International Collaboration and Engagement

Last updated: 09/16/2020 - 12:21pm

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Arizona State University supports academic freedom and the exchange of ideas and collaboration with foreign partners to advance knowledge. We are committed to supporting collaborations with international partners, faculty and researchers from all over the world. It is of great importance for us to maintain our productive relationship with the United States Government and the federal funding agencies that support our faculty in their research and scholarly work.

ASU faculty and staff who have such collaborations are required to be transparent and provide full disclosure of all funded and unfunded collaborations and affiliations as required by federal and state agencies, as well as ASU’s policies.

Federal funding agencies continue to share concerns regarding failure to disclose foreign relationships and activities, which could jeopardize funding eligibility. Many of the federal agencies have released further guidance and we should expect this information may continue to change. We will be providing regular updates, guidance and resources to keep the ASU Research Community up to date and as a reminder of our compliance obligations.

This comprehensive approach will help support consistency, transparency and compliance among our faculty and staff, and will help to meet the requirements of our federal funding agencies.

National Institutes of Health (NIH)

NIH policy requires all individuals included in an application as senior/key personnel – including the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way to disclose “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,” and for determination to be made if the project activities include a foreign component, “significant scientific element or segment of a project to be performed outside the United States.”

Foreign engagement and other support should be disclosed in proposals, and in interim and final Research Performance Progress Reports (RPPR). Specific disclosure of "Foreign Components" is to be disclosed on its Research and Related Other Project Information Form submitted with proposals. This disclosure is in Item 6 of the Research & Related Other Project Information Form

Throughout a project if the need arises to include a foreign component, it requires NIH prior approval and should always be included in the foreign components section of the RPPR Report, Section G.9.

Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.

NIH Resources:

National Science Foundation (NSF)

NSF policy requires full disclosure of domestic and foreign engagements, regardless if funded or unfunded. Disclosures are to occur in Current and Pending Support; Annual reports; final reports and Biosketches.

Biosketches – domestic and foreign appointments, funded and unfunded (e.g. Scientific Advisor, Consultant, etc.) are to be included in the “Appointment Section”

Note: Starting prior to October 5, 2020, if/when ASU discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the PI or co-PI must work with the AOR on submission of the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.

Resource:  October 5, 2020 Significant Change

Additional information and links to the forms are available on the NSF biographical sketch and current and pending support websites, and in the NSF Fillable PDF FAQs

Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.

Resources:

Department of Defense (DOD)

DOD policy requires full disclosure for all key personnel, in addition to PI or Co-PI, even if efforts are or are not to be funded by DOD., domestic and foreign engagements/support, regardless if funded or unfunded.  Disclosures are to occur in Current and Pending Support as announced in March 20, 2019 memo.   This memo applies to new research activities after April 19, 2019 and applies to grants, cooperative agreements, etc.   If you have a DOD contract, please review terms and conditions as it may have additional requirements.

Department of Energy (DOE)

DOE policy requires full disclosure, domestic and foreign engagements/support, regardless if funded or unfunded.  Disclosures are to occur in Current and Pending Support as announced in DOE FY 2020 Continuation of Solicitation for the Office of Science Financial Assistance Program.  Include as an appendix to your project narrative.  DO NOT attach a separate file.

National Aeronautics and Space Agency (NASA)

NASA requires full disclosure, domestic and foreign engagements/support, regardless if funded or unfunded.  Disclosures are to occur in Current and Pending Support  as outlined in NASA Guidebook for Proposers Responding to a NASA Funding Announcement.

If you are a co-I and spending more than 10% of your time on an active award or pending proposal, regardless if funded or unfunded, then you do need to disclose on your Current and Pending Support.

As a reminder, the proposal you will be submitting does not need to be included on your Current and Pending Support, unless you have submitted the same proposal to another agency.

If you have a NASA contract, please review terms and conditions as it may have additional requirements.

Resources: 

NASA grant restrictions and contract restrictions.

Additional federal funding agencies information

Best practices for foreign relationships and activities
  • To fully and accurately disclose domestic and foreign engagements to ASU, including equity interests in foreign entities and/or if you need to update your conflict of interest financial disclosure, contact ASU Research Operations at Research.Integrity@asu.edu.
  • Obtain restricted party screening of foreign collaborators and including foreign visitors.  Contact export.control@asu.edu
  • As you are developing your proposal include a clear description of all foreign collaborations
  • Review your active awards and pending proposals to ensure all locations outside of the United States have been disclosed to the federal agencies and ASU.
  • Ensure that any material transfers, data sharing and confidential information are covered by an agreement. Contact the Office of International Research Collaboration (OIRC) at industry.agreements@asu.edu should you need assistance with the development of an agreement.
  • Be aware of and follow peer review regulations, including confidentiality provisions related to the content provided during the review.
  • Obtain export control review for incoming and outgoing collaborations, including traveling abroad and international rework requests – whether funded or unfunded.  Contact export.control@asu.edu
Frequently Asked Questions
  1. If I have been approached by a domestic or foreign entity for an appointment (e.g. Visiting, Adjunct, Honorarium), who should I discuss this with?

    Please contact your Research Administrator (RA) so they can coordinate and facilitate with your departmental leadership and the Office of Research Integrity and Assurance (ORIA)

    Note: Your Dean’s Office needs to be aware of any proposed arrangement(s) before entering into any of them.
     
  2. Are there foreign activities, which should be disclosed to ASU and Federal Sponsors? Yes, those activities may include but are not limited to the following:
     
    • Consultancy agreements
    • Salary, living, lodging, research space or other reimbursements
    • Travel Funds
    • Ownership in a foreign company
    • Research Collaboration (e.g. funded or unfunded) and/or affiliations
       
  3. If it has come to your attention that a disclosure needs to be made to ASU  that hasn’t been previously reported, how should I manage disclosure at this time?

    Contact Research.Integrity@asu.edu to discuss how to best work through the best way to correct this omission or error
     
  4. If it has come to your attention that a disclosure needs to be made to a Sponsor that hasn’t been previously reported, how should I manage disclosure at this time?

    Contact export.control@asu.edu to discuss how to best work through the best way to correct this omission or error.
     
  5. I am working and/or collaborating with another institution – domestic or foreign? How do I disclose this to ASU?

    This work is considered outside activity. For ASU, it is required to be disclosed through our COI process. Please contact research.integrity@asu.edu

    Dependent upon the Sponsor, regardless if funded or unfunded should be disclosed in Current Pending Support, Biosketches, Other Support, Facilities, Equipment and Other Resources documents, Annual Reports, Final Reports, Just-In-Time, etc. Please work with your Research Advancement contact (RA).
     
  6. Should foreign affiliations be included on my Biosketch?

    Yes, all affiliations – domestic and foreign -  regardless if funded of unfunded, should be included on your Biosketch.
     
  7. If I am contacted by a Sponsor regarding a past or current foreign engagement, how should I respond?

    Do not respond directly. These responses need to come from the Institution. Please contact research.integrity@asu.edu and Executive Director, Research Operations Heather.Christina.Clark@asu.edu
     
  8. A Sponsor – domestic or foreign – has requested information outside of what I am required to provide under an agreement; how should I respond?

    Please contact your Research Administrator (RA), so they can work with a Contracts Officer within ASU Office for Research and Sponsored Projects Administration (ORSPA)
     
  9. If I have/will have foreign visitors (Scholars, Engineers, Scientists, Students, etc.) visiting ASU now or in the near future, what actions do I need to take?

    Please contact your Research Administrator (RA) so they can coordinate and facilitate with your departmental leadership and the Office of Research Integrity and Assurance (ORIA)
     
  10. If a Visiting Scientist/Scholar/Student/Engineer is visiting a laboratory more than a few days a week in an academic or in research capacity, should it be disclosed?

    Yes, if they are using up your potential capacity as the PI/Co-I/Researcher

  11. Do Material Transfer Agreements (MTAs) need to be disclosed?

    They do not need to be disclosed on your Current and Pending Support as they are a tool to perform the activities.  They should be referenced in the “Facilities” section of your proposal.

Related resources

July 2020 – International Engagement Slides
Purpose: To provide context and information to ASU researchers in support of international engagements

Export Control Wizard – Export controls may apply when you send an item, information or software outside the United States’ borders or when you share it with "foreign persons or entities" inside the United States. This tool has been designed to assist investigators in determining if an export license is needed. 

Export Control ASU Research and Sponsored Projects Policy (RSP) 214: Export Control: 

Background: It is the goal of the university to allow faculty both to explore freely their research interests and disseminate their research results. The university also wishes to allow faculty to collaborate freely with their international colleagues in the conduct of fundamental research and to allow foreign researchers and graduate students to participate in university research projects. However, the university must pursue these goals in accordance with applicable U.S. export control laws and regulations.

Policy:  All university personnel engaged in sponsored or non-sponsored research of any scope and duration are responsible for reviewing, prior to beginning such research, applicable export control regulations to determine whether any aspect of the intended research is subject to the regulations and, if so, whether any exclusion or exemption is available or whether a license must be obtained as a condition of conducting the research. Such determination must be re-evaluated prior to any subsequent changes in the terms of sponsorship, the scope of work or the personnel involved in the research.

Objectivity in Research-Disclosure of Financial Interests and Management of Conflicts of Interest

ASU policy to address the reporting of interactions with public or private sources outside the university and disclosures of conflicting financial of interest.

International Collaborations and Travel

Guidance on export controls and travel restrictions when facilitating international engagements.

Conducting Business Internationally

Addresses frequently asked questions related to contracting, operations and appropriate planning for expenses. 

Global Operations

Resources for ASU faculty and staff to conduct international business. 

Foreign Travel

Addresses frequently asked foreign travel questions.

ASU Travel

When traveling to countries of concern (e.g., Cuba, Syria,  Iran, North Korea and Sudan ), as well as China, please notify ASU’s Research Operations office at export.control@asu.edu at least a few weeks before your trip. This notification allows for vetting of collaborations and equipment (e.g., laptops and electronic equipment) or materials that may contain unpublished research data to ensure compliance with export controls and protection of intellectual property.

Prior to departure, any university travel to a sanctioned country must follow all foreign travel requirementsIf a license is required, ASU Research Operations will contact the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) to obtain the necessary license.  Currently, the sanctioned countries are Cuba, Syria, North Korea, Sudan and Iran. Support is also available for travel to China, Hong Kong, Jordan, Kazakhstan, Kyrgyzstan, Pakistan, Taiwan, Tajikistan and Uzbekistan. Research Operations will provide travel letters and support for obtaining licenses from the U.S. Department of Commerce or U.S. Department of State when necessary. Requests should be submitted six months in advance of the travel date. 

Questions?

Questions should be directed to research.integrity@asu.edu.

Inquiries from external funding agencies related to international engagements or requests for institutional endorsements such as letters of support should be directed to Research Operations Executive Director, Heather Clark at Heather.Christina.Clark@asu.edu.

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