International Collaboration
The University of North Carolina at Chapel Hill recognizes that international collaborations are critical elements to progressing research. As such, it promotes an open and collaborative environment while also complying with all requirements from federal partners and working with faculty to reduce the risks involved. There are considerations and business processes to consider before you start, and during, your international collaboration.
International Research Collaboration Agreements
If you are considering entering into an international research-related collaboration, take these steps:
- Please send an e-mail to the Research Security Office and the Export Compliance Office so that they can do a risk review for their respective areas, assign a risk level, and discuss it with you. Your e-mail should include the following:
- The name(s) of the individual(s) you wish to collaborate with
- The name(s) of the individual(s) entities where their part of the collaboration will occur
- What countries are involved in the collaboration
- The scope of work for the collaboration – detail both UNC’s role and the role of the collaborator(s)
- Benefit to you and the university if the collaboration occurs
- Proposed duration of collaboration
- Whether publications will occur based on the collaboration
- Whether any patent filings are anticipated based on the collaboration
- What UNC assets – systems, data repositories, data sets, etc – the collaborator(s) would need access to
- Whether the collaboration would be part of a sponsored award and if so, what the award’s project ID and sponsor are
- Whether any funds will any funds be involved in the collaboration – outside funding for the collaboration, funds sent from UNC to collaborator, etc
- Will this collaboration require the transfer of any research materials, supplies, data, or technical documents to the collaborator(s)
- Once a risk assessment is done and the results discussed with the faculty member, then a collaboration agreement will need to be created and executed by the Office of Sponsored Programs. To start this process, please submit a request through the ALICE system to initiate this process. More information on this process can be found here:
Foreign Component Approval (NIH)
The National Institutes of Health (NIH) requires principal investigators to seek approval before adding a foreign component to their project. NOT-OD-084 affirms this definition as:
Definition:
The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to
- the involvement of human subjects or animals at a foreign site,
- 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:
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.
The NIH considers most forms of co-authorship with a collaborator abroad to constitute a foreign component.
Guidance on Publications:
For clarity, NIH-funded researchers should represent their institution at the time of the project in their publications.
For example: Assume a post-doctoral scholar at UNC accepts a faculty position abroad. Any publications resulting from the scholar’s work at UNC should reflect, via a footnote or other attribution, that the work was completed during the time of the scholar’s work at UNC. This clarifies that there was no foreign component to the NIH, which is important for future collaborations.
Talent Programs
Definitions:
Several governments, including the United States, sponsor talent programs. Talent programs facilitate and often fund a scholar’s academic exchange or work in a laboratory.
The Federal Government designates some foreign talent programs as “Maligned” (U.S.C. 3001), because their participation terms compromise the academic integrity or intellectual property rights of federally-funded research. Scholars may not participate in Maligned Foreign Talent programs and, further, Common Forms Current and Pending (Other) Support require investigators to certify non-participation.
Concerns:
Some terms that present red flags include:
- Reporting unpublished data to an external party or government
- Reporting intellectual property to an external party or government
- Secrecy surrounding participation in the program
If you are contacted by a foreign talent program with recruitment opportunities, contact the Research Security Office for a complete screening of the program.
Export and Import Permissions
Exporting at UNC
Visit the International Shipping webpage to request export authorization.
As per the University Policy on Export Controls, the Export Compliance Office (ECO) is the only office authorized to provide prior approval for all University exports. This allows the ECO to review for license requirements and ensure compliance with all export controls regulations, including:
- International Traffic and Arms Regulations (ITAR),
- Export Administration Regulations (EAR),
- Office of Foreign Asset Control (OFAC)
- Foreign Trade Regulations (FTR).
The ECO frequently provides Electronic Export Information filings and other compliance services to outbound shipments.
Importing at UNC
Consult the International Shipping and Receiving Guide for guidance.
Several parties support import operations at UNC, including the Office of the University Council, the Export Compliance Office, Environment, Health and Safety, and Purchasing Services.
Consult the International Shipping and Receiving Guide for guidance on import practices, and reach out to [email protected] with any questions.
Visiting Scholars
Unpaid Visitor Process
Submit Unpaid Visitor requests in Connect Carolina.
The Office of Human Resources manages Unpaid Volunteers, Interns and Visiting Scholars Policy.
When hosting unpaid guests, departments should submit an Unpaid Visitor Request eForm in ConnectCarolina. These forms route through the Export Compliance Office for deemed export review and research security support, as appropriate.
Visa Sponsorship
Initiate ECO review for sponsorship, when required.
International Scholar and Student Services functions manages all visa sponsorships for students and employees sponsored by UNC.
Certain sponsorship types require review, support, and certification from the Export Compliance Office. Visit the Hosting International Visitors webpage for further information and to initiate ECO review.