International Collaborations


Important Information for Investigators with International Collaborations

Last updated 10/22/19 - New Memo from Department of Defense

Research activities that involve an international connection have come under increased scrutiny from the U.S. Government. Universities, which have long considered the open exchange of knowledge as an essential hallmark of research and scholarship, are now the focus of attention in part because of these very freedoms. Federal funding agencies, including NIH, NSF, DOE, and NASA, have expressed serious concerns of inappropriate influence from foreign sources over federally-sponsored research at universities and other institutions in the US. These concerns arise partly from the potential for unauthorized transfer of confidential information and intellectual property resulting from federally-funded research to entities in other countries and the associated impacts to economic and national security.

Some members of Congress, citing threats to U.S. interests from foreign influences, have introduced legislation that could impose new regulatory burdens on universities and their investigators involved in international collaborations, if enacted. Other voices in government have sought to focus attention on certain countries, thereby creating concerns among valued faculty colleagues of particular nationalities.

In response to this increased scrutiny, many universities have introduced or expanded requirements for faculty to disclose foreign connections, including paid and unpaid appointments at other institutions, as well as any form of support provided by another entity, whether monetary or nonmonetary in form. Stony Brook University is among those to require such disclosure by all faculty, as well as other personnel involved in sponsored research, through the myResearch Conflict of Interest portal.

Federal funding agencies have also provided new guidance that expands requirements for disclosing foreign connections relating to research activities, and have warned of possible consequences for failure to disclose. At some institutions, failures to disclose foreign connections or other regulatory violations have resulted in personnel actions and even indictments by law enforcement. Some federal funding agencies have stated that investigators who fail to disclose appointments or support from foreign entities may be ineligible to receive funding.

Stony Brook University remains committed to the principles of academic freedom and the open exchange of knowledge, which serve as the bedrock of research and scholarship. Faculty and students are encouraged to participate in international collaborations. However, such collaborations should be transparent and disclosed in a manner consistent with applicable requirements, including those of federal and state agencies, as well as Stony Brook’s own policies. The Office of the Vice President for Research continues to monitor new regulations and guidance provided by funding agencies regarding foreign collaborations, and we will inform the University community of relevant changes. Updates and new information will also be provided on this page.

Current Guidance from Federal Funding Agencies

National Institutes of Health

On July 10, 2019, NIH issued a Notice (NOT-OD-19-114) reminding researchers about “the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.” NIH has defined Other Support to include “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” Further information regarding foreign components and other support is provided on the NIH FAQ page.

National Science Foundation

On July 11, 2019, the NSF Director issued a Dear Colleague letter describing the steps that NSF is taking to address “emerging risks to the nation’s science and engineering enterprise.” Among these measures are streamlined processes to ensure disclosure of all appointments and current and pending support. Further guidance is expected soon.

Department of Energy

On June 7, 2019, DOE issued an Order prohibiting their employees and the employees of certain DOE contractors from participating in foreign government-supported talent recruitment programs of select countries. Further guidance is expected from DOE concerning policies for DOE grants and cooperative agreements.

Department of Defense

On March 20, 2019, the Under Secretary of Defense for Research and Engineering, citing section 1286 of the 2019 National Defense Authorization Act, issued a memorandum instructing DoD Grants Managers to require disclosures of all current and pending funding sources and time commitments to other projects by key personnel identified on DoD proposals and involved in research-related educational activities. 

NEW - These disclosure requirements were reaffirmed in an October 10, 2019 letter that cautions academic researchers about the importance of safeguarding integrity of academic research.

National Aeronautics and Space Administration

Since 2011, NASA has prohibited the use of NASA funds “to enter into or fund any grant or cooperative agreement of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company…”

Best Practices for International Research and Scholarship Activities

Stony Brook University recognizes that international collaborations can greatly enrich research and scholarship. Investigators are encouraged to pursue such activities, while adhering to the highest standards of integrity, with appropriate transparency. Disclosure of international relationships can help to avoid conflicts of commitment, duplications of research, and/or diversion of intellectual property related to federally funded research. Disclosure also safeguards investigators from possible ineligibility for future funding resulting from violations. Failure to disclose international relationships can also pose a threat to the University. The section below provides current “best practices” to guide investigators and scholars involved in international activities.

1. Disclosures on grant applications and progress reports.

Presently, there is no uniform practice among federal funding agencies for disclosing international components of research activities. Furthermore, there exist multiple ways in which such disclosures may be included in grant proposals and progress reports, depending on the funding agency. PIs must pay careful attention to the sponsor’s proposal guidelines and to requirements for annual and final reporting.

As an example, NIH requires that grant applicants and recipients (including key personnel) must disclose all relevant positions and appointments with foreign entities, as well as “Other Support”, which includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” Financial resources should be disclosed even if they relate to work that is performed outside of the investigator’s academic appointment period. For example, if an investigator with a 9-month appointment spends two months at a university outside of the US during the summer performing research supported by a foreign entity, that activity must be disclosed.

NIH also requires that “Foreign Components” be identified; this includes performance of work in a foreign location, whether or not NIH grant funds are expended. Such disclosures could be indicated by identifying a non-US performance site, identifying a foreign relationship and/or activity in a biosketch, or by 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?”

Principal Investigators (PIs) should review any pending proposals and active awards to ensure that all foreign components have been properly disclosed. If a PI identifies an omission or error in a previously submitted proposal, it is important that they contact the Office of Sponsored Programs to have the error corrected.

Other federal sponsors have similar disclosure requirements that are described in their guidelines.

2. Publications.

Funding agencies provide guidelines for information to be included in publications resulting from grants and contracts. They also generally require that all publications resulting from sponsored research must be reported, typically in annual and final progress (or technical) reports. Authors involved in international collaborations should determine if sponsor approval is required to perform the research. For example, NIH requires identification of a foreign component in a grant application. If a publication involving a foreign component (even via a co-author) resulted from the sponsored research, it must be reported to NIH in annual and final progress reports. Authors should also be aware that many journals require disclosures relating to funding sources (including those for co-authors) and participation (including roles) of authors/co-authors.

3. Stony Brook’s annual COI disclosure.

All Stony Brook University faculty, all personnel meeting the NIH definition of key personnel, and all personnel performing human subjects sponsored research are required to complete the annual Conflict of Interest (COI) disclosure through the myResearch portal. This disclosure now requires reporting of positions and appointments at institutions other than Stony Brook, whether paid or unpaid, as well as other support provided by entities other than Stony Brook or Research Foundation for SUNY, whether monetary or non-monetary in form.

4. MOUs with entities in other countries.

Individual faculty and staff of Stony Brook University are not permitted to complete (i.e., sign) a memorandum of understanding (MOU) or any agreement with a foreign entity. Those wishing to establish an MOU or agreement must contact the Office of Research Compliance.

5. Participation in foreign “talent programs”.

The Office of Science and Technology Policy has recently drawn attention to potential risks posed by foreign government-supported talent recrutiment programs. Investigators are strongly advised to disclose participation in any foreign government talent program to federal sponsors in their grant proposals. Disclosure should also be made in SBU’s Annual COI disclosure via myResearch.

6. International travel.

Members of the campus community traveling internationally using Research Foundation funds are required to submit an Electronic Foreign Travel Request (eFTR) prior to travel. Prior approval is required for travel to certain countries.

7. Restricted-party screening.

Members of the campus community should consult Stony Brook’s Export Control Policy, which explains the requirement for a Restricted-Party Screening prior to engagement with a foreign person or entity. A guidance document outlining best practices, responsible parties, and access to software is available here.

How to Get Additional Guidance

Any member of the University community may request additional guidance relating to international collaborations in their research and scholarly activities. Initial inquiries should be directed to:

Office of Sponsored Programs

Office of Research Compliance

Office of the Vice President for Research

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