Disclosure Requirements for International Collaboration

Federal Research Sponsor Disclosure Requirements

Certain collaborations with domestic and international entities or individuals must be disclosed in federal research proposals and reports. Generally, to meet federal reporting requirements, investigators should:


Failure to fully disclose international or domestic collaborations, affiliations, and resources in federal funding applications and grant-related documents can have serious consequences and may impact individual and institutional eligibility for future federal funding.

Federal Disclosure Policies

Each federal sponsor agency has unique and evolving disclosure policies. Investigators should review program announcements and proposal preparation guidelines for disclosure policies of other federal research sponsors and contact the Office of Sponsored Research with any questions.

In 2021, the U.S. government issued National Security Presidential Memorandum-33 (NSPM-33), which directed federal funding agencies to standardize disclosure processes, definitions and forms across funding agencies to the extent practicable. In response, NSF developed the common forms, definitions and guidance below. NSF will require common forms in all applications by May 20, 2024 prior to making funding recommendations. Federal funding agencies are expected to adopt the common forms to the extent possible in 2024.

Federal Sponsor links: 

 

Disclosures for Conflict of Commitment and Research Conflict of Interest

Under the university’s Conflict of Commitment Policy and the Research Conflict of Interest Policy, investigators are required to:

  • Obtain approval before accepting an academic, scientific, professional, or institutional affiliation with an international entity or government, just as one would obtain approval before engaging in US-based outside activity. Outside activities include any activity, paid or unpaid, that is related or similar to an employee’s university responsibilities and is performed outside of one’s OSU role and duties. Submit the request on the Request for Approval of Outside Activities Form. 
  • Disclose outside activities and financial interests related to one’s field of research at least annually, and within 30 days of acquiring a new outside interest, on the Research Conflict of Interest Disclosure form. This includes both domestic and international affiliations. The form, found in Cayuse, has a new section for international collaborations. Learn more about research conflict of interest in the COI Instructions and FAQs.
Managing Conflicts of Commitment and Conflicts of Interest 

The university encourages professional collaborations with individuals, companies, and other entities (“entities”) external to the university. Such outside activities can further the university’s commitment to excellence in research, education, and engagement, but they may also result in conflicts of commitment and research conflicts of interest. 

A conflict of commitment exists when outside activities interfere with the employee’s ability to fulfill university expectations, obligations, and/or responsibilities; or compete with the university’s interests, including its educational, research or service missions. To manage Conflicts of Commitment, all Oregon State University employees must comply with university disclosure requirements.

A research conflict of interest arises when an individual’s external interest(s) may, or could appear to, bias or unduly influence their decision-making during university work, or compromise their ability to fulfill their obligations to the university. To manage research conflicts of interest, all Oregon State University researchers and affiliate researchers must comply with university RCOI disclosure and training requirements. 

Active position, affiliation, consulting, or advisor relationship with an international entity

If you have an active position, affiliation, consulting, or advisor relationship with an international entity (whether paid, unpaid or honorary) you should:

  • Review federal sponsor disclosure requirements (see Federal Disclosure Policies, above) 
  • Seek prior approval from your college/unit by submitting a Request for Approval of Outside Activities form and providing a copy of any contract; and
  • After the position or affiliation has been approved by your supervisor and college/unit, disclose the relationship on your research Conflict of Interest disclosure form found in Cayuse according to the instructions provided in that form.
Foreign talent recruitment program

If you are being offered, considering, applying for, or participating in a foreign government talent recruitment program, or an activity funded by such a program, you should:

International Travel Registration

All international travel must be registered in Concur as described on OSU's international travel website. Faculty and students travelling internationally for research purposes, including attending conferences or participating in international research collaborations, must comply with the U.S. Export Control regulations. It is advisable to contact the university Export Controls Office and Office of Information Security weeks before you leave to allow enough time to determine what, if any, measures are required to protect data or intellectual property based on the location of the travel and/or the technology and data you would take with you. 

Travel expenses that will be paid or reimbursed by a foreign entity

If you have travel expenses that were paid or reimbursed by an international entity, you should:

  • Seek approval from your college/unit by submitting a Request for Approval of Outside Activities Form and provide a copy of the invitation letter;
  • Disclose the dollar amount (considered a payment) as part of your research Conflict of Interest disclosure form found in Cayuse;  
  • Contact the Export Control Office for restricted party screening; and
  • Review federal sponsor disclosure requirements (see Federal Disclosure Policies, above) 

 

Publications that are NIH-funded

If you have a collaborator who is going to conduct a part of your NIH-funded research project outside of the United States and that research may result in a co-authored publication, it is important that you obtain prior approval from the NIH for the collaboration (a “foreign component”). See the related NIH FAQ here. Any publication that subsequently arises or results from the collaborative research must be reported to the NIH in progress reports.

The publication itself should also acknowledge NIH support and any support from an international entity, individual, or government (if applicable).

 

Restricted Party Screening

It is an institutional best practice to conduct the restricted party screening (RPS) process before entering international collaborations to confirm no restricted entities or individuals are involved. The Office of Export Control and International Compliance conducts this screening.

Prior to initiating research-related activities (e.g., travel, shipping equipment or physical items overseas, giving presentations at international institutions), investigators are expected to request restricted party screening from the OSU Office of Export Controls and International Compliance. You can learn more about research security here.  

 

Invention Reporting

All employees are responsible for reporting intellectual property and any improvements to existing intellectual property promptly to OSU Advantage through an invention disclosure. Start a conversation with OSU Advantage.

 

Gifts and Donations

Item of value from an international entity

Researchers who have received an item of value from an international entity in connection with their research should:

  • Review federal sponsor disclosure requirements (see Federal Disclosure Policies, above) 
  • Disclose the value of the item(s) on the investigator’s research Conflict of Interest Disclosure, found in Cayuse according to form instructions.