International Engagements

The following general guidance is provided to assist Ohio State researchers regarding what they have to disclose, where they have to disclose, and who to contact for assistance.

General Guidance for Principal Investigators 

• Read sponsor guidelines, Funding Opportunity Announcements (FOAs), proposal questions, and award documents carefully to ensure that you and other project personnel are correctly answering the questions that address foreign engagements, foreign affiliations, and Foreign Components and collaborations, as required by the sponsor.
• Review current projects to ensure that all locations outside the United States where significant scientific activities are performed have been disclosed in the proposal or via a prior approval request to the sponsor, and through progress reports and final technical reports. It is important to:
  • Obtain prior approval when adding a Foreign Component to an existing federal award.
  • Include a clear description of all Foreign Components for any new proposals.
• Review each funding application to ensure that all resources available in direct support of an individual’s research activities are disclosed as required by federal sponsors and ensure that all new resources acquired that are available in direct support of an individual’s research activities are reported in progress reports and in the final reports as required by federal sponsors.
• Err on the side of transparency when considering or reporting any foreign activity. When in doubt, disclose.
• Review agency definitions to verify that your interpretation of your sponsor’s Terms and Definitions is correct. The Office of Sponsored Programs and your sponsor’s program and grants management staff can be contacted with questions about definitions.
• Report inventions and disclose Intellectual Property that may need to be protected.
• Ask the Office of Sponsored Programs any questions you might have concerning activities being proposed that will take place outside the United States and identify all foreign countries where research activities will be conducted.
• Only cite funding in publications that specifically supported the work in the publication. Do not cite any unrelated financial support in publications.
• Only cite publications in progress reports and final reports that were specifically supported and are directly related to the award. Do not cite funding that is not related or that did not support the publication.

NOTE: This issue is fluid. These pages and resources will be updated as additional guidance becomes available.

A ‘Foreign Component’ is defined by the NIH as: “The performance of any significant scientific element or segment of a project outside the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”

Activities that meet this definition (per NIH) include, but are not limited to:

• the involvement of human subjects or animals at a foreign location;
• extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities at a foreign location;
• collaborations at a foreign site anticipated to result in co-authorship;
• use of facilities or instrumentation at a foreign site;
• receipt of financial support (including travel support) or resources from a foreign entity; or
• samples provided to a foreign entity for additional award-related research.

Other Support, sometimes referred to as “current and pending support” or “active and pending support” is defined by NIH as “… all financial resources, whether Federal, non-federal, commercial or organizational, available in direct support of an individual’s research endeavors, including, but not limited to, research grants, cooperative agreements, contracts, or organizational awards. Other Support does not include training awards, prizes of gifts.

Other Support is distinct from a Foreign Component in that Other Support is independent of location, whereas a Foreign Component specifically refers to activity conducted outside the United States.

It is important to understand that federal agencies closely review Other Support disclosures to ensure that no time commitment or budgetary overlap exists, and that there is no scientific duplication.  

As defined in Ohio State’s Outside Activity and Conflicts Policy, a conflict of interest exists if financial interests or other opportunities for tangible personal benefit may exert a substantial and improper influence on an employee’s professional judgment in exercising any university duty or responsibility, including designing, conducting, or reporting research. “Employees” include faculty, staff, administrators, and others. A conflict of interest is not an accusation and does not imply that an employee’s judgment has been compromised.

Managing Conflicts of Interest requires disclosure of the source and amount of all outside personal income that is reasonably related to a person’s university responsibilities.

According to the Outside Activity and Conflicts Policy, a “Conflict of Commitment exists when external or other activities are so substantial or demanding as to interfere with the individual’s teaching, research, scholarship or service responsibilities to the university or its students.” This applies to any activities that have a reasonable potential to interfere or compete with the University’s educational, research, or service mission or with an individual’s ability or willingness to perform the full range of responsibilities associated with his or her position.”

Managing Conflicts of Commitment requires disclosure of the nature of all outside professional activities (paid or unpaid) and the amount of time spent on them.

Intellectual property (IP) refers to innovations that the law protects from unauthorized use by others. Main forms of IP include patents, copyrights, trademarks, and trade secrets. In an international research setting, IP protects the following: drugs, devices, software codes, curriculum, reagents, and data.

Faculty and staff should report inventions and disclose IP that may need to be protected through Ohio State’s Office of Innovation and Economic Development. 

The United States government regulates the transfer of information, commodities, technology, and software considered to be strategically important to the United States in the interest of national security, economic and/or foreign policy concerns. There is a complicated network of federal agencies and inter-related regulations that govern exports collectively referred to as “Export Controls.” Non-compliance with export controls can result in severe monetary and criminal penalties against both an individual as well as the university, and can result in the loss of research contracts, governmental funding, and the ability to export items.

Faculty and staff who engage in the following activities should be aware of export controls and how they apply in each case.  

• shipments to foreign locations
• procurement of goods or services from foreign vendors
• payments to foreign nationals and foreign companies
• faculty and staff travel to foreign countries
• contracting with a foreign source
• hosting foreign visitors and delegations
• foreign national access to controlled chemicals, microorganisms and toxins
• research involving specific military applications
• research collaboration with a third party appearing on a U.S. restricted party list