International Relationships and Activities
Stony Brook University remains committed to the principles of academic freedom and the open exchange of knowledge, which serve as the bedrock of research and scholarship. Our faculty and students are encouraged to participate in international collaborations, as these may promote the creation of knowledge and enrich learning experiences. However, such collaborations should be transparent and disclosed in a manner consistent with applicable requirements, including those of federal and state agencies, as well as Stony Brook’s own policies.
US Government funding agencies, including the National Institutes of Health (NIH), the National Science Foundation (NSF), the Department of Energy (DoE), the Department of Defense (DoD), and the National Aeronautics and Science Administration (NASA), have recently expressed serious concerns of inappropriate influence from foreign sources over federally-sponsored research at universities and other institutions in the US. These concerns arise partly from the potential for unauthorized transfer of confidential information and intellectual property resulting from federally-funded research to entities in other countries and the associated impacts to economic and national security. As a result, agencies have increased their scrutiny of sponsored research activities that involve foreign connections and support. Furthermore, agencies have revised their requirements for disclosing international connections and other support from foreign sources, which are described on this webpage.
Stony Brook University takes these concerns seriously, and we are committed to ensuring compliance with federal, state, and institutional regulations. We also recognize the importance of maintaining an open exchange of knowledge, which requires balancing these principles, while also ensuring that we do not create an environment that is hostile to dedicated colleagues because of their nationality.
Disclosure of Relationships and Activities
Investigators should familiarize themselves with the information provided by OVPR as well as specific guidance from their respective funding agency. Ultimately it is the Investigator's responsibility to appropriately disclose international relationships, activities and components in accordance with internal and external policies.
We strongly encourage investigators to err on the side of transparency when considering or reporting a foreign activity. At some institutions, failures to disclose foreign connections or other regulatory violations have resulted in personnel actions and even indictments by law enforcement. Some federal funding agencies have stated that investigators who fail to disclose appointments or support from foreign entities may be ineligible to receive funding.
Definitions of terms may differ by sponsor as the federal agencies have not adopted standard definitions or reporting requirements. Investigators should read sponsor guidelines and requirements to ensure that they are disclosing and reporting in accordance with the specified agency.
Presently, there is no uniform practice among federal funding agencies for disclosing international relationships, activities or components of research activities. There exist multiple ways in which such disclosures may be included in grant proposals and progress reports, depending on the funding agency. In addition, funding agencies provide guidelines for information to be included in publications resulting from grants and contracts. They also generally require that all publications resulting from sponsored research must be reported, typically in annual and final progress (or technical) reports.
PROPOSALS AND AWARDS
- Approach the Office of Sponsored Programs (OSP) if your proposal includes foreign collaborations, foreign components and/or activities in a foreign country. Outreach early and discuss with your OSP Specialist as they will provide you with current institutional and Sponsor policies/guidelines.
- Read sponsor guidelines, Funding Opportunity Announcements (FOA), and proposal questions (i.e. NIH Other Project Information Form Question #6 asks "Does this project involve activities outside of the United States or partnerships with international collaborators?") carefully to ensure that you and other project personnel are correctly answering the questions that address foreign engagements, foreign affiliations, and Foreign Components and collaborations, as required by the sponsor.
- At award stage, review agency definitions to verify that your interpretation of your sponsor's terms and conditions included in a notice of award and grants policy statements is correct. The Office of Sponsored Programs and your sponsor's program and grants management staff can be contacted with questions about definitions.
- Review current projects to ensure that all locations outside the U.S. where significant scientific activities are performed have been disclosed through progress reports and final technical reports (as applicable).
- Review each funding application to ensure that all resources available in direct support of an individual’s research activities (Other Support) is disclosed as required by the federal sponsor at the time of proposal submission, Just-in-Time/pre-award negotiation and post-award
- Identify foreign countries where the research activities are being conducted.
- Obtain Sponsor prior approval through OSP when adding a foreign component to an existing federal award.
- Determine if sponsor approval is required for international collaborations resulting in co-authorship.
- Cite in manuscripts only the funding which specifically supports the work in the publication.
- Do not cite unrelated financial support in publications.
- Check the funding agencies guidelines for information to be included in publications resulting from grants and contracts.
- Carefully review the sponsor's guidelines for reporting publications in reports (i.e. progress or final) as some sponsors differentiate between publications where funding specifically supported the work in the publication and all other publications.
FOREIGN TALENT PROGRAMS
- Disclose participation in foreign talent programs to federal sponsors and the university.
Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government -Supported Research and Development definition: “Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.”
Department of Energy definition: Distinguishing features of a foreign government talent recruitment program (covered by this policy) include:
(a) Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring knowledge and expertise to the foreign country. The compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or other consideration.
(b) Recruitment refers to the foreign state sponsor's active engagement in attracting the targeted individual to join the foreign-sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the United States, or in the foreign state.
Note that, generally, an invitation by a foreign state to simply attend or present work at an international conference would not constitute recruitment.
Contact the Director of Research Security or the Vice-President for Research if you have not disclosed participation in a foreign talent program to discuss the activity.
Article of Interest to NIH funded investigators
Why Properly Acknowledging NIH Support in Your Paper is Important by Dr. Michael Lauer (April 19,2021)
The Office of the Vice President for Research (OVPR) continues to monitor new regulations and guidance provided by funding agencies regarding foreign relationships and activities, and we will inform the University community of relevant changes. Updates and new information will also be provided on this page.
- Department of Defense
- Department of Energy
- National Aeronautics & Space Administration
- National Institutes of Health
- National Science Foundation
University Policy P209 requires reporting of positions and appointments at institutions other than SBU, whether paid or unpaid, as well as other support provided by entities other than SBU or RF, whether monetary or non-monetary in form.
Additional information is available on the Conflict of Interest and/or Commitment website.
Federal Government: Policy/Communications
Current and historical information from the federal government regarding foreign influence in U.S. research.
APPOINTMENTS AT FOREIGN AND DOMESTIC INSTITUTIONS
Faculty should follow the Approval Process for Faculty Members who are Offered Appointments at Foreign and Domestic Institutions issued by the Office of the Provost for appointments at foreign and domestic institutions.
OUTSIDE CONSULTING WORK
Faculty should follow the Outside Consulting Work Policy issued by the Office of the Provost for outside consulting engagements.
Faculty and staff are not permitted to complete (i.e., sign) any agreement with a foreign entity. Click here to find the appropriate campus office for your agreement.
International travels are required to register all international travel on sponsored research awards in the Concur Request Module.
Travelers should review IT Security Considerations While Traveling guidance.
Invitations to, and visits by, international visitors must comply with SBU Guest/Visitor Policy P601.
Faculty and staff who engage in international activities must comply with U.S. federal export control regulations ( SBU Policy P212). Specific information on export controls and how to comply is available on the Export Compliance website.
DATA SECURITY/SECURE COMPUTING
Faculty, staff and students should be familiar with the university requirements for data security and secure computing.
Securing data and secure computing
Security policy and compliance
RESTRICTED PARTY SCREENING
A Restricted Party Screening should be completed prior to engagement with a foreign person or entity. A guidance document and access to software is available here.
Ensure that intellectual property is protected.
- Disclose intellectual propery as required to sponsors.
- Disclose any potential inventions or other intellectual property to Intellectual Property Partners (IPP).
- Use the proper agreement (i.e. material transfer agreement (MTA), data use agreement (DUA) or non-disclosure agreement (NDA) when exchanging materials, data or other confidential/non-public information. Only authorized SBU/RF offices can sign these agreements, review the chart here for further guidance.
- If you are involved in a startup based on licensed technology from SBU, the company should disclose to IPP any investments, partnerships, or sublicenses made with foreign entities.