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Through collaborative international partnerships, researchers are pushing the frontiers of knowledge and discovery across many fields and are working together to find solutions to the world's most urgent problems. International collaborations sustain research and academic excellence. The success of these important partnerships depends on the highest standards of integrity, transparency, and trust. In working with international partners, U-M will maintain the highest standards in pursuit of new knowledge, and will comply fully with the federal regulations and guidelines that govern research and scholarship.
Amid growing federal concerns regarding "undue foreign influence" on academic research, several federal agencies have issued statements emphasizing the need for increased transparency around activities that may unduly influence research or research results. As these agencies further develop their guidelines for the required disclosure of international research collaboration and activity, U-M encourages its research community to continue following the best practices to ensure successful research collaborations with international partners.
International Collaboration Best Practices
Disclosures of international collaborations can occur in multiple areas of research and scholarship activity. U-M's current research administration and compliance processes assist researchers to appropriately identify and report their international collaborations. Expand the sections below to review the U-M disclosure guidance.
Research Funding Proposals & Awards
A foreign component is "the performance of any significant scientific element or segment of a project outside of the U.S. either by the recipient or by a foreign organization, whether or not grant funds are expended." ~ National Institutes of Health (NIH)
- 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.
- 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)
- 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).
Outside Interest Disclosure
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.
Conflicts of Commitment (COC)
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.
Restricted Party Screening (RPS)
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 (firstname.lastname@example.org). For details on how to request RPS and additional examples, see the Restricted Party Screening (RPS) website.
Gifts & Donations
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.
International Travel Registration
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.
Federal Reporting of Foreign Gifts and Contracts
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.
No. Per the National Institutes of Health (NIH), as long as the fully or partially foreign-funded student, postdoc, researcher, or visiting scholar is working exclusively within the United States, the participation is not considered a reportable foreign component.
However, any work that such an individual continues to perform under an NIH grant after leaving the U.S. would need to be disclosed and approved by the NIH as a foreign component. In addition, any support that such an individual, if key personnel on the project, receives from a foreign organization would be reportable to NIH as Other Support.
- National Institutes of Health (NIH) - "Investigators, including subrecipient investigators, must disclose all financial interests received from a foreign institution of higher education or government of another country..."
- Department of Defense: National Defense Authorization Act - "work with academic institutions who perform defense research and engineering activities...to limit undue influence, including through foreign talents programs, by countries to exploit United States technology..."
- National Science Foundation (NSF) - U.S. universities must "embrace transparency and rigorously adhere to conflict of interest and conflict of commitment policies."
- Department of Energy (DoE) - "...federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs.
As a foreign collaboration may touch upon multiple areas related to research activity - from funding to travel to invention reporting - U-M has established a cross-unit Committee on International Engagement to align the institutional knowledge across missions of the university to ensure continued academic excellence amid increasing concerns of undue foreign influence. Learn more about the International Engagement Committee charge.
In addition, U-M is collaborating with advocacy groups, such as the Council on Government Relations (COGR), the National Council of University Research Administrators (NCURA), to encourage federal agencies to clarify their foreign collaboration disclosure requirements and to provide guidance on how to meet these requirements.
For the purposes of disclosing international research activity to U-M and federal sponsors, the words "collaboration", "interest", and "affiliation" seem to be used interchangeably to describe or qualify the relationship an individual has with a foreign entity or individual. The terms are often associated with a specific activity or process, such as disclosing outside interests or reporting foreign affiliations on a biosketch.
- "Collaboration" tends to used to describe formal or contractual agreements between two parties, such as a research collaboration between investigators/study teams where both parties are working toward a common research goal.
- "Interest" tends to be used to describe external activity, especially financial-related activity (e.g., financial interests).
- "Affiliation" tends to be used to describe an association with an organization, such as employment appointments, honorary positions, and visiting scholar opportunities.
For more information about the University's disclosure requirement and reporting processes, visit our HEA 117 Reporting FAQ page.