International Collaborations and Activities
Introduction and Background
As a land-grant and top-tier research institution, Oklahoma State University (OSU) is committed to research, scholarship, and creative activity and recognizes the value of international collaborations in world-class research. The university is also committed to transparency and compliance with all federal and state policies regarding international research collaborations.
In extreme cases, failure to disclose all relationships could result in the termination of funding for a project and potential ineligibility for future funding. Noncompliance can also threaten not only the funding for individual projects, but overall funding for the University and from federal appropriations as a whole.
In an effort to provide guidance and consistency to employees, the following set of procedures has been developed to guide activities relevant to international activities, collaborations, involvements, travel, and visitors.
Protecting Yourself and OSU
1. Disclosing plans to have foreign visitors to OSU
Every year, Oklahoma State University welcomes visiting researchers, scholars, collaborators, and student from all around the world. These visitors enrich our campus community by bringing additional perspectives to academic and research endeavors and strengthening ties with institutional partners worldwide.
OSU is committed to complying with all U.S. laws and regulations, including keeping record of international visitors on short-term tourist visas (B-visas) to the university. Prior to finalizing the itinerary/plan and at least two weeks prior to the arrival of a short-term international visitor or delegation on the OSU campus, the hosting department needs to complete and submit the International Visitor Registration Form
International visitors whose visit is being funded by OSU should also have an international travel request submitted and approved prior to booking travel on their behalf.
For more information, please visit this page with the School of Global Studies and Partnerships.
2. Disclosing travel to foreign countries during which professional activities will/may occur (whether funded professionally or funded personally)
Personally-funded international travel: Regardless of who is funding the travel (i.e. personal or professional), when OSU employees travel internationally and any portion of the visit involves work-related business (or exploring opportunities for future work-related business), the employee needs to obtain and document approval of the international travel. OSU is working on a centralized electronic method to seek and document these approvals. In the meantime, faculty should seek approval from her/his Department Head. Before providing and documenting approval, Department Heads should bring any questions or concerns to the relevant Associate Dean for Research who will consult with others (e.g., Dean or VPR office) as needed.
Professionally-funded international travel: All OSU faculty, staff, and students traveling internationally on official OSU business are required to request travel approval via OSU procedures. This includes travel funded fully or in part by OSU. Detailed guidance regarding foreign travel can be found here.
3. Upholding confidentiality obligations related to serving on scientific review panels
Federal funding agencies have discovered that information gleaned by individuals during a review panel process has made its way to foreign actors/entities, resulting in the theft of intellectual property.
Federal funding agencies receive proposals in confidence and protect the confidentiality of their contents. For this reason, OSU faculty members serving on scientific review panels must not copy, quote, or otherwise use or disclose to anyone, including your graduate students or post-doctoral or research associates, any material from any proposal you are asked to review.
4. Utilizing proper signature authority and establishing MOUs or MOAs with foreign entities
Depending upon the nature of the agreement, institutional signatory authority is held only by the President, Provost, Vice President for Research, and in some cases the Dean of the School of Global Studies and Partnerships. No other persons are authorized to sign MOUs and MOAs.
Oklahoma State University's School of Global Studies and Partnerships facilitates the process of establishing official agreements with foreign institutions (e.g., government agency, business, research center, consortium, or university), and they will provide MOU/MOA templates or models. You may also refer to the university's guidance document for international agreements.
For international sponsored program agreements, please work with your College's research office.
5. Disclosing foreign affiliations, other support, and non-U.S. performance sites within proposals
In the context of sponsored programs, all foreign affiliations (paid and unpaid) must be disclosed on proposals, progress reports, and final technical reports.
NIH offers a good model and guidelines for this. For example, adding a new foreign component to an NIH grant requires NIH prior approval (NIH's Grants Policy Statement Section 184.108.40.206). Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended". The definition of “foreign component” (which can be found here) may include a large number of collaborative activities, including “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.” Other sponsors have similar requirements to disclose foreign components.
There are multiple ways in which foreign components can be disclosed. For example...
- Identifying a “foreign component” in a grant application;
- Listing a “non-U.S. performance site”;
- Identifying foreign relationships and activities in a biosketch;
- Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.
Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact Central Sponsored Programs Administration to have the error corrected.
6. Disclosing external (including international) financial interests and conflicts of commitment
Personal financial interests received from any international entity (e.g., government, non-profit, for-profit, university/academic) must be disclosed to the university, per the OSU Conflict of Interest in Sponsored Programs policy via the Conflict of Interest Disclosure Form. This includes all personal remunerations/financial interests that appear to be related to your institutional responsibilities. Examples include, living allowances; “consulting” to be a PI on a grant; honorariums; personal activities during summer months for 9-month appointments. NIH has also issued guidance that addresses different examples and the reporting requirements.
If you are unsure whether a particular interest or activity should be disclosed, please contact the university's Research Compliance office at email@example.com. For assistance completing your form, please contact firstname.lastname@example.org.
7. Disclosing inventions
One of the major concerns regarding undue foreign influence on US research, is that some US-developed intellectual property (IP) has been diverted to foreign institutions. Whether inadvertently or intentional, it is critical that IP or other legal rights NOT be diverted from OSU to a foreign party. The best way to protect against this possibility is to immediately disclose any invention (i.e., any innovation that even might have commercial value as intellectual property) to the proper OSU authorities. All inventions by OSU employees should be disclosed promptly to Cowboy Innovations: Submitting an Invention Disclosure.
8. Understanding Export Controls requirements (whether the work is done abroad or domestically)
Export controls apply to many university areas: hosting international visitors, research, international travel, and training foreign nationals, and export control laws and regulations have seen extensive revisions in recent years.
It is unlawful to send or take export-controlled technology out of the U.S. or to disclose, orally or visually, or transfer export-controlled technology to foreign nationals inside or outside U.S. territory without government approval. Technology is defined as “specific information necessary for the development, production or use of a product.” This applies to tangible technology such as field equipment, computers, smart phones, etc. and also includes software, source code, object code, technical documentation, etc. that you may carry with you or ship abroad for your professional use. Any of these items may be subject to export control regulations. For specifics of what is allowed on aircraft to and from certain countries, you should review the latest information on the U.S. Department of State’s Travel site.
There have been recent changes regarding laptops and other electronic items allowed on aircraft to and from certain countries. You should review the latest information on the U.S. Department of State’s Travel site.
Understanding the laws and regulations and how they apply can be confusing. Each item and/or project must be considered independently of others. Ivory Chandler, OSU's Export Controls Officer, is available to help you understand export control regulations. You will find more information by visiting the Central Sponsored Programs Administration (CSPA) website on Export Controls which provides links and more details on this issue.
9. Disclosing and screening collaborators against restricted parties lists
Restricted parties lists (also called denied party lists) are lists of organizations, companies, or individuals that various U.S. agencies have identified as parties with which we cannot do business. There are several reasons why a person or company may be added to a restricted party list. For example, they may have a history of corrupt business practices, or they may otherwise pose a threat to national security. Restricted party screening refers to the process in which OSU checks a potential business partner against one or more of the restricted party lists to ensure they are not doing business with a restricted party.
At OSU, screening occurs for various reasons in different offices. College research offices screen when a federally sponsored project includes payments to sub-awardees and/or individuals not employed by the university; Central Sponsored Programs Administration screens international sponsors, individuals involved in controlled research, and by request; and OSU Purchasing screens vendors.
Frequently Asked Questions
What is OSU doing to address the issue?
OSU is reviewing the National Science and Technology Council (NSTC)'s Joint Committee on the Research Environment (JCORE) set of recommendations for strengthening the security of research activity (published January 2021).
OSU is in the initial stages of forming a campus-wide working group to discuss how to implement best practices.
Can I add disclosures to current projects or proposals?
Yes! The PI should contact Central Sponsored Programs Administration to have disclosures added.
Do I need to make disclosures related to the work of my international graduate students?
In most cases, there is no reason to disclose participation of international students or postdocs on sponsored research, especially if all such work will be performed in the U.S. However, classified and export controlled projects will be subject to foreign national restrictions. Additionally, there may be cases where working with a student or postdoc might be considered a “foreign component,” if that student or postdoc is performing effort in a foreign country. NIH defines a foreign component as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended."
Federal Agency Communications Regarding Research Security and Foreign Influence
- View a partial list of communications from several federal agencies...
- NIH Protecting U.S. Biomedical Intellectual Innovation—February 4, 2021
- Executive Office of the President, Joint Committee on the Research Environment (JCORE) of the National Science & Technology Council: Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise—Jan 21, 2021
- Executive Office of the President: Presidential Memorandum on U.S. Government Supported Research and Development National Security Policy—January 14, 2021
- United States Government Accountability Office (AKA: Grassley Report)—December 2020
- The White House Office of Science and Technology Policy—June 23, 2020
- DOD Letter to Universities and Research Centers—October 10, 2019
- Letter to U.S. Research Community from Office of Science and Technology Policy—September 16, 2019
- NSF Dear Colleagues Letter: Research Protection—July 11, 2019
- NIH Promoting Objectivity in Research Guide Notice—July 10, 2019
- Department of Energy Directive Regarding Foreign Talent Recruitment Programs—June 13, 2019
- Department of Defense Memo – Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies—March 20, 2019
- NIH Dear Colleagues Letter—August 20, 2018
- NIH Financial Conflict of Interest Guide Notice – Investigator Disclosures of Foreign Financial Interests—March 20, 2018
It protects everyone’s interests to have international relationships disclosed and vetted to determine if there are any potential conflicts of commitment, duplications of research, and/or diversion of intellectual property in the performance of federally-funded research.
As noted above, in extreme cases, failure to disclose international collaborations could result in direct consequences for the individual researcher, including termination of funding for a project and potential ineligibility for future funding. Noncompliance also threatens overall funding for the university.
How to get assistance
- Faculty members are encouraged to contact their Associate Dean for Research for an initial discussion regarding any foreign affiliations related to their research efforts.
- Questions regarding individual grants and contracts can be directed to Central Sponsored Programs Administration.
- Additional information regarding export control compliance can be found here .