About International Collaboration

Equity, Inclusion, Innovation and Interdisciplinary Collaboration are essential components of our culture at the University of Cincinnati. We believe that collaborations across campus, across the region, and around the world are vital to the advancement of knowledge and innovation. While the University of Cincinnati strongly supports international collaboration and values our partners, it is important that everyone at UC understand the current regulatory landscape and the importance of transparency.

Recently, several federal officials and agencies have expressed concerns about improper foreign influence in U.S. academic research. (See Federal Timeline below.) The concerns were highlighted in letters from the Director of the National Science Foundation (NSF) and from the Director of the National Institutes of Health (NIH), alerting the research community to "threats" from foreign entities that undermine the integrity of U.S. research.

Highlighted concerns include:

1. Failure to disclose resources from other organizations, including foreign governments while receiving US federal funds for research;
2. Diversion of intellectual property (IP) in grant applications or produced using US federal funds to other entities, including other countries; and
3. Sharing of confidential information on grant applications by peer reviewers with others, including foreign entities, or otherwise attempting to influence funding decisions.

In most cases the failure to disclose is an error, but it is an error that can jeopardize funding to the individual and to the university as a whole. Importantly, there is little federal tolerance for failing to disclose. While we continue to grow and strengthen our global partnerships you are reminded of the following requirements:

1. Be transparent and promptly disclose any foreign component of your research including work conducted outside of the U.S. or supported by a foreign entity.
2. Disclose other sources of support for your entire research portfolio, no matter where the work is done. Even if that support is not through UC or is not related to your U.S. federally funded research. It’s important to disclose a foreign component to the funding agency and the University whenever elements of your research are conducted or rely on resources that exist, or originated, outside the U.S. This includes disclosing any effort both in current or pending support proposals and at just in time. This may include collaborators, funded students, research subjects, or facilities and equipment. IF YOU HAVE QUESTIONS, please contact your grant administrator in your college for guidance.
3. Keep your Outside Activity report (OAR) current and insure that includes all personal compensation, financial interests and outside activities, including stipends, living expenses, and travel paid for or reimbursed by a foreign entity, and any involvement in any foreign recruitment or “talent” programs in accordance with the university’s disclosure requirements and conflict of interest policies. IF YOU HAVE QUESTIONS, please contact the Office for Ethics in Industry Engagement or refer to the website.
4. There are several lists of restricted or problematic entities and individuals maintained by the federal government and other organizations.  Please see the Restricted Party Guidance for Researchers for more information.

Successful International Collaborations

The University of Cincinnati welcomes and encourages International Collaborations.  International Collaborations benefit the whole research enterprise at UC.  It is important to ensure collaborations are compliant to evolving regulations.  The Office of Research Security and Ethics can provide guidance to Protect you, the Researcher, your Research and yours and UC’s Reputation by keeping current with new sponsor and government regulation and reporting requirements. 

Below are some basic tips of the trade related to international collaborations

Transparency	Be TRANSPARENT and promptly disclose any foreign component of your research.  This includes financial interests or support from foreign entities.
Sources of Support	Disclose other SOURCES OF SUPPORT for your entire research portfolio, regardless of if it is through UC or not, or if it is related to your Federally funded research.  This could include support from collaborators, if you have funded students research subjects or facilities and/or equipment from outside sources.  Report this in your Outside Activity Report (OAR)
Outside Activity Reporting	Keep your OUTSIDE ACTIVITY REPORT current.  Ensure to include all personal compensation, financial interests and outside activities, including stipends, living expenses, and travel paid for or reimbursed by a foreign entity, and any involvement in any foreign recruitment or talent programs in accordance with University policy.   UC Policies:   Research How 2 Outside Activity Report:  Outside Activity Report (OAR)
Foreign Support	Disclose any FOREIGN SUPPORT of the relevant research and /or collaborations, as well as personal financial interest related to your research and all public sharing of research results including journal articles, presentations and other publications.  If you are approached by a foreign entity to collaborate or if you have received funding from a foreign entity, keep your Outside Activity Report up to date and email the Office of Research Security and Ethics or the Export Control Office for assistance.
Export Controls	Comply with US EXPORT CONTROL regulations.  These regulations impact traveling internationally, attending conferences; participating in international collaborations; working with international faculty, staff, students and visitors even while in the US; shipping or hand carrying materials internationally, or engaging in any international transactions.  Compliance with these regulations also require that UC will not host visitors, enter into contracts, do business, or engage in any activity with entities listed on a Restricted Party List with out prior approval of the UC Export Controls Office.  Contact the Export Controls Office (ECO) prior to starting any international collaboration.
Travel	Follow UC travel guidance outlined on the UC International's page for University related travel.  Per government regulations and UC Policy, UC faculty, staff, and researchers are required to register their international travel.  Information collected may include the following:  Destination of travel, Purpose of Travel, How travel will be paid for, and Export information including technology and information to be shared while traveling.  UC International Risk Management International Travel. HR Benefits Travel Abroad International Travel Training Resources--Including Specific Country Travel Questionnaire Training
Agreements	Have an agreement in place governing the use of research materials or data when it will be shared with other institutions, foreign or otherwise.  The Technology Transfer Group in the Office of Innovation oversees these agreements. More information about agreements and tech transfer can be found at the 1819 Innovation Hub website or via email.

Foreign Talent Recruitment Programs

Many countries sponsor talent recruitment programs to attract researchers from across the globe.  Many use legitimate mechanisms of recruitment including fellowships, student and scholar exchanges, and grants.  However, some programs include restrictions or contracts that create conflicts of interest or conflicts of commitment or event encourage unethical or even criminal behaviors.  These types of foreign talent recruitment programs are classified as Malign Foreign Talent Recruitment Programs.   Participation in Malign Foreign Talent Recruitment Programs is prohibited by UC Policy as well as United States law per the CHIPS and Science Act of 2022.
Further more, the White House Office of Science and Technology Policy has released 

Malign Foreign Talent Recruitment Programs (MFTRP) can be defined by (A). Programs sponsored by "Foreign Country of Concern" or an entity based in a "Foreign Country of Concern" (People's Republic of China, North Korea, The Russian Federation, The Islamic Republic of Iran), any institutions or programs on the lists created in the National Defense Authorization Act of 2019 or found on the document titled "Countering Unwanted Foreign Influence in Department Funded Research at Institutes of Higher Education" published by the US Department of Defense in June of 2023.
The White House Office of Science and Technology Policy has released Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs that outlines the guidelines for federal agencies on MFTRP and a standard definition.  

Additionally, Malign Foreign Talent Recruitment Programs have some or all of the following provisions, contract terms.  If the following types of compensation is offered:  Cash, In-kind compensation, including research funding, Promise of future compensation, Things of non de minimus value, Honorific titles, Career advancement opportunities or other types of renumeration or consideration IN EXCHANGE FOR PERFORMING ONE OF MORE OF THE FOLLOWING ACTIVITIES:

• Unauthorized transfer of intellectual property, materials, data, or other nonpublic information. 
• Recruitment of trainees or researchers to enroll in such program, position, or activity. 
• Establishing a lab or forming a company in a foreign country in violation of terms and conditions of a federal research award.
• Accepting a faculty position or undertaking any other employment or appointment in violation of terms and conditions of a federal research award.
• Signing a contract or agreement which you are unable to terminate except in extraordinary circumstances. 
• Committing a specified amount of time to work for the foreign institution. 
• Engaging in work that overlaps or duplicates a federal research award. 
• Applying for or receiving research funding from the foreign government that would be awarded to the foreign institution. 
• Requirement to omit acknowledgement of the foreign institution, or any U.S. federal research sponsors. 
• Requirement to not disclose participation in the program, position, or activity to the University of Cincinnati or the U.S. federal government. 
• Having a conflict of interest or commitment contrary to a federal research award.

As of May 20^th,2024, senior/key personnel cannot be a party to a malign foreign talent recruitment program (MFTRP). Individuals who are a party to a MFTRP are not eligible to receive NSF funding.

1. We strongly encourage you to take an 8-minute training video to learn about MFTRPs and to certify that you are not involved in an MFTRP.

2. The NSF is modifying the SciENcv to include an attestation statement that you are not a party to a MFTRP. The modification is scheduled to be released by May 20^th , 2024. 

3. A new PI certification at proposal stage is being added to Kuali for purposes of attestation:

Yes/No      Do you certify that you as PI (or Multi-PI) and your senior/key personnel are not a party to a malign foreign talent recruitment program (Section 10638(4) of CHIPS and Science Act)?

If you have been asked to participate in a Foreign Talent Recruitment Program, reach out to the Research Security Team or the Export Control Office for assistance.