Guidance Regarding Management of International Relationships and Activities
The federal government and several federal sponsors have expressed growing concerns regarding the potential for improper foreign influence over academic research. Reminders have been issued highlighting the importance of ensuring compliance with existing and new policies and regulations, including those related to full disclosure of foreign engagements, conflicts of interest, and conflicts of commitment.
Wayne State University encourages international collaborations, while ensuring that our investigators are mindful of the need to be transparent about foreign relationships and activities. The following information has been compiled to provide guidance and resources to assist researchers with their compliance obligations to federal sponsors.
Please check back for updates as additional guidance becomes available.
Conflict of Interest & Commitment Reporting
Any potential conflicts of interest – either foreign or domestic – must be identified and managed appropriately in accordance with the Research Policy on Financial Conflict of Interest and Commitment.
National Institutes of Health (NIH) & Foreign Affiliations
Any work done outside of the United States must be disclosed in grant proposals, progress reports, and final technical reports. According to the NIH Grants Policy Statement, the definition of a foreign component is as follows:
“The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. Examples of other grant-related activities that may be significant are:
- collaborations with investigators at a foreign site anticipated to result in co-authorship;
- use of facilities or instrumentation at a foreign site; or
- receipt of financial support or resources from a foreign entity.
Foreign travel for consultation is not considered a foreign component.”
Faculty involved in the peer review process are expected to follow the applicable confidentiality requirements for proposals undergoing review.
Federal Export Control Regulations prohibit disclosure of certain information, technology and products to designated persons or entities, whether on U.S. soil ("deemed exports") or abroad. Lists of sanctioned, prohibited, or regulated activities and entities are generated by the Departments of Commerce, Treasury and State. Even though these laws may conflict with the University's tradition of academic freedom, they carry severe criminal and civil penalties for noncompliance by individuals and the Institution. Therefore, it is imperative that all researchers at Wayne State University familiarize themselves with these Export Control Regulations and understand their responsibility to determine when these laws apply to their research activities.
Regulations in this area are complex and constantly evolving. Consult the export control office website for the most up-to-update information.