International Engagements

The Ohio State University is committed to promoting the highest standards of ethical research and scholarly pursuits, and we are privileged and compelled to model exemplary standards of research integrity. In addition, Ohio State is committed to fostering dynamic international research collaborations and engagement, while also promoting full transparency surrounding all interactions with industry and foreign entities. It is critically important that we understand the concerns of our federal partners and how they are responding to increasing global threats to the United States’ economic and national security, and that we address the unique vulnerabilities and threats specific to the academic environment. Ohio State offers many resources and tools for faculty, staff and students to ensure that we are all properly protecting those individuals involved in international engagements while maintaining research integrity and security.

Disclosure of all outside activities and affiliations, both internally and externally, is a fundamental requirement of Ohio State researchers. Complete and accurate disclosure of all external financial interests, affiliations (paid and unpaid), activities and/or relationships that could be reasonably related to your institutional responsibilities at Ohio State should be disclosed via Ohio State’s eCOI. Proper disclosure enables the university and the federal government to identify, assess, and manage possible risks or non-compliance with university policy or federal regulations.

Ohio State’s Office of Research, through the Office of Sponsored Programs, the Office of Secure Research, and the Office of Research Compliance, has assembled the following information for the Ohio State research and creative expression community to understand the current regulatory landscape and requirements and to reinforce the varying compliance obligations.

Federal Concerns Continue Over International Activities

The United States government and federal agencies continue to communicate significant concerns about foreign governments exerting undue influence over federally-funded research and inappropriately obtaining United States technology. Government funding agencies like the National Institutes of Health (NIH), the National Science Foundation (NSF), the Department of Defense (DOD), and the Department of Energy (DOE) have each announced specific actions and provided guidance to assist universities in addressing these concerns.

Ohio State researchers can begin or continue international engagements and collaborations. However, federal funding agencies are reminding grantees that all proposed engagements with foreign entities should be reciprocal, transparent, and aligned with academically-based research terms and conditions, which promote broad dissemination of information.

General Guidance and Definitions

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.

What do I need to do?

Principal Investigators should review current projects to ensure that all Foreign Components have been disclosed and approved as required by specific sponsor. If not, contact your sponsored program officer as sponsors have varying requirements regarding disclosure.

For more information regarding Foreign Components please see  the Foreign Affiliations FAQ page.

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.  

What do I need to do?

Principal Investigators should review each funding application to ensure that all Other Support is disclosed as required by the federal sponsors.  See below for reporting details by sponsor.

As defined in Ohio State’s Faculty Financial Conflict of Interest 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 Faculty Conflict of Commitment 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 Corporate Engagement Office and its Office of Technology Commercialization.  

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

Foreign Affiliations

Under university policy, all Ohio State personnel are required to disclose to the university any foreign affiliations and receive prior approval for those activities (paid or unpaid). This includes, but is not limited to, participation in any foreign government talent recruitment program, any active or honorary titles, appointments, any student advising or mentoring, or any other relationship with a foreign entity.

If you...

…seek approval from your college/unit to participate

AND

…disclose in your biosketch and disclose participation on your eCOI disclosure

AND

…if supported by the U.S. Department of Energy, receive prior approval for participation in such programs for research they fund


Resource/Guidance
All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

    …list the position/affiliation in your biosketch

    AND

    …disclose the relationship on your biosketch and on your eCOI disclosure


    Resource/Guidance
    All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

      …seek approval from your college/unit

      AND

      …disclose the approved relationship on your eCOI disclosure


      Resource/Guidance
      All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

        Guidance & Resources for Federal Reporting

        If you...

        …obtain the required prior approval from NIH by including a Foreign Justification document with your proposal


        Resource/Guidance

        …work with your SPO to obtain the required prior approval from the NIH by submitting a request to the award’s GMS (not the program officer)


        Resource/Guidance

        …include a description of the foreign component in the annual progress report (RPPR)


        Resource/Guidance

        …if routed through Office of Sponsored Programs (OSP) list the funding on current and pending support or other support documents as required by federal sponsors

        AND

        …if not routed through OSP, seek approval from your college/unit to accept the funding and disclose the funding in your eCOI disclosure


        Resource/Guidance

        If not routed through OSP:

        …list the support on current and pending support or other support documents as required by federal sponsors

        AND

        …have the scholar complete a visiting scholar agreement, if required by your college

        AND

        …obtain prior approval for a foreign component from the NIH if the personnel will continue to work on the NIH funded project outside of the US after they leave Ohio State, and then report on the approved foreign component in the next RPPR


        Resource/Guidance

        If not routed through OSP:

        …be able to explain how the publication directly arises from the award (e.g., the award supported personnel activity that contributed to the publication, such as authorship, consulting with authors, preparing manuscripts, running analyses reported in the publication, etc.)


        Resource/Guidance

        …include only those grants that directly support the published research—don’t cite grants for which the publication may provide general scientific support but which did not directly pay for the work


        Resource/Guidance

        …ensure that sponsor prior approval was obtained for a foreign component if significant work was performed outside of the U.S.

        AND

        …be able to explain the foreign co-author’s contribution to the work/publication

        Disclosing Foreign Components and Other Support by Agency

        What to Disclose

        Where to Disclose

        When to Disclose

        Outside appointments, both paid and unpaid Biosketch Proposal, Just In Time (JIT) Request, Research Performance Progress Report (RPPR)
        International collaborations with activities performed at locations outside of the U.S., whether or not grant funds are expended Foreign Component Proposal, JIT Request, or Prior approval for active projects
        All resources available to the researcher or key personnel in support of and/or related to all research endeavors, regardless of Other Support Proposal, JIT Request, RPPR
        monetary value or location of resource
        International visiting scholars, students or collaborators in your facilities (including labs) that support your research (not key personnel) Other Support Proposal, JIT Request, RPPR

        What to Disclose

        Where to Disclose

        When to Disclose

        Outside appointments, both paid and unpaid Biosketch Proposal, Progress Report
        Research, training, and/or education carried out with international counterparts either overseas or using virtual technologies Cover sheet (list countries) and Project Description Proposal
        Funding of a foreign organization including subaward or consultant arrangements as part of award Cover Sheet and Project Description Proposal or requires prior approval for active projects
        Unfunded substantial international collaborations Facilities, Equipment and Other Resources, and letter of collaboration; Organizations that have been involved as partners with full details. Proposal, Progress Report
        All resources, including in-kind contributions, made available to an individual in support of and related to his/her research Current and Pending Support Proposal, Progress Report
        efforts, regardless of monetary value
        In-kind contributions made available to an individual in DIRECT support of the NSF project, regardless of monetary value Facilities, Equipment and   Other Resources Proposal, Progress Report

        What to Disclose

        Where to Disclose

        When to Disclose

        Outside Appointments, both paid and unpaid Biosketch Proposal
        Related sources of support Other Support Proposal

        In certain circumstances, DOE requires the university to notify DOE of any project personnel who are active in a “foreign government talent recruitment program” (FGTRP) sponsored by the People’s Republic of China, Russia, North Korea, or Iran. When necessary, Ohio State will request that personnel participating on DOE awards complete the DOE FGTRP Certification form and submit it to the Office of Sponsored Programs.

        NASA is prohibited from providing funding to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company – including Chinese universities and research institutes. NASA does not consider this a prohibition on the participation of Chinese nationals. The university must certify compliance with this restriction for each proposal and/or award. Any Ohio State personnel seeking funding from NASA must fill out the NASA Certification form and provide it to the Office of Sponsored Programs before submission of any funding proposals.

        Managing Conflicts of Interest and Conflicts of Commitment

        University faculty and staff are responsible for making disclosures related to their outside activities to facilitate effective identification and management of conflicts of interest and conflicts of commitment.

        If you...

        …seek approval from your college/unit to participate

        AND

        …disclose in your Biosketch, awards and other professional activities, and disclose participation on your eCOI disclosure

        AND

        …if supported by the U.S. Department of Energy, receive prior approval for participation in such programs for research they fund


        Resource/Guidance

        All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

        …list the position/affiliation in your biosketch

        AND

        …disclose the relationship on your eCOI disclosure


        Resource/Guidance

        All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

        …seek approval from your college/unit

        AND

        …disclose the approved relationship on your eCOI disclosure


        Resource/Guidance

        All paid external consulting, including foreign talent programs, require prior approval from a chair or TIU

        …disclose the support on your eCOI disclosure

        AND

        …list the support on current and pending support or other support documents if the travel relates to your research


        Resource/Guidance

        …list the support on current and pending support or other support documents as required by federal sponsors

        AND

        …disclose it on your eCOI disclosure

        Specific information on the Conflict of Interests, who must disclose and how, as well as answers to other FAQs, are available on the Office of Research Compliance Conflict of Interest website. For a listing of all university policies, rules and forms pertaining to conflicts of interest and outside activities please see the following webpage Office of University Compliance and Integrity.

        Reporting Inventions and Disclosing Intellectual Property (IP)

        If you...

        Ohio State’s Corporate Engagement Office is available to answer any questions related to intellectual property, patents, copyrights, or trademarks.

        Managing Export Controls

        If you...

        …determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned entities. The university has developed an easy to use International Risk Assessment tool to allow you to quickly assess possible export control concerns

        AND

        …if federally funded, determine if collaboration requires prior approval by funding sponsor


        Resource/Guidance

        (see International Collaborations)

        …obtain an approved travel T-number prior to travelling

        AND

        …contact the University’s Office of Secure Research


        Resource/Guidance

        Ohio State’s Office of Secure Research is available to provide training, or review individual situations upon request.