Foreign Institutions & Scholars
Guidance for reporting and compliance obligations when engaging with foreign institutions and scholars, shared with all faculty and staff in a memo sent on December 20, 2018, by the University of Minnesota President, Executive Vice President and Provost, and Vice President for Research.
External Influence & Interest Reporting
Contact: Jon Guden, Conflict of Interest Program
To ensure that any potential conflicts of interest—foreign or domestic—are identified and managed appropriately, research personnel must accurately disclose covered financial and business interests, activities, and support on their Reports of External Professional Activities (REPAs), in accordance with Administrative Policy, Individual Conflicts of Interest and Standards Governing Relationships with Business Entities (see also the appendix on Required Disclosures). Specifically, researchers must disclose on the REPA:
- Outside professional commitments. Such disclosures must include commitments involving a foreign institution of higher education, foreign governments, or any for-profit or nonprofit business entities—including non-U.S. organizations.
- Significant financial interests and business interests relating to your University responsibilities and expertise. Report these interests, whether received from foreign institutions of higher education, a foreign government, or any for-profit or nonprofit business entities, including non-U.S. organizations.
- If you receive research funding from one of the Public Health Service (PHS) agencies, report travel for you, your spouse, or your dependent children that is valued in excess of $5,000 annually and paid for by a foreign institution of higher education, foreign government, or any for-profit or nonprofit business entity, including non-U.S. organizations.
Grant Proposal Information (e.g., Current and Pending Support)
Contact: Pamela Webb, Sponsored Projects Administration
Investigators are personally responsible for including in their Current and Pending Support (or other relevant) sponsored projects documents all sources of foreign support consistent with the funding agency’s requirements. NIH, in particular, currently states: “Other Support includes all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts do not need to be included.” As noted in NIH director Collins’ letter, there have been instances reported nationally of investigators failing to properly report sources of foreign support for their research. NSF and other agencies have also voiced concern. Failing to report other sources of domestic or foreign support increases the likelihood that the same or closely related research could be funded more than once, and increases the potential for allegations of fraud, as well as overlap in intellectual property obligations to employers and the government. While we are not aware of any such instances at the University, it is important that vigilance in this area be maintained. In any case, careful attention to the specific requirements of an individual Funding Opportunity Announcement/FOA is warranted.
Proper Handling of Peer Reviewed Proposals
Contact: Pamela Webb, Sponsored Projects Administration
Investigators involved in the peer review process are expected to follow the stringent confidentiality requirements of proposals undergoing review. NIH director Collins also reported instances (nationally) of study section reviewers inappropriately sharing proposals undergoing peer review with domestic and foreign collaborators. While we are not aware of any violations that have occurred at the University, it is important that vigilance in this area be maintained.
Contact: Leza Besemann, Technology Commercialization
Anyone who develops an invention or software, whether in the course of conducting University research or while using University resources, must notify Technology Commercialization (Tech Comm), as described in Administrative Policy, Reporting Inventions or Software Arising from Research. Such disclosures allow Tech Comm to best ensure that the proprietary rights and responsibilities of the University, our personnel, and outside parties are honored.
Contact: Lynne Schoen, University of Minnesota Foundation
Disclose to the University of Minnesota Foundation any gift solicitation with foreign organizations or entities in compliance with the University’s Administrative Policy, Accepting and Managing Gifts.
International Travel Registration
Contact: Kevin Dostal Dauer, Global Programs and Strategy Alliance
All travel outside the U.S. on University business (i.e., not personal trips) must be registered with the Global Programs and Strategy Alliance. Registration takes very little time and gives University experts an opportunity to provide important health, safety, and compliance guidance and services.
Traveling with Technology
Using laptops, email, and other technology outside the U.S. can entail elevated risks of data compromise or loss. For best practices to mitigate these risks, see the University’s page on Technology Guidance for International Travel.
Export Controls & Sanctions
Contact: Pat Briscoe, Research Compliance Office/Office of Sponsored Research
Federal export regulations govern shipments and releases of certain sensitive commodities, technologies, and software to non-U.S. locations and persons. In addition, economic sanctions rules can significantly affect educational and research activities involving Cuba, Iran, Syria, North Korea, and the Crimea region of Ukraine. The University is committed to compliance with these requirements, and personnel are encouraged review the Export Controls Compliance Information Page and contact the Export Control and International Projects Officer with any export questions or concerns.
Sending Tangible Research Materials Outside the U.S.
When sending tangible research materials outside the U.S., researchers must ensure that the materials are sent out under a material transfer agreement (MTA). The process for putting an MTA in place may be initiated by completing the MTA Request Form and emailing the form to firstname.lastname@example.org.
Foreign Visiting Scientists
Departments are responsible for verifying the eligible visa status of their visiting scientists, and certain visa statuses are not eligible to serve as visiting scientists. Please contact International Student and Scholar Services for assistance with any visa-related issues. Foreign visitors are a welcome addition to our campus, and the University supports such collaborations. Visitors (foreign or domestic) who are working alongside University personnel are expected to have on file with their department a Volunteer Researcher Agreement and Release prior to work being undertaken. Questions about the agreement and release should be sent to Arnie Frishman, Office of General Counsel.