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,
originated, outside the U.S. This may include collaborators, funded students, research subjects, or facilities
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
outside activities, including stipends, living expenses, and travel paid for or reimbursed by a foreign entity
governments and institutions), and any involvement in any foreign recruitment or “talent” programs. Disclosure
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
related to your research in all public sharing of research results including journal articles, presentations,
- 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
(even while in the U.S.); hosting international visitors; shipping or hand carrying materials internationally;
engaging in any international transactions. Refer to the university’s export control website for additional
- 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
agreement, such as a material transfer agreement (MTA), data use agreement (DUA), or nondisclosure agreement
place governing the use of those materials or data. Having an agreement also allows UC to complete all required
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 (email@example.com) or the Export Controls Office
Patrick Limbach, PhD
Vice President for Research
University of Cincinnati