International Research & Scholarship Guidance

1. Identify foreign components on federally sponsored research proposals, progress reports, and final technical reports. (NIH) 

Per the National Institutes of Health (NIH), the following activities are considered a foreign component:

• Research at a foreign site involving human subjects or animals;
• Extensive foreign travel for the purpose of data collection, surveying, sampling, and similar activities; and
• Activities that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country (e.g., through an impact on another country's wildlife, population, or environment).

The NIH may also consider the following activities as a foreign component:

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

In the NIH grant application forms, a foreign component may be identified by:

• Indicating "yes" to the "activities outside the US/partnerships with international collaborators" checkbox on the Research & Related Other Project Information form;
• Listing a non-US project/performance site location;
• Identifying foreign relationships/activities in the biosketch; and
• Identifying foreign financial support in the Other Support documentation.

2. Report all resources for research, including those from foreign entities, in the "Current and Pending Support/Other Support." (NSF, NIH)  

This includes any research support you receive.  Examples include, but are not limited to:

• Financial support from a foreign award for work conducted outside the U.S. and/or outside the investigator's U-M appointment, whether received by an investigator or another organization;
• Equipment or research material provided by a foreign organization;
• Consulting relationships relating to your expertise;
• Work with visiting personnel who are supported by a foreign organization; or
• Funds received from a foreign recruitment program (e.g., China's Thousand Talents Program or other "Talents Programs").

Per NIH, “Other Support” includes all foreign and domestic resources made available to a researcher in support of or related to their research, regardless of whether or not the resources have monetary value.  Examples of other support include U-M internal funding, startup packages, and consulting.  Other support is reported to NIH prior to the award activation as part of the "just-in-time" process, as well as in progress reports submitted to NIH.  Pending applications for support should be reported as part of the "just-in-time" process, but such support does not need to be identified in progress reports until it is committed by the sponsor.

For National Science Foundation (NSF) awards, financial and non-financial resources made available for research should be reported.  Per the NSF, "Current and Pending Support" includes "all current project support from whatever source" and "all other projects or activities requiring a portion of time [i.e., commitment] of the principal investigator (PI) and other senior personnel must be included, even if they receive no salary support from the project(s)." (NSF Grant Proposal Guide, Chapter II)

3. Include foreign affiliations in your Biosketch and in your NIH Other Support document.  This includes relevant positions such as appointments and/or visiting scholar affiliations held at foreign institutions. Currently, NIH is advising that any foreign affiliation should be disclosed as "relevant."

For Existing Awards

The NIH requires its prior approval whenever a significant part of a project will be performed outside of the United States, regardless of who is doing or whether or not the work is funded.  To add/amend a foreign component on an existing NIH award, use the "Request Action/Modification" activity in the eResearch Proposal Management (eRPM) system to upload a "Foreign Justification" document for ORSP to submit to the NIH for consideration.  If the NIH approves the foreign component, include the Foreign Justification document in the annual (or final) Research Performance Progress Report (RPPR).

Investigators who have responsibility for designing, conducting, and reporting of PHS-funded research are required to disclose all outside interests, activities, and relationships that are associated with their U-M responsibilities or area of scholarship, including those of their spouse, domestic partner, or dependent (Policy for Identification and Management of Conflicts of Interest in Research and Technology Transfer).  These disclosures are reviewed to determine if the activity is related to, and may unduly influence, the U-M research, resulting in a conflict of interest. 

This includes disclosing, for example:

• Appointments and/or visiting scholar affiliations at foreign institutions;
• Participation in, as well as payments or items of value received from foreign recruitment programs (i.e., "Talents Programs"); and 
• Travel reimbursements from foreign institutions.

See the Outside Interest Disclosure Process website for more information about disclosure requirements and processes.

While M-Inform (the University's outside interest disclosure system) asks you to report the amount of time you expect to devote to an outside interest, activity, or relationship, your school/college may have additional requirements regarding the reporting of conflicts of commitment. Review your school/college policy on the Provost's COI/COC website.

If you have an NIH award, ensure that any corresponding reduction in effort or absence for three (3) months or more in a single period under the NIH grant is approved by U-M and NIH, as required.  Supervision or performance of work under an NIH grant while engaging in separate activities outside the United States may create a foreign component and require NIH prior approval. 

If you have a collaborator who is going to conduct a part of your NIH-funded research project outside of the United States and that research may result in a co-authored publication, it is important that you obtain prior approval from the NIH for the collaboration (i.e.,  a foreign component).  Any publication that subsequently arises or results from the collaborative research must be reported to the NIH in progress reports. 

The publication itself should also acknowledge NIH support and any support from a foreign entity, individual, or government (if applicable), as well as clarify whether any of the research was performed outside of the United States.

It is an institutional best practice to conduct the restricted party screening (RPS) process before entering into international collaborations in order to confirm there are no restricted entities/individuals involved. 

U-M central offices, such as the Office of Research and Sponsored Projects (ORSP), Procurement, Office of Technology Transfer (Tech Transfer), and the Office of University Development, conduct RPS as part of their standard business processes (e.g., ORSP runs RPS on proposed sponsored research).  Some schools/colleges, such as the College of Engineering, run RPS prior to authorizing visiting scholars and other visitor access to university facilities.

Prior to initiating research-related activities (e.g., travel, shipping equipment or physical items overseas, giving presentations at international institutions), you are expected to request restricted party screening from the U-M Export Controls Office (exportcontrols@umich.edu).  For details on how to request RPS and additional examples, see the Restricted Party Screening (RPS) website.  

U-M is pleased to work with benefactors from around the world to increase private support for important research and programs.  In doing so, we follow a careful process to review the sources of philanthropic funding and determine what, if any, expectations may be attached to such funding.

Per U-M SPG 602.02 Gift Acceptance, only the University President, Chancellors, Chief Financial Officer (CFO) and the CFO's written designee (e.g., Vice President for Development) have the authority to accept private gifts and donations from individuals, corporations, foundations, and associations. Report all gift solicitations from domestic and international sources to the Office of University Development or the development office within your school, college, or unit. 

For questions related to international conversations regarding gift or donations, please contact the International Giving and Engagement team within the Office of University Development.

Faculty and students travelling internationally for research purposes, including attending conferences or participating in international research collaborations, must comply with the U.S. Export Control regulations.  It is advisable to report your travel plans weeks before you leave by using the Faculty & Staff Travel Registry or the Student Travel Registry (Compass), as applicable, to allow enough time to work with the U-M Export Controls Office to determine what, if any, protections may be required based on the location of the travel and/or the technology/data you are taking with you.

For details, see the International Travel & Export Controls website.

All employees have an obligation to report intellectual property and any improvements to existing intellectual property promptly to the U-M Office of Technology Transfer (Tech Transfer) via an invention disclosure, per U-M SPG 303.04 Technology Transfer Policy.

See Tech Transfer's Submit Your Invention website for more information on the invention disclosure process.

Section 117 of the Higher Education Act (HEA) of 1965 requires that institutions of higher education participating in Title IX student assistance programs must report incoming gifts or contracts from a foreign source that, alone or combined, have a value of $250,000 or more for a calendar year.

See the HEA 117 Reporting FAQ for more information about the University's disclosure requirement and reporting processes.