are all deeply committed to the open flow of ideas and research partnerships, a welcoming environment for students and faculty from all corners of the globe, and open opportunities for our students and staff to discover the world. At the same time, over the past several years, numerous federal agencies and Congress have raised concerns regarding inappropriate foreign state influence on research conducted at US universities. While we remain steadfast in our commitment to international collaboration, we also must comply with a changing landscape of federal regulations. It is important to have international relationships disclosed and vetted to determine if there are any potential conflicts of commitment or interest, duplications of research, or concerns about intellectual property.
The purpose of this website is to provide members of our community with resources and information to maintain compliance with these rules as they continue to evolve.
Disclosure Requirements and Best Practices
As the environment continues to change, we offer a series of best practices that faculty should review and follow to help them stay compliant.
1. Disclose all foreign support and collaborations in proposal applications and reports
PIs, co-PIs, and key personnel should pay careful attention to the sponsor’s guidelines and requirements regarding requirements to disclose foreign collaboration and support. Sponsored researchers are required to notify their sponsor of any foreign support they are currently receiving or anticipate receiving. This includes monetary or non-monetary foreign support, and work at foreign institutions whether paid or unpaid. In addition, it is important to ensure that your current and pending supporting document includes mentions of all support for research, scholarship, and creative activity regardless of funding source. All collaboration disclosures must be complete and accurate.
At this time, PIs, co-PIs, and key personnel should review any pending proposals and active awards to ensure that all foreign components have been fully disclosed in conformance with the specific federal sponsor’s guidelines. Any PI who identifies an omission or error in any disclosure, including international collaboration in a previously submitted proposal, should contact Sponsored Projects Services to have the error corrected with the sponsor. In addition, researchers involved in international collaborations should determine if sponsor approval is required to perform the research.
Questions regarding individual awards: firstname.lastname@example.org.
2. Disclose and seek prior approval of outside activities
All University of Oregon employees are required to disclose and seek prior university approval for certain interests and activities with outside entities, including for example, conducting research and development through an outside entity (see https://provost.uoregon.edu/coicoc for more details). Outside activities involving foreign entities that meet the definition requiring disclosure and prior approval must be disclosed through this process. We strongly recommend that employees err on the side of caution if unsure whether any given activity requires approval, especially when considering engagement in outside activity with a foreign entity. You can find more information about disclosure and approval here: https://provost.uoregon.edu/coicoc.
If you discover you may be already be conducting an outside activity that may require disclosure and prior approval, simply contact email@example.com and we will work through the disclosure and approval process with you. Note that over the course of the coming year, more procedures will be developed to streamline the disclosure process.
Questions regarding UO’s COI and COC disclosure requirements: firstname.lastname@example.org.
3. Conduct due diligence and seek assistance before considering foreign contracts, payments, or participation in talent programs
Some foreign universities and companies have been seeking private relationships with faculty at US Universities. These programs may provide appointments, labs, or startup funding at foreign universities or companies. While in some cases, these offer an opportunity to engage in productive collaborative research, in other instances, the foreign entity may require the researcher to sign a contract that includes intellectual property provisions, effort requirements, hiring obligations at US institutions, and other provisions that may place investigators at odds with federal funding requirements, university policy, state, or federal law. Before signing any such agreement, please contact email@example.com to disclose your plans and determine if prior approval can be given. In addition, seek outside counsel; the university will not be able to provide legal advice if you are considering personally signing any document.
Questions about talent programs: firstname.lastname@example.org
4. Disclose inventions and other intellectual property
PIs with federal funding have a responsibility to report all resulting inventions prior to publication and ensure the federal government receives a non-exclusive license for government purposes to the data, content, code and other intellectual property created under an award. Working with foreign entities without properly scoping intellectual property rights can result in a PI losing: a) access to use intellectual property needed for their future research; b) the ability to obtain intellectual property rights in their work; or c) the ability to provide rights to intellectual property granted by the PI and university to a sponsor.
Questions regarding intellectual property developed under grants and contracts: email@example.com
5. Refrain from signing MOUs and other contracts with foreign entities without first contacting SPS
Individual faculty and staff are not permitted to sign any contracts, grants, agreements, or memoranda of understanding with a foreign entity for activities associated with work at the University of Oregon. Such agreements should generally be treated as sponsored projects and routed through Sponsored Projects Services. If you are considering engaging in outside activity with a foreign entity, please contact firstname.lastname@example.org.
As with all purchases of goods and services, procurement involving a foreign entity should be managed through Purchasing and Contracting Services.
Questions about foreign MOUs, grants, and contracts: email@example.com
6. Appropriately credit all funding sources and foreign collaborators in publications
All funding sources should be credited in publications. Authors should also ensure that information about the institutional affiliations in publications is accurate and complete. Both funding agencies and journals provide guidelines for information to be included in publications.
If sponsored research results in a publication involving foreign components (such as via a co-author at a foreign institution), some agencies, including NIH, require that those components also be reported in annual and final progress reports.
7. Book international travel through Concur
All university travel, both domestic and international, must be entered into Concur. This includes travel reimbursed by outside entities if that travel is done in the course of work at the UO. This allows the university to know where employees and students are so that the institution can provide assistance in the event of a natural disaster, political crisis or other emergency. The Concur system has also been set up to notify both the traveler and travel administrator at the time of booking if the travel is to a sensitive country, which may require additional approvals by the export control officer.
Travel to sensitive countries – travel to high-risk, sanctioned or embargoed countries (such as Iran, Cuba, or North Korea) can trigger export control regulations. Travelers may need an export control license before traveling to these countries. Questions regarding export controls: firstname.lastname@example.org.
Computer and other device security while traveling – employees traveling to some certain countries (e.g. China, Iran, North Korea, and others) with high risk of having information on their equipment breached and their device used as a vector to get into the university network upon return. Instead of bringing their regular devices to these countries, employees traveling to sensitive countries should seek a loaner device.
To participate in the device loaner program: email@example.com.
Travel registration and insurance – UO travelers who book through Concur have a comprehensive insurance plan that includes coverage and services such as out-of-country medical benefits, medical evacuation, 24-hour travel, safety and security assistance services, repatriation, etc. Insurance is accessed by booking travel in Concur.
In addition, it is strongly recommended that international travelers also register their travel with the Department of State’s Smart Traveler Enrollment Program (STEP). Enrollment in this program provides travelers with the latest security updates and makes it easier for the nearest U.S. embassy or consulate to contact you in an emergency. You can find more information about STEP here: https://step.state.gov/step/.
Questions regarding travel registration and insurance: firstname.lastname@example.org.
8. Follow these guidelines when bringing international visitors to campus.
Courtesy Appointments – All non-U.S. citizens are screened before approval to determine if an export license is necessary. Questions about courtesy appointments: email@example.com.
Short-term visitors from sensitive countries – Before a visitor from sensitive and embargoed country arrives on campus, please contact firstname.lastname@example.org to determine if there will be any restrictions placed on their visit.
Delegation Visits – The State Department requires that embassy delegation visits from certain countries will need to be registered with the State Department prior to their visit to campus. Questions regarding registering for delegation visits: email@example.com.
9. Follow these guidelines for international shipping.
International shipping of potentially controlled materials to high-risk, sanctioned or embargoed countries can trigger export control regulations and result in significant financial and criminal penalties. All UO employees should consult with the export controls office prior to conducting international shipping to determine whether an export license is necessary prior to shipping abroad.
All biological and other materials (which may include, but are not limited to: chemical compounds, genetic materials, mouse models, and some computer software) transferred must have a material transfer agreement and clearance from export controls prior to shipping. Please contact firstname.lastname@example.org to execute such a materials transfer agreement and email@example.com to determine if an export control license is required.
Unmodified and non-pathogenic biological materials collected under approved UO sponsored research agreements are not required to obtain additional export control or IPS review for shipping.
10. Understand and follow host country requirements when conducting human subjects research internationally.
When conducting human subjects research in foreign countries or with foreign collaborators, it may be necessary to secure additional approvals to comply with U.S. and international regulations and laws. In addition, anyone who is engaged in research involving human subjects must complete a conflict of interest form and disclose any identified conflicts to the Institutional Review Board (IRB). Such disclosure should include foreign financial interests or collaborations.
Questions regarding human subjects research requirements: firstname.lastname@example.org.
11. Maintain an up-to-date financial conflict of interest in research disclosure
Everyone who is responsible for the design, conduct, or reporting of sponsored research is required to annually complete a significant financial interest declaration. This declaration should be updated anytime there is a change in your circumstances. Please ensure that you fully disclose any foreign activity that meets the criteria in the policy. You can update your disclosure at http://orsa.uoregon.edu/epcs.
Questions regarding financial conflict of interest in research disclosure requirements: email@example.com.
12. Work with Division of Global Engagement to obtain international employee and student visas
The Division of Global Engagement, International Student and Scholar Services can assist UO departments with H1-B Employee Sponsorship, J-1 Visiting Scholars, and alternate types of visas.
Questions regarding international employee relations: firstname.lastname@example.org.
The purpose of this section is to provide links to recent federal agency guidance, rule changes, and announcements related to foreign research collaboration.The National Defense Authorization Act, signed in August 2018, included Sec. 1286, which stated that “The Secretary of Defense shall, in consultation with other appropriate government organizations, establish an initiative to work with academic institutions who perform defense research and engineering activities…to limit undue influence, including through foreign talent programs, by countries to exploit United States Technology…”
Department of Defense (DOD)
March 20, 2019: A DOD-issued memo outlining disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements
October 10, 2019: A DOD-issued memo providing additional updates on efforts to address this evolving issue
Department of Energy (DOE)
June 7, 2019: Directive DOE O 486.1 is issued, mandating that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs” on new DOE contracts and subcontracts. DOE is expected to issue a separate policy directive to implement the requirement on DOE grants and cooperative agreements.
National Institutes of Health (NIH)
August 20, 2018: NIH Dear Colleague LetterNIH Director Francis Collins issued a Foreign Influence Letter to Grantees and testified to the Senate Health, Education, Labor, and Pensions Committee regarding concerns about systematic programs of foreign influence in U.S. research.
December 2018: Initial report from NIH Advisory Committee to the Director
July 10, 2019: NOT-OD-19-114 issued.A reminder for research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.” Other Support includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”
National Science Foundation (NSF)
July 11, 2019: NSF Dear Colleague Letter: Research ProtectionThis letter outlines NSF plans to “address emerging risks to the nation’s science and engineering enterprise.”
December 6, 2019: NSF-Commissioned JASON ReportThis report was intended to enhance NSF’s understanding of the threats to basic research posed by foreign governments that have taken actions that violate the principles of scientific ethics and research integrity. With the official receipt of the report, NSF will now begin the process of analyzing its findings and recommendations.
Effective June 1, 2020: New NSF Proposal & Award Policies & Procedures Guide (PAPPG, NSF 20-1)
Office of Science and Technology Policy (OSTP)
September 16, 2019: Letter to the U.S. research community regarding research security matters
Federal tracking of new technologies
On February 11, 2019, the President signed an Executive Order launching the American AI initiative, requiring federal agencies that support the development of artificial intelligence to adhere to objectives that will enhance the nation's standing in the field.
On February 10, 2020, the Department of Education published a proposed information collection to ensure institutions of higher education report gifts or contracts with foreign sources.