The University of Georgia is increasingly engaged in research partnerships with individual scientists, universities and other organizations around the world. These international collaborations are vital both to the scientific community and to the public at large, as many of today’s most vexing challenges pay little heed to geopolitical borders. While such work is critical to UGA’s future research ambitions, it is not without risk.
The National Institutes of Health and other federal agencies have recently raised concerns about research protection and undue foreign influence in academia. This has created an increased interest from federal agencies in understanding faculty affiliations and international engagements. As a result, faculty may be uncertain about how best to meet federal agency expectations when engaging in international activities and research partnerships. The Office of Research is here to answer your questions and assist you in making all of the required disclosures. Our goal is to help ensure that you are aware of existing disclosure, reporting and oversight mechanisms and can continue to engage with the global research community. We fully appreciate the value of foreign partnerships and exchanges—and we expect these activities to continue to grow.
Members of the UGA community are strongly encouraged to leverage the university’s available expertise (via the applicable contacts below) to ensure all disclosure and other procedures are followed. Support is available to assist with outgoing proposal review, incoming awards compliance, conflict of interest management, export control, and intellectual property, along with support for global engagement activities.
Specific Federal Concerns
Federal agencies have expressed growing concerns over the potential for undue foreign influence in the following areas:
- Failure by some researchers to disclose substantial contributions of resources from other organizations, including foreign governments;
- Diversion of intellectual property to foreign entities; and
- Sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.
Lawful and Responsible Conduct
Disclosing and Managing Conflicts of Interest
Colleges, schools, and units manage conflicts of interest and approve outside activities, via the Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy. Activities requiring approval would include startup companies, appointments at other institutions, and participation in foreign talent programs, for example. Colleges, schools, and units will review and manage actual or apparent conflicts of interest, as well as approving compensated outside activities.
The Office of Research Integrity and Safety manages financial conflicts of interest (FCOI) in sponsored programs, via the Policy on Conflicts of Interest in Sponsored Programs. Visit the Financial Conflicts of Interest website for access to the disclosure tool and to review relevant regulations and policies, and the Startup Conflicts of Interest website for additional startup related guidance. The Office of Research Integrity and Safety reviews and manages FCOI, specifically in sponsored projects, and will work directly with University personnel on that management.
Disclosing Appointments at Other Institutions
The Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy addresses consulting, teaching, speaking, and participating in business, professional, or service enterprises, including at other academic institutions, and applies to all faculty and staff that work over 30 hours per work. Receive approval for appointments at other institutions from your college, school, or unit.
Dean, Department Head, Vice President, Associate Provost or Director of the employee’s college, school, or unit of primary appointment
Staff Policy Contact: Sige Burden, 706-542-9231
Faculty Policy Contact: Dr. Sarah Covert, 706-542-0547
Protecting Intellectual Property
Help protect the University’s intellectual property, by avoiding the disclosure of new technologies without first contacting UGA’s Innovation Gateway per the UGA Intellectual Property Policy. Additional resources include the Guide to Patents for Faculty and Staff and the Intellectual Property & Technology Transfer Overview.
Transferring Materials and Confidential Information
When sharing materials or confidential information or receiving materials or confidential information, a material transfer agreement or confidential disclosure agreement may be necessary.
Export Control and Trade and Economic Sanctions
Federal export control laws govern the transfer or transmittal of certain technology, materials, data, and information to anyone overseas or to foreign nationals in the United States. Sanctions and embargoes apply to certain individuals, entities, and countries. Both export control and sanctions regulations are complicated and subject to geopolitical influences. The Office of Export Control provides a variety of reviews and services to assist University academic and operation units with recognition and navigation of these complex regulations. Accepting or sharing controlled information may also require heightened cybersecurity.
Foreign Corrupt Practices Act (FCPA)
The FCPA prohibits providing, offering, authorizing, or promising anything of value to a foreign government official with the intent to corruptly influence or gain an unfair advantage. Foreign officials include officials and employees of foreign governments, state-owned enterprises, public international organizations, and political parties, as well as agents and close relatives of those individuals. Anything of value includes not only cash or cash equivalents, but also trips, donations, and services.
Sponsored Projects Administration (SPA), facilitates proposed and awarded sponsored research, no matter the sponsor. SPA and Office of Export Control processes include review of internationally sponsored projects as well as international collaborations and travel.
Disclosing Foreign Support
Investigators should disclose all forms of other support and financial interests, including support coming from foreign governments or other foreign entities when providing details about current and pending support on sponsored research proposals and related applications.
Find your SPA Representative
International Initiatives, in the Office of Global Engagement, provides assistance with initiating and memorializing international partnerships and collaborations. The Office provides assistance and signature authority on Cooperative Agreements, Student Exchanges, Faculty Exchanges and Mobility Agreements, Collaborative Degrees, Research Collaborations, and Student Internships.
Hosting Foreign Visitors
The University welcomes visiting researchers and scholars from all across the world. The Office of Research manages a hosting and onboarding process for visiting researchers and scholars, including the completion of the Visiting Researcher/Scholar Questionnaire and the Visitor Agreement.
Jessica Hawks Farmer
Immigration Services, in the Office of Global Engagement, provides centralized immigration and visa-sponsorship to international students, scholars, faculty, and staff and to UGA colleges and schools.
International Initiatives, in the Office of Global Engagement, manages protocol for visiting international delegations.
Travel Authority and Expense Reports
Accounts Payable is responsible for processing all documents related to University business travel. Travel authorizations and travel-related expense reports are submitted via the UGA Financial Management System. Travel authorities require prior authorization before travel may commence.
International Travel Registry
International travel must be registered in the Office of Global Engagement Travel Registry, for all international travel on UGA business. Travel to areas under a Department of State Level 3 or 4 travel warning, or a CDC Level 3 warning, is governed by the OGE Risk Management Policy.
Sanctioned and Embargoed Country Travel
Travel to Cuba, Iran, Sudan, Syria, or the Crimea region of Ukraine requires permission from the U.S. Department of Treasury, Office of Foreign Assets Control. U.S passports are not valid for travel to, in, or through North Korea, unless specially validated by the Department of State pursuant to very limited U.S. “national interests.” Sanctioned country travel must be discussed and approved with the Export Compliance Officer, and if necessary, the Department of Treasury (and State, for North Korea), before the traveler finalizes travel arrangements.
Electronic and Information Security While Traveling
International travelers should follow available International Travel Guidelines related to protection of electronic devices and data and the temporary export of electronic devices and/or access of UGA information abroad, including the consideration of loaner electronic devices and travel service email.
Specific Federal Agency Guidance
National Institutes of Health “Dear Colleagues” Letter
National Institutes of Health “Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components”
National Institutes of Health “Frequently Asked Questions: Other Support and Foreign Components”
National Science Foundation “Dear Colleagues” Letter
Department of Energy “Foreign Government Talent Recruitment Programs” Directive
Department of Defense Memorandum on “Actions for the Protection of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies”