International Collaborations

Investigators on sponsored projects should check their sponsors’ current disclosure requirements carefully and, if in doubt, reach out to the contacts at the bottom of this page for disclosure assistance and further guidance. Disclosures can be added at coi.gmu.edu. Collaborations with foreign or domestic entities may include exchanges of personnel, materials, data, or other significant activity likely to result in co-authorship. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through Mason, through another institution, or provided directly to the researchers themselves. In addition, investigators should:

• Review and update Other Support and Current and Pending Support information in proposals in accordance with instructions in NIH’s Other Support, NSF’s Proposals & Awards Polices and Procedures Guide, and similar documentation from other sponsors. (For these references, please see "Federal Government Resources" page)
• Review and update biosketches
• Review COI disclosures and update as necessary
• Report all reimbursed or sponsored travel related to NIH/PHS-supported projects
• Reach out to Mason’s Export Control office at export@gmu.edu for guidance related to export control regulations

Disclosure requirements are currently under review by NIH and NSF and revisions are expected during 2020.

The PHS regulation requires investigators to disclose any reimbursed travel exceeding a threshold amount of $5,000 in total payments from a single sponsor in a single year, as well as sponsored travel related to the investigator's institutional responsibilities (i.e. that which is paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available). The disclosure requirement also applies to the investigator’s spouse and dependent children. However, the disclosure requirement does not apply to travel that is reimbursed or sponsored by Mason or the following entities:

• a federal, state, or local government agency
• an Institution of higher education as defined at 20 U.S.C. 1001 (a)
• an academic teaching hospital
• a medical center
• a research institute that is affiliated with an Institution of higher education

Note: The exemption does NOT apply to any reimbursement from a foreign entity, university, or government, or from professional societies. Agencies and other entities other than PHS/NIH that fund your work may require advance approval and/or disclosure of foreign travel or domestic travel sponsored by foreign entities. Check the requirements associated with your specific funding sources. Consider using Mason’s “Clean Laptops” when traveling abroad – especially to locations of heightened cyber security concern.

The federal government is increasingly scrutinizing participation in foreign talent programs, such as China’s Thousand Talents Program, and the U.S. Department of Justice has taken legal action against investigators and institutions that do not disclose participation in such programs to federal research sponsors. Not only should participation in a foreign talent program be disclosed to federal sponsors, Mason researchers should also reach out to their ADR to discuss such activity, even if they’ve previously disclosed their participation to other university officials.

Several federal agencies have emphasized that failing to disclose foreign relationships and activities could restrict eligibility for future research funding. The National Institutes of Health (NIH), the National Science Foundation (NSF), the Department of Defense (DoD), and the Department of Energy (DoE) have issued notices and directives reminding researchers who have federally-funded projects of their obligation to disclose relationships with and support from foreign entities. Each has different requirements and standards. Although the government has indicated it is in the process of harmonizing federal disclosure requirements and related restrictions, such efforts have not yet borne fruit. Links for the following and other announcements can be found on the "Federal Government Resources" page.  NIH: NIH is generally at the forefront of requiring disclosure of foreign financial interests and support and of warning of ethical challenges related to participating in foreign “talent programs.” In August 2018, the NIH Director’s “Statement on Protecting the Integrity of U.S. Biomedical Research” cited the “failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds…” On July 10, 2019, NIH issued a notice (NOT-OD-19-114) reminding researchers of the need to report foreign activities and ensure such activities do not lead to scientific, budgetary or commitment overlap. NIH followed this notice with letters to grant recipients inquiring into possible failures to disclose foreign affiliates and support. In September 2019, the NIH Deputy Director for extramural research, Dr. Michael Lauer, noted that NIH has investigated at least 180 well-funded and established scientists at 65 institutions for violating NIH policies requiring grant recipients to report foreign ties. NSF: Director Dr. France Cordova issued a “Dear Colleague” letter in July 2019 (NSF 19-200), discussing the importance of research protection and the regulations requiring accurate and timely financial disclosure – including disclosure of gifts from foreign governments. NSF has also proposed changes in its Proposal and Policies Procedures Guide (PAPPG) that include reporting “all sources of support regardless of whether salary support is requested.” Although NSF maintains this reporting requirement is not a policy change, it is a significant departure from many institutions’ practices and procedures. The NSF PAPPG changes have not yet been made final. DoD: In October 2019, the Under Secretary of Defense for Research and Engineering, Dr. Mike Griffin, released memoranda indicating that all research and research-related education activities conducted through DoD research grants, cooperative agreements, Technology Investment Agreements, and other non-procurement transactions require Key Personnel to disclose all current and pending projects, time commitments to other projects, and funding sources at the time of application. DoE: Order 486.1 has prohibited its employees and the employees of its contractors from participating in “foreign talent recruitment programs.” U.S. Senate & U.S. House of Representatives: Members of Congress are increasingly asking the Federal Executive Branch to review how the federal government is implementing conflict of interest policies in taxpayer-supported research. White House: The White House Office of Science and Technology Policy (OSTP) has called out researchers’ “breaches of research ethics,” including “failure to disclose required information such as foreign funding, unapproved parallel foreign laboratories, affiliations and appointments, and conflicting financial interests.” In May 2019, OSTP and the National Science and Technology Council established the Joint Council on the Research Environment (JCORE), which is focused on research security, including coordinating disclosure requirements and developing “best practices” for academic research institutions. However, disclosure requirements are not yet harmonized.