International Engagement

International engagement is often a foundational element of successful research and scholarship, and the University of Michigan remains committed to supporting and safeguarding this important activity with integrity, transparency and trust. Partnering with individuals and entities outside U-M allows teams across all three campuses to push the frontiers of knowledge and discovery so that researchers can work together to find solutions to the world’s most urgent problems.

International Research Engagement Town Hall

January 11, 2022

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Best Practices

Disclosures of international collaborations can occur in multiple areas of research and scholarship activity.  U-M’s current research administration and compliance processes assist researchers to appropriately identify and report their international collaborations.  Expand the sections below to review the U-M disclosure guidance.

Ethiopia

Research Funding Proposals & Awards

  1. Identify foreign components on federally sponsored research proposals, progress reports, and final technical reports. (NIH)

Per the National Institutes of Health (NIH), the following activities are considered a foreign component:

  • Research at a foreign site involving human subjects or animals;
  • Extensive foreign travel for the purpose of data collection, surveying, sampling, and similar activities; and
  • Activities that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country (e.g., through an impact on another country’s wildlife, population, or environment).

The NIH may also consider the following activities as a foreign component:

  • Collaborations with investigators at a foreign site anticipated to result in co-authorship;
  • Use of facilities or instrumentation at a foreign site; and
  • Receipt of financial support or resources from a foreign entity in connection with performance that occurs at a foreign site.

In the NIH grant application forms, a foreign component may be identified by:

  • Indicating “yes” to the “activities outside the US/partnerships with international collaborators” checkbox on the Research & Related Other Project Information form; and
  • Listing a non-US project/performance site location.
  1. Report all resources for research, including those from foreign entities, in Other Support Reporting for NIH, or Current and Pending Support for NSF and other sponsors. (NSF and other sponsors)

This includes any research support you receive.  Examples include, but are not limited to:

  • Active & Pending awards/gifts received and managed by U-M;
  • Active & Pending awards/gifts provided or managed by external entities (including non-U.S. entities);
  • Unpaid research conducted outside your U-M role;
  • Other non-U-M monetary resources (including external employment start-up packages);
  • Equipment, personnel or research material provided by any non-U-M organization;
  • Consulting relationships relating to your expertise that involve the design, conduct, or reporting of research; or
  • Funds received from a foreign recruitment program (e.g., China’s Thousand Talents Program or other “Talents Programs”).

Per NIH, “Other Support” includes all foreign and domestic resources made available to a researcher in support of or related to their research, regardless of whether or not the resources have monetary value. Other Support is reported to NIH prior to the award activation as part of the “just-in-time” (JIT) process, as well as in progress reports submitted to NIH.  Pending applications for support should be reported as part of the JIT process, but such support does not need to be identified in progress reports until it is committed by the sponsor.

For National Science Foundation (NSF) awards, financial and non-financial resources made available for research should be reported.  Per the NSF, “Current and Pending Support” includes “all current project support from whatever source” and “all other projects or activities requiring a portion of time [i.e., commitment] of the principal investigator (PI) and other senior personnel must be included, even if they receive no salary support from the project(s).” (NSF Grant Proposal Guide, Chapter II)

  1. Compile your Biographical Sketch (Biosketch) for federal research proposals following the appropriate agency guidelines. Be sure to include all appointments/affiliations/employment outside U-M that are related to your U-M area of expertise (including full-time, part-time, voluntary, adjunct, visiting, honorary, those labeled as “guest”, paid or unpaid, domestic or outside the U.S., and appointments/affiliations likely to be cited in publications).

The COI Offices provide the institutional review of Other Support documentation that include international engagements. For details, see the Other Support Review website.

FOR EXISTING AWARDS

  • Foreign Components: The NIH requires its prior approval whenever a significant part of a project will be performed outside of the United States, regardless of who is doing or whether or not the work is funded.  To add/amend a foreign component on an existing NIH award, use the “Request Action” activity in the eResearch Proposal Management (eRPM) system to create an Award Change Request (ACR) and upload a “Foreign Justification” document for ORSP to submit to the NIH for consideration.  If the NIH approves the foreign component, include the Foreign Justification document in the annual (or final) Research Performance Progress Report (RPPRs).
  • Other Support/Current & Pending: Provide updates regarding active sources of Other Support/Current & Pending via any annual progress reports (RPPR) for the project.

IMMEDIATE NOTIFICATION REQUIRED

  • Immediately notify the Other Support Review team at Other.Support.Questions@umich.edu if previously undisclosed sources of Other Support were not correctly included in the initial proposal, JIT, RPPR, etc.

Outside Interest Disclosure

All investigators on Proposal Approval Forms (PAFs) and Awards (AWDs) are required to disclose in M-Inform (the University’s outside interest disclosure system) any outside activities, relationships, and interests that are associated with their U-M responsibilities or area of scholarship, including those of their spouse, domestic partner, or dependents (Policy for Identification and Management of Conflicts of Interest in Research, Sponsored Projects, and Technology Transfer). These disclosures are reviewed by the COI Offices to determine if the activity is related to, and may unduly influence, the U-M research, resulting in a conflict of interest.

This includes disclosing, for example:

  • Appointments and/or visiting scholar affiliations at institutions outside the U.S.;
  • Participation in, as well as payments or items of value received from foreign recruitment programs (i.e., “Talents Programs”); and
  • Travel reimbursements from foreign institutions outside the U.S.

See the Outside Interest Disclosure Process website for more information about disclosure requirements and processes.

Publications

If you have a collaborator who is going to conduct a part of your NIH-funded research project outside of the United States and that research may result in a co-authored publication, it is important that you obtain prior approval from the NIH for the collaboration (i.e.,  a foreign component).  Any publication that subsequently arises or results from the collaborative research must be reported to the NIH in progress reports.

The publication itself should also acknowledge NIH support and any support from a foreign entity, individual, or government (if applicable).

Restricted Party Screening (RPS)

It is an institutional best practice to conduct the restricted party screening (RPS) process before entering into international collaborations in order to confirm there are no restricted entities/individuals involved.

U-M central offices, such as the Office of Research and Sponsored Projects (ORSP), Procurement, Innovation Partnerships, and the Office of University Development, conduct RPS as part of their standard business processes (e.g., ORSP runs RPS on proposed sponsored research).  Some schools/colleges, such as the College of Engineering, run RPS prior to authorizing visiting scholars and other visitor access to university facilities.

Prior to initiating research-related activities (e.g., travel, shipping equipment or physical items overseas, giving presentations at international institutions), you are expected to request restricted party screening from the U-M Export Controls Office (exportcontrols@umich.edu).  For details on how to request RPS and additional examples, see the Restricted Party Screening (RPS) website.

Gifts & Donations

U-M is pleased to work with benefactors from around the world to increase private support for important research and programs.  In doing so, we follow a careful process to review the sources of philanthropic funding and determine what, if any, expectations may be attached to such funding.

Per U-M SPG 602.02 Gift Acceptance, only the University President, Chancellors, Chief Financial Officer (CFO) and the CFO’s written designee (e.g., Vice President for Development) have the authority to accept private gifts and donations from individuals, corporations, foundations, and associations. Report all gift solicitations from domestic and international sources to the Office of University Development or the development office within your school, college, or unit. 

For questions related to international conversations regarding gift or donations, please contact the International Giving and Engagement team within the Office of University Development.

International Travel Registration

Faculty and students travelling internationally for research purposes, including attending conferences or participating in international research collaborations, must comply with the U.S. Export Control regulations.  It is advisable to report your travel plans weeks before you leave by using the Faculty & Staff Travel Registry or the Student Travel Registry (Compass), as applicable, to allow enough time to work with the U-M Export Controls Office to determine what, if any, protections may be required based on the location of the travel and/or the technology/data you are taking with you.

For details, see the International Travel & Export Controls website.

Invention Reporting

All employees have an obligation to report intellectual property and any improvements to existing intellectual property promptly to Innovation Partnerships via an invention disclosure, per U-M SPG 303.04 Technology Transfer Policy.

See Innovation Partnerships’ Submit Your Invention website for more information on the invention disclosure process.

Federal Reporting of Foreign Gifts and Contracts

Section 117 of the Higher Education Act (HEA) of 1965 requires that institutions of higher education participating in Title IX student assistance programs must report incoming gifts or contracts from a foreign source that, alone or combined, have a value of $250,000 or more for a calendar year.

See the HEA 117 Reporting FAQ for more information about the University’s disclosure requirement and reporting processes.

FAQs

I am afraid to disclose international activities because it might make me a target for government scrutiny. What should I do?

We understand the concern, but it is always better to disclose than have to explain to a federal sponsor why a required disclosure was not made when they discover it. Federal agencies are using data analytics to proactively identify undisclosed Other Support and affiliations with international entities, so one cannot count on non-disclosure as a means to avoid government scrutiny.

In a positive development, recent guidance from the Office of Science and Technology Policy to federal funding agencies states that, “Agencies should strongly encourage self-disclosure and correction of omissions and inaccuracies, including by ensuring that self-disclosure will be taken into consideration during the process of administrative resolution of noncompliance with disclosure requirements, and by publicly highlighting circumstances or instances where this occurs, where appropriate.”

What is the role of the U-M Office of the General Counsel with respect to faculty if the government takes legal action?

The OGC will have an integral role on behalf of the University in overseeing a government investigation or other government action.  The OGC’s role with respect to an individual faculty member will depend upon the faculty member’s role and involvement in the matter.

The University’s SPG 601.09 provides that it is U-M’s policy to defend (pay legal expenses) and indemnify (pay settlement or judgment) employees who become parties to legal proceedings by virtue of their good faith efforts to perform their responsibilities of employment.

OGC is involved in the implementation and administration of this policy. 

If there are problems or concerns identified with a disclosure that do not rise to the level of a legal proceeding, the relevant offices (ORSP, COI, Departments, etc.) would work to review and correct whatever the potential problem may be. Depending on the issue, this could involve updated documentation that needs to be submitted to sponsors, updated disclosures needed in the U-M systems or other actions.

I am on a 9-month academic year appointment. Why do I need to upload contracts to the NIH involving my activities during the summer months?

NIH requires this information in order to assess whether there is any conflict of interest or commitment or any scientific, budgetary or effort overlap between the work it intends to fund and your outside activities during the summer months. This is especially important when you are requesting summer months salary in your NIH proposal.

Are investigations into disclosure concerns being handled consistently across faculty and countries?

A majority of the federal investigations appear to be focused on faculty associations with China, and not other countries, which leaves some uncertainty as to whether all disclosures are under the same government scrutiny. 

U-M carefully reviews all disclosures that involve an international component, regardless of the country involved.

What are the guidelines we should follow if we are involved in or offered a contract with an international partner (e.g., thousand talents)? What are the consequences?

When faculty pursue outside activities, such as consulting or other contracts, it is important to make sure that all University policies are being followed – including policies related to use of University resources, intellectual property and data. It also includes making sure that all disclosure obligations are met, including those related to Other Support, potential Conflicts of Commitment and/or Conflicts of Interest.

Depending on the proposed activity, there may be COI and/or COC management needed. If you are considering an outside activity with an international partner and have questions about compliance with U-M policy, it is important to reach out for help. Generally speaking, engaging with an international partner via private contract as an outside activity is permissible, so long as that activity is appropriately disclosed and all U-M policies are followed.  

It is also important to note that some federal research sponsors – including the U.S. Department of Energy and DARPA – have agency-specific rules regarding the participation in foreign talent programs such that participation in a talent program could result in denial of an award or not being eligible to receive funding from those agencies. If you are considering participating in one of these programs and/or have questions about potential impacts on federal funding or whether they may cause conflicts of interest or commitment that violate U-M policies, it is important to reach out to the teams here for help navigating that space.

Should faculty collaborate or do anything with China?

Absolutely, as long as it is consistent with U-M and sponsor policy and is disclosed appropriately. We can help the faculty determine whether the activity complies with those policies, and we therefore encourage faculty to reach out to us with any questions they have as they consider entering into these activities.

I am concerned that filing foreign patents may result in extra scrutiny. Should I avoid doing so to reduce the potential of raising a red flag?

We encourage you to disclose the invention to Innovation Partnerships, who will work with you to ensure that appropriate disclosures are made to ensure compliance with applicable policies and regulations. Innovation Partnerships has a variety of resources available to assist you with the translation of your research discovery through commercialization.

What are the consequences for failing to follow relevant disclosure requirements?

The most important thing you can do is understand and adhere to the disclosure requirements and avail yourself of the resources available to support you. The consequences for not following the disclosure requirements are decided on a case-by-case basis, depending on factors like the seriousness of the violation, the impact, whether it was unintentional or intentional, and other similar factors.

With respect to consequences beyond the University, federal sponsoring agencies may pursue additional actions. Note that false, fictitious, or fraudulent statements or claims (including omissions) to federal sponsors may result in criminal or civil enforcement actions.

 

As a faculty member with an academic year appointment, what business is it of U-M or NIH to know (or even ask about) what I do during my free time or who I spend my time with?

 SPG 201.65-1, which was revised in December 2021 to account for changes covered in today’s (January 11 town hall) materials, and the unit CoI/CoC implementation policies, set out CoI/CoC expectations and procedures for faculty and staff.

In particular, the SPG provides in part that:

Faculty and staff members have the right to acquire and retain outside interests that do not conflict with University interests or with the individual employee’s commitment to the University…

Faculty and staff members must meet the specific responsibilities and professional activities that constitute their appropriate [university] commitments…

All faculty and staff members must disclose all actual or potential conflicts of interest or conflicts of commitment…as potential conflicts arise or are identified.

In addition, when sponsored funding or technology transfer is involved, a faculty or staff member must disclose actual or potential conflicts of interest or commitment to the appropriate research conflict of interest committee…

A faculty or staff member must also provide additional relevant information concerning disclosed or undisclosed matters as may be requested… 

If required, [the university] will develop a [management] plan in consultation with the faculty or staff member…

Where is U-M’s responsibility in getting faculty disclosures right?

U-M has policies and procedures in place to help ensure that faculty disclosures related to funding applications submitted through U-M are indeed true, accurate, and complete. This includes the U-M policies requiring faculty disclosures related to outside activities and Other Support. We must rely on our investigators who have direct knowledge of all of their Other Support and outside activities to fully disclose, so that we can help ensure that those disclosures are appropriately reflected in what is submitted to sponsors. 

The University also offers education sessions, as well as resources and guides to help faculty navigate disclosure obligations. Many of these resources are linked on the OVPR International Engagement webpage. The teams here today (January 11 town hall), from COI and ORSP, are also always available to answer questions and help navigate the disclosure obligations.

I regularly engage in activities with international entities where I receive an honorarium for my efforts. What must I report to U-M and to a federal agency as Other Support for each of the following circumstances: (a) I give a talk at a university in another country, (b) I review a research center in another country, (c) I review a research proposal from another country, (d) I edit an international journal that is based in another country.

In each circumstance the activity and accompanying honorarium must be disclosed in M-Inform as an outside activity, however, these activities do not need to be disclosed in Other Support. Note that if you receive an honorarium from an international entity, it is U-M’s longstanding requirement to disclose the honorarium in M-Inform if it was received within the past 12 months. Honoraria payments older than that may be disclosed at the investigator’s discretion. 

What is the process for correcting innocent mistakes in the disclosure process?

If the innocent mistake was made in M-Inform, the investigator needs to update their disclosure with the correct information.  If the mistake needs to be corrected on sponsor documentation (e.g., Biosketch, Other Support, Current & Pending), the investigator should notify Other.Support.Questions@umich.edu for further guidance. Depending on the specifics of what has not been disclosed, the information may need to be reported immediately to the relevant grants management specialist and program officer, or may simply need to be included in the next annual Research Performance Progress Report.

What should I do if I’m contacted by a law enforcement agency?

If U-M faculty or staff are contacted by law enforcement seeking U-M documents, U-M property, or otherwise relating to the University or their role at the University, they should contact campus law enforcement and OGC. Additional details and campus-specific contact information are available in the FAQ on the U-M OGC website.

Can we anticipate other federal agencies will implement requirements similar to those of NIH for Other Support reporting?

There will undoubtedly be changes from other federal agencies, although at this time the changes are unknown. The federal agencies have been instructed by the White House to harmonize their Other Support requirements to the extent it is practicable.

As a faculty member, I would appreciate a grace period for correcting errors and discrepancies in my disclosures.

We would welcome a grace period as well, but could only grant a grace period if the federal agencies’ policies and regulations afforded us the opportunity to do so. At present, we are not aware of any prospect that this will happen.

On January 4, the White House issued guidance through its Office of Science and Technology Policy about implementation of the Presidential Memorandum dealing with international engagement, and requested comments/input within 90 days. How will UM participate in this process?

We will be carefully reviewing the guidance document and determining how best to respond. We will also be providing input on the University’s position through our participation on the Council on Governmental Relations and similar professional organizations.

How does the University engage with federal law enforcement? Would OVPR inform a PI if they were being investigated by the FBI under the China Initiative?

The University fully cooperates with federal law enforcement agencies. What that engagement consists of will depend upon the nature of the federal law enforcement contact and the facts and circumstances surrounding the matter. Whether and when the University might inform a PI of an investigation will depend upon the facts and circumstances of each situation.

Are there any key elements that should be incorporated into research projects (and their associated data use agreements) involving sites that must adhere to the European Union’s General Data Protection Regulation?

If you are planning a research project that involves sites subject to the European Union’s General Data Protection Regulation or GDPR, it is important to work with the applicable IRB and ORSP to ensure that all needed documentation is in place for compliance.

Does U-M value, support and encourage and advocate for collaboration with Chinese colleagues in China?

U-M supports all collaborations that are compliant with U-M and federal sponsor policies. In addition, our federal relations team has been actively engaged with federal policymakers to safeguard and protect university research enterprises and the international collaborations that have made this nation a global leader in innovation.

We operate Limited Data Set registries in our work group. We are encountering issues with the European Union’s General Data Protection Regulation. What items are critical to getting a functional agreement? Is Date Of Birth allowed? Is consent necessary?

It is difficult to give specific advice for a particular research project. There are contexts when the European Union’s General Data Protection Regulation (GDPR) does require consent, and contexts in which date of birth information could be used for research. The key to ensuring a functional agreement that is compliant with GDPR is to reach out for help from the central offices. Both IRBMED and IRB-HSBS have GDPR information available on their website, as well as the U-M ITS Safe Computing site. ORSP will also help to put needed agreements in place related to Data Use.

Other universities have trained people to help faculty fill out the forms. What has U-M done to aid faculty or to offer consultations to faculty while they fill out their forms. Can we have a contact of who we can call to walk us through this?

The staff at COI and ORSP are trained and always available to help faculty navigate the system. The contact information for COI is COI.Support@umich.edu and for ORSP is Other.Support.Questions@umich.edu

NIH’s guidance and process for disclosing is confusing. Where should faculty who want to get help getting it right go?

COI and ORSP staff are always available to help: just email or call them. In addition, COI staff hold special open office hours during the July M-Inform disclosure period, during which one can connect at your convenience via Zoom. The contact information for COI is COI.Support@umich.edu and for ORSP is Other.Support.Questions@umich.edu.

Other universities have been vocal about the situation. What has U-M done publicly?

Actually, you can include Michigan in the category of universities that have been vocal on these issues. Michigan is believed to be the only university that has publicly expressed concern over policies that would negatively impact our ability to collaborate internationally. President Schlissel and university leaders, including Vice President for Research Cunningham, have publicly supported our international students, postdoctoral scholars and faculty, and emphasized the role these scholars have played in enriching our institution through teaching, learning, research and impact on society.

How is U-M to be present on the national stage; to provide a voice in shaping national dialogue on academic freedom, national security, and anti-Asian actions. We say we are the #1 public research university. What are we doing nationally?

Without going into specifics, we can share that the office of federal relations is actively working with our associations on these issues. Our office, located in Washington, DC, advocates and supports the university on all federal issues that impact our ability to educate and conduct research. We do this by working closely with key congressional members in the Michigan delegation and staff working on committees with relevant jurisdiction. Over the years, the university has become a trusted resource for congressional staff working on research and security issues and has been a leader among our university colleagues.

What is OVPR doing to alert PIs about the China Initiative? What is OVPR doing to facilitate compliance specifically in relation to this?

We are holding town halls, providing information in email newsletters, and have developed a webpage, all devoted to international engagement.

How do you define "international entity"? Are domestic affiliates of foreign companies "international"?

An international entity is one located outside of the United States (U.S.).  “International” in this context does not refer to a U.S. entity that does business internationally (e.g., not General Motors), but rather an entity that is formed outside the United States. If an investigator signs a contract/agreement with a U.S. subsidiary of an international “parent” company, the U.S. subsidiary is not considered an international entity.

NIH and NSF have publicly announced their requirements and policies, but what about DoD?

DoD has been relatively quiet compared to NIH and NSF. Moreover, each DoD component (e.g. ARO, AFOSR, DARPA) has its own set of rules and regulations for disclosing Other Support, appointments, positions, affiliations and international collaborations. For this reason, it is difficult to go into great detail here. We instead encourage investigators to reach out to COI or ORSP staff with their specific questions.

Who reviews information about disclosed activities? Who decides whether they are problematic?

Investigator disclosures in M-Inform are reviewed by Conflict of Interest office staff, who have been trained to recognize potentially problematic activities.

My understanding was that all faculty at U-M needed to fill out a Conflict of Commitment form each year, whether or not they are on a current PAF. Are only researchers with a PAF required to disclose?

All faculty must report all conflicts of commitment to their schools/colleges and/or departments, which could include disclosing in M-Inform. However, faculty who are listed on PAFs and/or Awards (AWDs) must also disclose in M-Inform because of University and funding sponsor requirements.

Would PI travel outside of the U.S. solely to attend/present at conferences constitute a foreign component?

No. Travel outside the U.S. to attend/present at a conference would not constitute a “significant scientific element or segment” of the project. However, if you receive an honorarium from either a domestic or foreign entity to present at the conference then this needs to be disclosed in M-Inform.

Should a completed relationship be reported? Per your example about a visiting scholar at Kyoto University, what if the person was a visiting scholar two years ago when they were on sabbatical, but they are not currently a visiting scholar?

NIH staff clarified on June 8, 2021 in response to a reader’s comment in an NIH extramural NEXUS article that, “The Biosketch must include all active positions and scientific appointments. Positions and appointments that have ended are optional if the applicant wishes to highlight them in support of their application.” [emphasis added] NSF requires that investigators include all current and previous academic, professional, or institutional appointments.

Is it a "foreign component" if I am temporarily relocating to a foreign country and conduct some research while there (not requiring any foreign equipment, space, etc.)?

Generally speaking, if research on an NIH project is being performed outside the U.S., then it is a foreign component. If in doubt, err on the side of caution and seek prior approval from NIH, as all foreign components require pre-approval by the NIH.

Additionally, working from a foreign country can present a number of HR, tax, immigration, and other unique concerns depending on the specific circumstances. Refer to the HR website on remote work for additional details and requirements for establishing a remote work agreement.

Several faculty have approached me asking if they need to report service as a reviewer or a guest lecturer (over zoom) to an entity in China. This seems to be something that needs to be on a Conflict of Commitment form. Does it count as a foreign appointment for the purposes of a PAF/grant application?

U-M’s understanding of agency guidance is that service as a grant reviewer or guest lecturer does not need to be included in a federal proposal as a foreign appointment, provided that such service is not related to having a position, scientific appointment, or other affiliation with the entity for whom the service is being provided. Depending on the circumstances (e.g., you receive an honorarium for your service), you may need to report this outside activity in M-Inform.

As it relates to current and pending support in NSF forms, the guidelines say that internal support should be included. Should I include Collegiate professorship support and Department support, such as computer funds?

No. Unrestricted gifts are not required by NSF to be listed as Current and Pending Support, provided that the gift was given without expectation of anything in return. Internal funds need only be reported as Current and Pending Support if they are allocated toward a specific project.

How do we deal with active sharing of data and information online between inside and outside U.S. entities during collaborations.

With respect to collaborating with a research partner in another county, which would include sharing  research data online, the first question to consider is whether the collaboration was approved as part of the original funded proposal or if it requires prior agency approval. Once agency approval is obtained, the investigators and/or their respective institutions may wish to establish a Data Transfer and Use Agreement to clarify rights and responsibilities regarding the shared data.

In the event the collaboration involves data or other technology that may be subject to export restrictions, please refer to the Research Ethics and Compliance Export Controls webpage for additional information.

I would imagine everyone might make an honest mistake despite best efforts to disclose. Is there support if there are any issues when mistakes happen?

If the innocent mistake was made in M-Inform, the investigator needs to update their disclosure with the correct information.  If the mistake needs to be corrected on sponsor documentation (e.g., Biosketch, Other Support, Current & Pending), the investigator should notify Other.Support.Questions@umich.edu for further guidance. Depending on the specifics of what has not been disclosed, the information may need to be reported immediately to the relevant grants management specialist and program officer, or may simply need to be included in the next annual Research Performance Progress Report.

During these confusing times in the past few years, what has the university done to directly work with funding agencies to push back for some unreasonable new disclosure requirements, although many other requirements are reasonable? Did we do anything or we just do whatever funding agencies ask us to do without any discussion with them.?

U-M works with national organizations such as the Association of American Universities (AAU), Association of Public and Land-Grant Universities (APLU) and the Council on Government Relations (COGR), among others, on issues related to federal disclosure requirements. The University also works directly with key White House agency officials and agency staff when, and if, appropriate.

Since there is extra scrutiny for China, is there extra scrutiny for domestic companies with Chinese interests (e.g. a U.S. company has significant presence in China, gets funding from China or the CEO who holds Chinese citizenship)?

If the country is headquartered in the U.S., interactions with that company are not considered to be international engagements. An example would be General Motors.

If a foreign entity would like to license U-M patents and work with faculty to establish a startup now in today's environment, is this encouraged by the university? Or should this not be done in today's environment?

There are ways that this activity can be managed that are compliant with federal laws and regulations. Innovation Partnerships is available to help you navigate this process.

If I travel to another country to give a seminar, and the host institution reimburses my travel costs and there is no honorarium, do I need to upload my reimbursement report to M-Inform?

Yes. Travel paid or reimbursed by a foreign entity including academic and healthcare institutions, governments, companies, or non-profits (any dollar amount) must be reported as an outside activity in M-Inform.  See Outside Activity Disclosure Guidance for more information on what to report. 

About honorarium received when giving a lecture in another country, or when reviewing a research institute in another country, or when reviewing a proposal from another country, is Mike’s answer for disclosure the new rule, or is it a long-standing rule? If it is a long-standing rule, should we report such honorarium retroactively?

The requirement to report honoraria received from international entities is a longstanding requirement.  Honoraria must be disclosed in M-Inform if they were received within the past 12 months. Honoraria payments older than that may be disclosed at the investigator’s discretion.

The level of detail and required knowledge is immense. How can U-M faculty who specialize in other topics for their work and research be expected to navigate the complex, daunting and ever-changing set of rules and regulations?

We don’t expect faculty to know all the answers. The COI and ORSP staff do know them, however. We hope, therefore, that by putting on town halls such as this and by providing faculty and their local research administrators with access to U-M and federal guidance, faculty will know enough to ask the right questions and reach out for assistance as needed. And if the COI/ORSP staff happen not to know on the spot, they know where to find the answer.

I understand that copies of contracts with an international entity need to be provided to NIH if as part of the arrangement I am engaged in the design conduct or reporting of research. But what if I'm receiving some Other Support from an international entity and there is no contract to document this fact (e.g. the Max Planck Institute for Multidisciplinary Natural Sciences is giving me access to one of their labs to do research over the summer). Does anything need to be uploaded to NIH?

Yes, all forms of Other Support from an international entity where you are involved in the design conduct or reporting of research must be documented to NIH, even if there is no formal contract. In those cases, copies of email exchanges, letters of invitation, and similar informal communications will suffice.

Questions?

If you have any further questions, please contact InternationalResearchGuidance@umich.edu.