Coronavirus (COVID-19) Updates: uc.edu/publichealth
Coronavirus Impacts - Minimizing Research: research.uc.edu/coronavirus-impacts-minimizing-research
Coronavirus Impacts – Return to on-campus Research: https://research.uc.edu/coronavirus-impacts-return-to-on-campus-research

International Research Engagement

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.

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 recent 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.

Foreign Influence Training Video

International Outside Activity: What, When and How to Report

This table describes how the Office for Ethics in Industry Engagement (OEIE Conflictofinterest@uc.edu) and Export Controls Office (ECO ExportCo@uc.edu) work to monitor and identify possible concerns regarding foreign influence.



If you... You should... When Support
...have been invited to participate or are currently participating in a foreign talent recruitment program (e.g. foreign 1000 talents program, young scholar 1000 talents plan, etc.), or work with Huawei or a subsidiary of Huawei. ...alert your Department Dean/Chair/Supervisor

...contact Office for Ethics in Industry Engagement (OEIE) or Export Controls Office (ECO) with questions/concerns
Immediately - The Export Controls Office keeps up to date on any developments in federal guidelines and regulations around foreign talent programs
...have travel reimbursed or sponsored by a foreign entity, individual or government ...contact Office for Ethics in Industry Engagement (OEIE) or Export Controls Office (ECO) with questions/concerns

...comply with the UC travel policy, submit the trip to Concur, and complete an international travel checklist

...disclose the relationship in your Outside Activity Report (OAR)

Disclose to SRS and funding agencies as appropriate
Prior to accepting the engagement and before travel occurs - The ECO reviews each international travel checklist and performs necessary screenings and follow up

- UCIT has laptops available for researchers to borrow for UC related international travel.

- The OEIE and screens all disclosures, international entities, and works with investigators to complete any necessary reporting to sponsors
...have a foreign entity propose an institutional partnership with UC or a consulting relationship with you ...Contact Office of General Counsel (OGC)

...disclose the relationship in your Outside Activity Report (OAR)

...contact Office for Ethics in Industry Engagement (OEIE) or Export Controls Office (ECO) with questions/concerns
Immediately - The ECO supports the mission of connecting UC to the world by reviewing collaborations and helping to streamline the development of international relationships

- The ECO can provide screenings as appropriate for purchases and/or shipments of materials and equipment
...have an active or proposed position (e.g. job) with, or have been provided with funding by, a foreign institution ...disclose the relationship in your Outside Activity Report (OAR)

...disclose the relationship to Sponsored Research Services and funding agencies as appropriate

...contact the Export Controls Office (ECO) to perform a review
Immediately - The ECO works closely with Sponsored Research Services, and OGC to screen, review, and approve international relationships or work

- The ECO can provide screenings as appropriate for purchases and/or shipments of materials and equipment
...have funding from DOE or DOD which includes international collaboration ...contact the Export Controls Office (ECO) prior to starting any international collaboration As early as possible and prior to beginning work - DOE and DOD have specific clauses that may limit international collaboration. The ECO provides support to sponsored programs to identify and negotiate such clauses and works with the PI to develop an appropriate management strategy
...have ownership interest in a foreign company ...disclose the relationship in your Outside Activity Report (OAR) Immediately - The OEIE reviews and screens foreign companies and/or relationships disclosed via the OAR
...have any active research on campus (funded or un-funded) ...be sure to submit Outside Activity Report (OAR) at least annually or within 30 days of a change Annually and/or within 30 days of a change - The OEIE reviews all disclosures made on campus and screens any foreign companies, compensation, or other relationships disclosed via the OAR

- The ECO works with the UCPD building access team as necessary to secure labs working on restricted research

- The ECO works with IT as necessary to develop procedures to protect research data
...want to host a visiting scholar, student, tour group, or other individual from a foreign entity ...work with UC International Services to complete any necessary pre-visit paperwork Immediately - UC International Services reviews H1B and J1 visa applications and works with faculty to ensure they are prepared to host an international student, scholar, or visitor
...have concerns or questions about a proposed collaboration or research project ...contact your grant administrator in your college or Sponsored Research Services 

...contact Office for Ethics in Industry Engagement (OEIE) or Export Controls Office (ECO) with questions/concerns
Immediately Contact:

SRS: Srs.era@uc.edu

ECO: ExportCo@uc.edu

OEIE: ConflictOfInterest@uc.edu
...have concerns or questions about Peer Review ...never share information gained through peer review processes, whether reviewing grant applications or publications. This information is confidential.

...declare all competing or conflicting interests when agreeing to serve as a reviewer.

...check the requirements of the relevant agency or journal. If in doubt, disclose or ask.
Contact:

UCORI: integrity@ucmail.uc.edu

UC Office of Research Integrity 
...have concerns or questions about Gifts and Donations Only designated University personnel are authorized to accept gifts (either cash or in-kind) from any source. For this reason, you must work with University of Cincinnati Foundation on all gifts and donations from any domestic or foreign individual or organization, including foundations and corporations. University of Cincinnati Foundation
...have concerns or questions about Intellectual Property ...disclose to UC all potentially patentable inventions conceived or first reduced to practice in whole or in part in the course of your University responsibilities or with more than incidental use of University resources. Remind your group members and collaborators to do the same. Before sending or receiving proprietary information about the related technology and/or investing funds. If you have questions about intellectual property, industrial contracts, or affiliates programs, contact:

Office of Innovation-Technology Transfer

techcomm@uc.edu
...have concerns or questions about sharing information/materials with colleagues at another institution or receiving them ...work with Melissa Baines to create a material transfer agreement, confidentiality agreement, or data use agreement. Faculty, students and staff are not able to sign on behalf of the university.

A Material Transfer Agreement (MTA) is an agreement intended to cover the transfer of materials from one institution to another, particularly biological materials that are easily reproduced from the original material. An MTA should always be used when sharing any biological materials with other institutions, especially foreign institutions.

A Confidential Disclosure Agreement (CDA) is an agreement which outlines information to be shared for certain evaluation purposes, but wish to restrict from wider use and dissemination. CDAs are commonly executed when considering a relationship/collaboration and there is a need to understand each other's processes, methods, or technology solely for the purpose of evaluating the potential for a future relationship. CDAs are also sometimes referred to as Non-Disclosure Agreement (NDA) or Proprietary Information Agreement (PIA).
Before sharing materials or information with a colleague at another institution or receiving them. If you have questions about sharing information/materials contact:

Melissa Baines

Office of Innovation-Technology Transfer

Full Guidance from Vice President for Research (VPR): Guidance Involving Foreign Influence and Involvement in University Research

It is important that all researchers understand the current regulatory landscape informing the research enterprise, and the actions that you should take in light of this reality. For more details, please refer to this announcement from the Vice President for Research.

Federal Timeline

Issues surrounding foreign influence and international activities in federally funded research has been an evolving topic in recent months, in which the U.S. Government has shown growing concern. To learn more and view a timeline, click here.