Foreign Collaborations and International Research Activities FAQ

Foreign Collaborations and International Research

Rochester Institute of Technology encourages research partnerships and collaborations. Many federal sponsors, however, require disclosure and, in some cases, prior approval when foreign individuals, institutions, resources, or activities are involved in a sponsored project. Early disclosure helps protect both the investigator and the university while ensuring compliance with sponsor and research security requirements.

Quick Self-Assessment

Ask yourself these questions:

  • Will anyone outside the United States contribute to the scientific work?
  • Will research activities occur outside the United States?
  • Will foreign facilities, laboratories, data, samples, or equipment be used?
  • Will a foreign institution receive funding or perform part of the work?
  • Will a foreign researcher be involved in publications or project deliverables?

If you answer "yes" or "maybe" to any of these questions, there is likely a foreign collaboration disclosure required to any federal projects you plan to propose to pr are currently working on.

A foreign collaboration generally exists when a significant scientific or scholarly component of a federally sponsored project involves:

  • A researcher affiliated with a foreign institution
  • Research activities conducted outside the United States
  • A foreign laboratory, facility, field site, or research resource
  • Research data, specimens, samples, or materials obtained from a foreign source
  • A foreign institution performing a portion of the project's work
  • Foreign financial or in-kind support related to the research

Importantly, a foreign collaboration may exist even when no federal funds are being sent to a foreign organization.

Why does this matter?

Federal agencies such as NIH, NSF, DOE, DOD, and USDA have strengthened requirements related to research security and transparency. Investigators are expected to accurately disclose foreign collaborations, affiliations, sources of support, and international research activities.

Failure to disclose required foreign involvement can lead to:

  • Delays in award processing
  • Sponsor compliance findings
  • Award restrictions or corrective actions
  • Increased institutional oversight
  • Potential loss of funding

The following are generally considered foreign collaborations and should be discussed with Sponsored Research Services (SRS):

✅ Working with a researcher employed by a university in another country

✅ Collecting research data or samples outside the United States

✅ Conducting part of a project at a foreign laboratory or field site

✅ Issuing a subaward to a foreign institution

✅ Using specialized equipment or facilities located abroad

✅ Receiving in-kind research support, data, software, materials, or personnel effort from a foreign organization

✅ Collaborating on research that is expected to result in co-authored publications with foreign researchers

The following activities generally do not, by themselves, constitute a foreign collaboration:

❌ Attending or presenting at an international conference

❌ Participating in a workshop or professional meeting overseas

❌ Purchasing routine goods or services from a foreign vendor

❌ Informal scientific discussions that do not contribute to the project's research activities

Because circumstances vary by sponsor and project, faculty should contact SRS whenever they are unsure.

Possibly.

Federal sponsors often focus on the scientific contribution rather than the flow of funds. If a foreign collaborator is contributing intellectually, conducting research activities, analyzing data, providing resources, or participating in publications, disclosure may still be required.

Contact SRS before the collaboration begins.

Some sponsors require prior approval before adding foreign collaborators, conducting work outside the United States, or establishing foreign subawards. SRS can help determine whether sponsor notification or approval is required.

Often yes.

If the foreign researcher is contributing to the sponsored project's scientific work and is expected to be a co-author, the collaboration may need to be disclosed to the sponsor.

Faculty should indicate the following relationships within the RIT COI system:

  • Foreign research collaborators
  • Foreign organizations participating in the project
  • International research activities or field work
  • Foreign gifts, subawards or consultant arrangements
  • Foreign appointments, affiliations, or visiting researcher positions related to the project
  • Foreign sources of financial or in-kind research support
  • Foreign laboratories, facilities, equipment, datasets, or specimens used in the project

Contact SRS if you plan to:

  • Include a collaborator from a foreign institution in a proposal
  • Conduct research activities outside the United States
  • Use data, samples, or facilities located abroad
  • Establish a foreign subaward or subcontract
  • Enter into an international research agreement, NDA, MOU, or data-sharing arrangement
  • Receive support or resources from a foreign entity

It is always easier to address disclosure requirements before a proposal is submitted than after an award is made.

If you plan to submit to a federal agency, check the agency's website for guidance on the disclosure of foreign collaborations. SRS can also provide guidance.

Most agencies have specific pages for guidance on foreign activity, and the two most common are linked below.

NOTE: regulations are evolving, so links may change or update as determinations are made at the federal level. 

NIH

NSF

 

Malign Foreign Talent Recruitment Programs (MFTRP)

Many sponsors are requiring disclosures related to specific types of foreign collaborations. For more information, please visit RIT's MFTRP page.