International Collaboration in Research & Scholarship
The ability to engage in open collaboration and academic pursuits including research and scholarship is the hallmark of academe. Boston College works to protect these collaborations and resulting intellectual property through transparency and by supporting and educating the faculty.
Federal agencies have asked researchers to become more vigilant in their disclosures of international research collaborations, affiliations, and activities to protect the integrity of U.S. research and intellectual property. As the Awardee, BC will work with faculty to provide clarity and management of these disclosures. We are closely watching the guidance from the National Institutes of Health (NIH), the National Science Foundation (NSF), and other agencies as they emerge. We encourage faculty to stay abreast of current agency regulations, best practices and BC guidance, some of which are outlined below.
Complete all sections of grant proposals thoroughly, particularly items related to foreign components.
Update funding agencies on new foreign engagements in your annual reporting.
Complete a financial conflict of interest disclosure at the time of proposal development.
Report all intellectual property to Boston College’s Office of Technology Transfer and Licensing (OTTL) to ensure protection. Always check with OTTL before receiving and sending materials both domestically and abroad.
Familiarize yourself with Boston College’s policies related to research agreements and export controls.
Make sure your Boston College Faculty annual report matches the information on your Biosketch.
If you are not sure if a particular international activity must be disclosed it is best to be as transparent as possible and seek guidance from your OSP representative.
Federal grant proposals must be completed thoroughly and accurately. Inconsistencies and errors could jeopardize your funding opportunity or raise flags with federal fundings agencies.
As a reminder, all proposals for external research support must be submitted through the Office for Sponsored Programs and awards should be made to the “Trustees of Boston College.”
Guidelines from specific agencies related to “foreign influence” are outlined below.
NIH requires prior approval of “foreign components”. Disclosures of foreign components should occur at the time of proposal. If there is a desire to add a foreign component after an award has already been made, prior approval is required from the sponsor prior to the start of any work.
NIH grants policy requires the disclosure of your involvement in all ongoing and proposed research projects both domestic and foreign. This is not a new requirement, merely an enforcement of existing policy.
NIH defines “foreign component” as the performance or existence of any significant scientific element or segment of a project outside of the United States. A scientific element or segment of a project can be performed by the recipient or by a researcher, whether or not grant funds are expended. Specifically, any 1) performance by a researcher or subrecipient in a foreign location 2) performance by a researcher in a foreign location employed or paid for by a foreign organization.
Activities that would meet this definition include, but are not limited to:
The involvement of human subjects or animals; extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities; or 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 - n.b. resources include personnel.
There are several sections of the NIH application and Research Performance Progress Report (RPPR) in which foreign collaboration must be disclosed. These include:
- NIH Application Other Project Information page (Question 6) requires you to indicate if this project involves activities outside of the US or partnerships with foreign collaborators. If you check “Yes” to Question 6, you must upload a “foreign justification” document in Field 12, Other Attachments. In this form, you must describe the special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting.
NIH RPPR Participants (Section D1) requires you to list who has worked on the project at least one-person month per year and identify if the individuals’ primary affiliation is with a foreign organization.
NIH RPPR Personnel updates (Section D2) requires you to report if there are will be new/senior key personnel or if there has been a change in other support of senior/key personnel since the last reporting period.
NIH RPPR Impact (Section E4) requires you to report the dollar amount from the budget that is being spent in foreign countries.
NIH RPPR Project Performance Site(s) (Section G8) requires you to report changes to the project/performance site(s) including any new sites where either human subjects or vertebrate animals will be involved.
NIH RPPR Foreign Component (Section G9) requires you to report on Foreign Components (note — Foreign Components require prior approval).
Biosketch: Senior/Key Personnel must list all foreign affiliations and scientific appointments (e.g., positions, honors) they hold in their Biosketches. All of these things should be included whether or not remuneration was received. NIH currently is recommending that any foreign affiliation be disclosed as “relevant” to the proposal.
- Other Support: Other support includes all financial resources, whether Federal, non-Federal, commercial, or institutional, available in direct support of an individual’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts are not included.
- NIH GUIDELINES ON OTHER SUPPORT: “NIH reminds applicants and recipients that other support includes all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, talent programs, including and not limited to financial support for laboratory personnel, and provision of high -value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.”
While NSF has similar requirements to those of the NIH for reporting “Current and Pending Support”, there are differences in between the two agencies. “Current and Pending Support” is defined by the NSF as the support requested or available from all sources of project funding. The NSF particulars are as follows:
Gifts should not be reported. If there is effort associated with the gift, this should be reported as in-kind support.
In-kind contributions with time commitment and will not be used on the proposed project is not required to be reported.
In-kind support with time commitment/effort must be reported in the Current and Pending Support section. If there is no time commitment and the in-kind support will be used on the proposed project, this must be reported in the Facilities, Equipment and Other Resources section.
Start-up funds received from BC are not required to be reported. If you receive start-up funds from another institution, that must be reported in Current and Pending Support.
As with NIH, your foriegn appointments and affiliations must be reported.
All current and pending support from whatever source (e.g., federal, state, local or foreign government agencies, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects) must be listed. The proposed project and all other projects or activities requiring a portion of time of the PI and other senior personnel must be included, even if they receive no salary support from the project(s).
Researchers and Faculty must abide by Boston College’s finance-related policies. In order for Boston College to better support your research, you must be transparent about your collaborations and relationships.
Disclosure of Financial Interests
Faculty must disclose any income or travel reimbursements received from a foreign entity, including governments and academic institutions. For domestic activities, faculty must disclose any income or travel reimbursements in excess of $5,000, including governments and academic institutions.
Gifts and Donations
As a reminder, the solicitation or acceptance of gifts for services rendered in the course of one's normal employment is prohibited.Gifts from domestic and foreign entities of more than nominal value (in excess of $100.00) from individuals or organizations with whom the University does business, or from those who hope to do business with the University in the future, are prohibited. Please refer to the Gift and Entertainment of the Professional Standards and Business Conduct -- General Policy.
Activity reports: Familiarize yourself with BC’s policy on external activites and complete your annual Faculty Report thoroughly, including the forthcoming new sections on international employment, international support, and international patents.
Research agreements: You may not enter into any agreement whether informal or otherwise which restrict publication or the sharing of research results. Publication restrictions in research can only be negotiated by University officials who have delegated authority to accept contracts and grants.
- Export control: You must comply with U.S. export control regulations when doing any of the following: traveling internationally and attending conferences, participating in international collaborations, using proprietary information, working with international staff and students, hosting international visitors, shipping materials internationally, or engaging in any international transactions.
- Intellectual property: To ensure that all intellectual property is protected and, when required, appropriately reported to sponsors, all BC employees are expected to promptly disclose intellectual property and any improvements or changes to existing intellectual property to BC Office Office of Technology Transfer and Licensing.
Please use the following links to review the most up to date frequently ask questions from federal sponsors:
If you have questions, please contact Sharon Comvalius-Goddard, Director, Office for Sponsored Programs at firstname.lastname@example.org.