OCGA: International Research Collaborations

Last Updated: September 30, 2021 4:25:41 PM PDT

Learn about engaging in International research collaborations at UC San Diego.

International/Foreign research collaborations at UC San Diego: Learn about anticipating and working with foreign/international sponsors and collaborators, including federal regulations associated with such collaborations.

International Research Collaborations

International engagement refers to the scientific research collaborations with transparent and reciprocal exchanges for mutual benefit of parties from different countries. International research collaboration can take many different forms:

accepting an invitation to attend or present work at an international conference
receiving a fellowship or participating in a scholarship program sponsored by a foreign institution
a multi-site clinical trial with participants in Europe
hosting a visiting research from a University in Japan
establishing an affiliation agreement with a partner in Australia.

Faculty Disclosures on International Collaborations

International collaboration is very important. However, it is also important to be aware of disclosure requirements and compliance procedures UC San Diego has in place to protect faculty members. Recent reports and guidance from the federal government have highlighted the importance of disclosing financial interests, affiliations, activities, and relationships with foreign entities.

Risks of Non-Disclosure

There are risks to US science and security, and to research integrity through:

Conflicts of Interest / Commitment
Over-Commitment
IP and Data Theft
Diversion of IP in grant applications
Export Control violations
Integrity of Peer Review process

Guidance from Federal Sponsors

Federal agencies are increasing the requirements for principal investigators (PIs) to disclose their foreign sources of support and to disclose how those sources are being used to support the proposed and related research. UC San Diego researchers who receive federal funding for research activities need to be aware of these requirements and how each federal agency interprets what is meant by foreign sources of support.

Some of these federal agency requirements have been in place for some time and others are either new or are being interpreted differently and/or more rigorously than in the past. Below are the different sponsor-specific disclosure requirements and resources to contact if you have any questions.

NIH

View the International Research Portal for more information on requirements for international research projects.

The National Institutes of Health issued the following guidance:

According to NIH policy foreign influence includes:

Collaborations with investigators at a foreign site anticipated to result in co-authorship;
Use of facilities or instrumentation at a foreign site; or
Receipt of financial support or resources from a foreign entity.

Determine if there is a "Foreign Component"

NIH requires recipients to determine whether activities it supports include a foreign component, defined as the existence of any "significant scientific element or segment of a project" outside of the United States.

Significant Element or Portion

If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient will need to determine if the activities are considered significant. If an activity does not meet the definition of a significant element or portion because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator/researcher, it must be reported as Other Support (NIH.gov).

Outside of the United States

Identifying foreign component involves the following, whether or not NIH grant funds are expended:

performance of work by a researcher or recipient in a foreign location
performance of work by a research in a foreign location employed or paid for by a foreign organization

NIH applicants must:

List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments.
Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation.
Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources must be reported.
Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.

Visiting Scholars

A Visiting Scholar working on the project as Key Personnel will trigger the need to submit their Biosketch and Other Support in the "Personnel Updates" section of the RPPR.

Visiting Scholars on Proposals: A visiting scholar should submit other support documentation, if he/she will contribute in any way to the research set out in the scope of work. Submit in the format required by the sponsor and at the time the sponsor requires.
Visiting Scholars on On-going Projects: You do not need to receive prior approval from NIH for a visiting scholar in your lab to work on a project. However, keep these requirements in mind: Report all participants on a project within your progress report. This section also requests whether the individual’s primary affiliation is with a foreign organization.

Resources

COGR Other Support Guidance: Commentary on Disclosing Other Support to NIH (PDF)

DOD

Recent Broad Agency Announcements (BAAs) from Defense agencies such as DARPA are seeking more detailed disclosures on the sources of support for Principal Investigators and other Key Personnel. National Security Impact Statements are now features of these proposals, with particular attention being paid to plans to transfer technology to U.S. industry and disclosures on whether technologies developed under the contract will be transferred to foreign entities. Proposers are also instructed to disclose any prior instances of transfer of technology to foreign entities.

Excerpt:

Proposers shall submit the below information for all key personnel, whether or not the individuals' [PI and Co-PI] efforts under the project are to be funded by the DoD:

A list of all current projects the individual is working on.
Any future (pending) support the individual has applied to receive, regardless of the source.
Title and objectives of each of these research projects.
The percentage per year each of the key personnel will devote to the other projects.
The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
Name and address of the agencies and/or other parties supporting the other research projects.
Period of performance for the other research projects.

See March 20, 2019 memo for details.

DoD indicates that failure to submit this information may cause the proposal to be returned without further review. DoD also reserves the right to request further details from a proposer before making a final determination on funding the effort.

DoD Frequently Asked Questions

Q: Do I have to report all of my projects, even if they are unrelated to my DoD-funded proposal?

A. Yes. The memo requests a list of all current projects that key personnel are working on, “whether or not the individuals’ efforts under the project are to be funded by the DoD”. We encourage PIs to be transparent in their disclosures, and include all projects funded by gifts, grants or contracts, as well as unfunded projects or collaborations that require disclosure on Conflict of Commitment reporting.

Q: Do I need to disclose US-based industrial support?

A. Yes. The memo does not distinguished between foreign and domestic sources of corporate support. In the spirit of complete transparency, philanthropic gift support as well as industrial alliances and contract and grant support from corporate entities should be disclosed.

Q: I am responding to an NFO that was issued prior to April 19, 2019. Do these rules still apply?

A. No. The March 20, 2019 memo only applies to new NFOs after April 19, 2019. Note that the memo only applies to research and research-related educational activities.

DOE

The U.S. Department of Energy issued a directive on June 7, 2019 that prohibits DOE and contractor personnel from participating in talent recruitment programs operated by certain foreign countries. While this directive does not directly affect faculty who are unaffiliated with DOE or its National Labs, it illustrates a pervasive concern across the federal agencies. DOE is still developing guidance to its community of university performers.

See Directive Foreign Government Talent Recruitment Programs [DOE O 486.1] (DOE.gov) June 7, 2019 for details.

NSF

Researchers whose projects are supported with federal funding should update their Current and Pending Support (nsf.gov) documentation, and should include all sources of support foreign or domestic.

Include all financial resources and commitments of time even if no salary support is received.

The National Science Foundation Director sent out a Dear Colleague Letter: Research Protection clarifying numerous policies on July 11, 2019.

Among the key points are:

NSF is proposing to use an electronic format for submission of biographical sketches, including disclosure of all appointments.
NSF has commissioned a study to assess risks and recommend possible practices for NSF and its awardee organizations to achieve the best balance between openness and security of science.
NSF is issuing a policy making it clear that NSF personnel and IPAs detailed to NSF cannot participate in foreign government talent recruitment programs.

NASA

NASA Restrictions on Funding activities NASA Grant Information Circular GIC 12-01 (February 9, 2012)

Partner Offices

While OCGA handles some international agreements, we may consult with, or refer you to one or more of the following offices/teams:

Office of Innovation and Commercialization (OIC) - OIC manages UC San Diego's intellectual property portfolio on behalf of investigators and researchers. An example of engaging with OIC on an international research project might involve licensing a UC San Diego technology to an international commercial partner.
Office of Postdoctoral and Visiting Scholar Affairs (OPVSA ) - OPVSA oversees appointments, training, services and benefits for postdoctoral researchers at UC San Diego. They also coordinate appointments or affiliations for international scholars and scientists visiting UC San Diego from other universities, research institutions, companies or government agencies.
Graduate Division - Grad Division oversees appointments of international predoctoral graduate students (PhD, MA, MS, MBA, MD) pursuing research at UC San Diego related to a degree program at their home institution.
Office of International Affairs (OIA) - OIA works with UC San Diego stakeholders in support of global research and education, by serving as a resource for academic divisions, research units and professional schools on executing their international strategy, including International Memoranda of Understanding (MOU) and Affiliation Agreements.
Academic Personnel Services (APS) - APS is responsible for recruitment, compensation, and other HR related activities for international academic personnel.
Export Control - Export Control identifies and manages export risks and provides export licenses in support of the research activities of university faculty, staff, and students.
International Shipping - Conducting international research may involve foreign shipment of materials or research supplies. The International Shipping team works closely with the Export Control Office at UC San Diego to mitigate risk and ensure compliance with international freight regulations.
UC-wide Outside Activity Tracking System (UC OATS) - A multi-campus Conflict of Commitment system that facilitates the collection, review, approval, and reporting of faculty outside professional activities for the adopter campuses.
Office of Research Compliance and Integrity (RCI) - RCI is responsible for broad oversight, resources and education for the integrity and compliance issues relating to the conduct of research in the areas of Conflict of Interest, Dual Use of Research Concern, Export Control and Facility Security, Institutional Animal Care and Use, Research Misconduct, ClinicalTrials.gov, Good Clinical Practices (GCP), and Responsible Conduct of Research (RCR).