Research Compliance  /  International Collaboration  /  Frequently Asked Questions

Frequently Asked Questions

Updated June 9, 2021

Below are answers to frequently asked questions. These will be added to as questions are submitted. If you have any other questions, please contact caltechcoi@caltech.edu.

  1. Do the prohibitions towards Foreign Talent Recruitment Programs apply only to PIs/co-PIs, or do they apply to students and postdocs involved in the DOE-sponsored research? For example, what if I have a postdoc scholar supported by a DOE grant who is interviewing for or has accepted a position in China?

    If the postdoc is interviewing for but has not accepted the position yet, this is not an issue. If the postdoc accepts the position, there may be an issue. Please contact the Office of General Counsel.

  2. Who do we contact for issues related to IP, specifically, how it should be divided in these collaborative situations? Can you provide borderline examples?

    Please contact the Office of Technology Transfer and Corporate Partnerships (OTTCP) for IP concerns.

  3. Is the participation of a foreign national student or postdoc on a sponsored research project considered a reportable foreign component?

    No, as per the National Institutes of Health (NIH), as long as the fully or partially foreign-funded student, postdoc, researcher, or visiting scholar is working exclusively within the United States, the participation is not considered a reportable foreign component.

    However, any work that such an individual continues to perform under an NIH grant after leaving the U.S. would need to be disclosed and approved by the NIH as a foreign component. In addition, any support that such an individual, if key personnel on the project, receives from a foreign organization would be reportable to NIH as Other Support. See the NIH Compliance page for more information.

  4. A postdoc in my lab was awarded a fellowship from a Foundation in France. A stipend is paid directly to him. Do I need to disclose this award as "in-kind support" ?

    Yes, it is considered as a financial resource which directly supports your research endeavors. Federal sponsor reporting requirements vary on this matter. See the Federal Agency Compliance and Communications page for specific agency information.

  5. I am a Principal Investigator on an NIH award to a domestic university and have an unpaid appointment at a foreign university. At the foreign site I have access to lab space, research materials, and staff. Should I report this as Other Support?

    Yes. While the researcher is not receiving monetary compensation, the lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts. NIH requires applicants to list all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

  6. A researcher in my lab has a 9-month appointment. They spend two months at a university outside of the United States during the summer conducting research under a foreign award. Does this need to be reported?

    Yes. Available resources in support of and/or related to an investigator's research endeavors should be disclosed even if they relate to work that is performed outside of a researcher's appointment period. The researcher should report this immediately through the Disclosure of Financial Interests and Commitments. In addition, if the person is named as an investigator/key personnel on an NIH grant here at Caltech, details of the award, effort, scope and other information must be included in their Other Support, and a copy of the proposal and any agreement for that appointment must be submitted to Caltech immediately.

  7. I am collaborating with another scientist in the US, whose experiments have directly benefited my research. Their experiments were conducted with funds awarded to their institution. Should this be reported as Other Support?

    Yes. Other Support includes domestic research collaborations that directly benefit the researcher's research endeavors.

  1. Do I only include paid positions on my Biosketch?

    No, include the positions, whether or not you receive compensation. NIH requires the positions be list on the biosketch if related to your application. NSF may require it be listed on the biosketch regardless of relevancy. Be sure to disclose all unpaid relationships to Caltech through the Disclosure of Financial Interests and Commitments

  2. Work on this project will be conducted at another institution at which I have an appointment. Do I need to report that appointment?

    Yes, include the appointment on biosketch, and perhaps also Other Support, depending in the sponsor's requirements. If the other institution is outside the U.S., it may be considered a "foreign component", which requires prior approval for NIH-sponsored awards. Check the Federal Agency Compliance and Communications for specific agency information.

Do we have to pay attention to Controlled Unclassified Information (CUI)?

Caltech's policy is not to accept awards that require the use of CUI. If compelling circumstances exist such that a PI believes that an exception to the policy should be made, contact OSR to discuss the particular matter. Note that sponsors sometimes mark material as CUI when it is not supposed to be. If you believe this has happened or have questions about CUI, please contact the Office of Export Compliance.


Since answers to some questions vary depending on the agency, we have created pages specifically for those with NIH funding and for those with NSF funding.