Research Compliance  /  International Collaboration

International Collaboration

Updated August 31, 2021

The Importance of and Benefits from International Collaboration

Caltech as an institution of higher learning is committed to a policy of openness regarding international collaborations. We allow full access to research activities for graduate students, postdocs, and staff of all nationalities.

Caltech derives significant benefit from foreign collaborations and such collaborations are in keeping with the Institute's mission. While concerns have been raised regarding such engagements, the consistent application of standards of openness, transparency, reciprocity, and integrity will make it possible to participate in such engagements while deriving the associated mutual benefits. The Institute should ensure that these important characteristics are fundamental components of any proposed international collaborations.

For more information, please read the Report of the faculty committee on international collaboration.

Concerns

Recently, the U.S. government has raised several concerns about research security, specifically, theft of intellectual property, research materials, and unfair practices related to research results. This has led to investigations at a variety of research and educational institutions where the government has analyzed international collaborations for an unfair advantage, the potential for conflict of commitment, practices contrary to funding agency reporting requirements, and in rare cases, scientific misconduct.


Watch the April 26, 2021 Faculty Town Hall on Transparency in Foreign Collaboration (Caltech credentials required for registration. Duration: 90 minutes).


What Do Researchers Need to Do?

The purpose of this website is to inform the Caltech community and our external partners regarding Caltech policies and procedures related to engaging with foreign partners.

August 31, 2021: NSF Chart on Pre-award and Post-award Disclosures

August 2, 2021: NIH issues Additional Clarifications to Biosketch and Other Support Policies

July 30, 2021: NIH issues report of its findings on foreign influence cases from 2016 to 2021

July 18, 2021: NIH issues new and updated FAQs - Other Support and Foreign Components

June 28, 2021: NSF issues new FAQs Regarding Current & Pending Support

May 17, 2021: For more guidance on reporting research collaborators as NIH Other Support, please review Caltech's guidance on when to report collaborators to the NIH, which includes several examples.

May 11, 2021: In response to concerns raised by the academic community, NIH is deferring implementation of its new Other Support and Biosketch formats and the other new requirements imposed in Notice NOT-OD-21-073, which was issued on March 12. The changes will now go into effect on January 25, 2022, instead of May 25, 2021.

You still must disclose all Other Support as described in that Notice and in Notice NOT-OD-19-114 in your just-in-time submissions and RPPRs, and you should contact the Office of General Counsel if you have any previously undisclosed other support.

For more details, please see the memo regarding the Update on NIH Requirements from the Vice Provost.

April 28, 2021: NIH issued a follow-up Notice: NOT-OD-21-110 regarding the May 25th deadline for reporting Other Support and biographical information on the Biosketch.

March 12, 2021:Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 (NOT-OD-21-073)

Caltech recommends the CITI training modules: Undue Foreign Influence: Risks and Mitigations and Export Compliance Awareness Training. Access the training through access.caltech.edu under Self Service > Research Ethics Education (CITI).

Conflicts of Interest. All investigators who receive funding from the Public Health Services, including the National Institutes of Health (NIH), must take conflict of interest training at least once every 4 years. Training is strongly encouraged for all other Caltech researchers. Access the training through access.caltech.edu under Self Service > Research Ethics Education (CITI).

Watch the Faculty Town Hall on Transparency in Foreign Collaboration (Caltech credentials required for registration. Duration: 90 minutes)

Federal funding agency-specific requirements:

The Office of Sponsored Research (OSR) assists you in the review and submission of proposals, and the negotiation, and acceptance of awards, for research, training, and other sponsored programs. OSR can help you with questions about the forms and about agency requirements.

It is essential to disclose all forms of research support, especially from foreign sources (including gifts). When there is a question about a possible conflict of interest or a conflict of commitment, a decision to err on the side of disclosure will protect both the investigator and the Institute. More information may be found at Conflicts of Interest.

  • Everyone must disclose covered outside activities and financial interests:
    • at least annually, and
    • within 30 days of engaging in any new activities or acquire any new financial interests which could be perceived as being a conflict
    • PHS-funded investigators must report travel paid or reimbursed by a third party with 30 days of completing the trip

Use Disclosure of Financial Interests and Commitments through access.caltech.edu for all disclosures.

Note that changes in federal agency requirements mean Investigators may need to report outside activities to sponsors, as well. See agency-specific requirements for details.

Send questions to caltechcoi@caltech.edu.

Quick Reference Sheet for Faculty [To be updated]

As part of an international collaboration or other research-related or professional activity, you may be asked to sign an agreement that includes provisions pertaining to intellectual property (IP), possibly including, but not limited to, rights in inventions, patents, software, or copyright. Such IP terms should be reviewed by Caltech's Office of Technology Transfer and Corporate Partnerships (OTTCP) and may need to be renegotiated to be compatible with your IP obligations to Caltech, whether the agreement is with a domestic or foreign entity.

Caltech's fundamental research "safe harbor" generally applies only to work at or for Caltech in the U.S. These protections do not always apply when activities cross international borders. Researchers should request a review of their activities for EAR or ITAR compliance when they plan research for Caltech outside the U.S. or the research involves export-controlled technology transfers to foreign persons in the U.S. (deemed exports).

Export Control regulations are likely to apply to the following activities:

  • Use of export-controlled information or items in your collaboration with foreign parties
  • Use of Controlled Unclassified Information (CUI) or restricted information
  • International collaborations that include JPL involvement
  • Foreign Talent Program engagements
  • Traveling internationally and attending conferences
  • Traveling to sensitive, embargoed or sanctioned countries
  • Participating in international collaborations
  • Use of proprietary data subject to a confidentiality or nondisclosure agreement
  • Hosting international visitors, or
  • Shipping items (software, hardware or technical data) internationally

Researchers may be held personally liable for violating export control laws. The Export Compliance Office will assist you with any questions regarding export control requirements in a particular country or licensing requirements for specific activities.

Please visit the Export Compliance Office and International Travel page for additional information and guidance.

If you are exporting or importing items as part of your research, please visit the Export Compliance Office for requirements in a particular country or licensing requirements for specific activities and the Environment Health and Safety Office or Research Compliance for shipping, labeling, and receiving biological, hazardous, or radioactive materials.

Please contact the OTTCP Material Transfer Agreement team at mta@caltech.edu for assistance with MTAs, which may be required to provide materials to, or receive materials from, your collaborators.

Section 889 of the John S. McCain National Defense Authorization Act prohibits government contractors from providing the federal government with telecommunications or video surveillance equipment, systems, or services (or an essential component thereof) produced or provided by five Chinese companies and their subsidiaries and affiliates. Separately, Section 889 prohibits government contractors from using these prohibited items or services, regardless of whether they are used in the performance of work under a federal contract.

Visit Export Compliance's NDAA Section 889 page for more details.

The Export Compliance International Travel page provides information to travelers about special restrictions when traveling to certain foreign destinations, information about exporting items including hand-carried items. You may send a direct email to exportcompliance@caltech.edu for assistance. See also the Travel Advisory for International Scholars.

If your travel is paid for or reimbursed by an outside entity and you are involved in the design, conduct, and reporting of Public Health Service (PHS)/NIH-funded research, it is necessary to report this in the Disclosure of Financial Interests and Commitments.

Disclosure is required when the aggregate value of sponsored or reimbursed travel exceeds an estimated $5,000 for an entity in the previous 12 months. The disclosure of each trip should be submitted as it occurs regardless of the estimated value. (i.e. submit all trips from the last 30 days so as to not need to track value). The aggregate value includes:

  • Travel for which the individual is reimbursed by an outside entity
  • Travel that is paid for on the individual's behalf by an outside entity
  • Any registration fees, accommodations, transportation costs, etc.

Concerns by the federal government about the potential loss of intellectual property or inappropriate foreign influence on federally-funded research has led agencies to revise their requirements to achieve greater transparency into investigators' outside activities, including how foreign and domestic researchers are collaborating on federal projects, whether or not they are paid from an award. See agency-specific requirements for details.

Researchers should adhere to the following:

  • Disclose all research collaborations to federal sponsors. In some cases, sponsors require prior approval before engaging in international collaborations directly related to sponsored awards.
  • Disclose all outside research activities, appointments, affiliations, and positions to federal sponsors and Caltech through the Disclosure of Financial Interests and Commitments.
  • Secure any export-controlled information: Visit Safeguarding Export Controlled Data and Safeguarding Export-Controlled Documents, Data & Items
  • Use SciENcv Science Experts Network Curriculum Vitae when possible, to reduce administrative burden. SciENcv is a researcher profile system for all individuals who apply for, receive or are associated with federally-funded awards.
  • Use ORCiD Open Researcher and Contributor ID when possible to attribute publications with the correct researcher. ORCiD is a unique, persistent identifier provided free of charge to researchers. More information may be found at: https://libguides.caltech.edu/orcid.
  • Be aware of sponsor restrictions on access to fundamental research
    • Awards that involve controlled information (e.g., classified information or Controlled Unclassified Information (CUI)) cannot be accepted unless an exception is approved.
    • Awards that include terms requiring approval or excessive delays in publications, or that require approval for the participation of foreign nationals in the project, may delay the start of a project while the Office of Sponsored Research (OSR) negotiates acceptable terms.

Reports and other information on research security:

The Vice Provost for Research has commissioned a working group to review processes and develop recommendations for addressing issues and risks related to hosting visitors on campus. We urge researchers to consult with the following offices before bringing non-US visitors to campus:

More information about updated procedures will be posted here when it becomes available.

The International Offices also offers travel advice for visitors (serving both campus and JPL international scholars):

Federal sponsors require detailed information about research collaborations. Review the agency-specific information for details.

Significant collaborations on NIH-funded projects with non-US entities may require prior approval from the NIH. See the foreign component information under the NIH page.

Also, note the export controls regulations and the shipping guidance above when sending materials or data across the border.



Thank you to Michelle Christy for assistance with this site.