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Office of the Vice President for Research

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Guidance Involving Foreign Influence and Involvement in University Research

04/25/2019

Fellow Researchers,

The University of Cincinnati (UC) embraces diversity and inclusion, locally and around the globe. We are all aware that there is increasing federal scrutiny (NIH and DoD) and public pressure to disclose and monitor funding and affiliations that might reflect foreign influence. While UC strongly supports international collaboration and values its partnerships with universities and other organizations worldwide, 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.

In keeping with university and federal mandates you must 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. You must 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.

As UC continues to strengthen existing international collaborations and pursue new opportunities that benefit our faculty, students, and research objectives, we ask that faculty and all principal investigators remain mindful of the following requirements:

  • Disclose a foreign component whenever elements of your research are conducted or rely on resources that exist, or originated, outside the U.S. This may include collaborators, funded students, research subjects, or facilities and equipment. This includes disclosing any effort both in proposals (current/pending support) and at just in time. Disclosure should be to the funding agency and the university.
  • Disclose to the university on your outside activity report (OAR) all personal remunerations/financial interests and outside activities, including stipends, living expenses, and travel paid for or reimbursed by a foreign entity (e.g. governments and institutions), and any involvement in any foreign recruitment or “talent” programs. Disclosure must be done both annually and within 30 days of acquiring new interests in accordance with the university’s disclosure requirements and conflict of interest policies.
  • Disclose any foreign support of the relevant research and/or collaborations as well as personal financial interests related to your research in all public sharing of research results including journal articles, presentations, and other publications.
  • Comply with US export control regulations. These regulations impact the following: traveling internationally and attending conferences; participating in international collaborations; working with international staff and students (even while in the U.S.); hosting international visitors; shipping or hand carrying materials internationally; or engaging in any international transactions. Refer to the university’s export control website for additional information.
  • Follow guidance outlined on the university’s website for UC affiliated travel.
  • When materials or data will be shared with other institutions, foreign or otherwise, it is often prudent to have an agreement, such as a material transfer agreement (MTA), data use agreement (DUA), or nondisclosure agreement (NDA), in place governing the use of those materials or data. Having an agreement also allows UC to complete all required internal controls and checks. The Technology Transfer group in the Office of Innovation manages these agreements; more information can be found at http://commercialization.uc.edu.

While the above focuses on your responsibilities for reporting international collaborations, sponsorships and activities, these reporting responsibilities extend to your domestic activities as well.

The world is changing and we must change with it. Transparency is key. Thank you for complying with these requirements to disclose and report so that the University’s and your interests are protected. For questions, contact the Office for Ethics in Industry Engagement (confint@uc.edu) or the Export Controls Office (exportco@uc.edu).

Sincerely,
Patrick Limbach, PhD
Vice President for Research
University of Cincinnati


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