FAQs: International Engagements

Yes, there are a number of considerations.

1. If your travel may involve a comprehensively sanctioned country or a restricted entity, see FAQ 1 above. 

2. All Columbia affiliates are required to register their Columbia-related international travel in International SOS MyTrips. Registering your trip helps the University to communicate with you in the event of an emergency and provide assistance as needed. Visit the Global Travel website for additional information about applicable policies and rules for global travel. 

3. If you are bringing your laptop or other electronic device, then you need to follow Columbia’s data security guidelines for travel abroad.

4. If your travel is being reimbursed or paid for by another entity, you may need to disclose it.  (a) If you have Public Health Service funding (e.g., NIH, CDC, AHRQ, etc.), you must disclose sponsored travel in your Annual Financial Interest Report in Rascal.  (b) If the travel relates to a research collaboration and there is an associated time commitment, you may need to disclose it in Other Support or Current & Pending Support.

Factors to consider include the following:

1. Is the non-U.S. university a restricted entity (see FAQ 1a above)?  If yes, contact the Office of Research Compliance and Training (RCT) for guidance as soon as possible.

2. Is the non-U.S. university located in a comprehensively sanctioned country (see FAQ 1b above)?  If yes, contact RCT as soon as possible. 

3. Are you being compensated for the talk?  If so, you must disclose the compensation in Rascal in your Financial Interest Report. 

4. Is the non-U.S. university paying for your travel expenses or providing a per diem? If so, see FAQ 2(4) above regarding possible disclosure requirements.

5. Are you receiving any kind of title, even if honorary, at the non-U.S. institution? If so, you must disclose it on your biosketch submitted to federal funding agencies. See FAQ 6 for more information.

6. See FAQ 2 for additional guidance on international travel.

Factors to consider include, but are not limited to, the following:

1. Is the non-U.S. university a restricted entity (see FAQ 1a above)?  If yes, contact the Office of Research Compliance and Training (RCT) for guidance as soon as possible.

2. Is the non-U.S. university located in a comprehensively sanctioned country (see FAQ 1b above)?  If yes, contact RCT as soon as possible.

3. Will you be sharing physical materials (e.g., reagents, plasmids, equipment, prototypes, etc.), non-public data, or code with this collaborator? If so, a material transfer agreement (MTA), data use, or other agreement may be needed, regardless of who funded the research. Contact  SPA or CTV for more information and to request an MTA or other agreement between Columbia and the other institution.  In addition, all exports of physical materials outside the U.S. should be reviewed for export control restrictions prior to sending.  Please contact RCT for export controls review.

4. Will Columbia be providing any funding to the collaborator, or vice versa? If so, contact SPA for the appropriate sponsored research agreement.

5. Will the non-U.S. collaborator perform a significant scientific element or segment of an NIH-funded project outside the United States? If so, it may constitute a foreign component that requires NIH’s prior approval. Contact your SPA project officer to submit a request for prior approval to NIH.

6. Will you receive any physical materials (e.g., reagents, plasmids, equipment, prototypes, etc.) or other in-kind resources (e.g., office/ laboratory space, students, postdocs) to use in this collaboration?  If so, you must disclose them in your Other Support or Current & Pending Support disclosures to funding agencies, at proposal submission, and in your progress reports. Contact SPA for additional information.

7. Do you expect that the collaboration will lead to co-authored publications with the non-U.S. collaborator?  If so, you may need to disclose the collaboration as an in-kind resource or a project, as applicable, in your Other Support or Current & Pending Support disclosure. 

8. Is the collaborator a member of a talent recruitment program? If so, some funding agencies, such as the Department of Defense, might view that as a research security risk that requires mitigation.

9. Will you travel to the non-U.S. university? If so, please see FAQ 2.

a. The non-U.S. institution will be funding the visitor. Am I required to disclose this visitor to my funding agencies?

If this externally-funded visitor will be a resource for your research, then you may need to disclose them as an “in-kind resource” in Other Support or Current & Pending Support or in the Facilities and Resources section for the project being proposed. For NIH and Department of Energy, such disclosure is always required. For NSF, senior/key persons need to disclose the visitor only if hosting the visitor requires a time commitment from the senior/key person.  

b. Can I host a visiting student, postdoc, faculty member, or other scholar who is affiliated with a restricted entity?

Generally, yes, subject to disclosure requirements described in FAQ 5a, although additional review and approval may be required.  Depending on the legal restrictions and the specific facts at issue, a compliance plan may be required. See FAQ 1a and contact the Office of Research Compliance and Training (RCT)  for guidance. 

c. Can I host a visiting student, postdoc, faculty member or other scholar who is from a comprehensively sanctioned country?

Generally, yes subject to disclosure requirements described in FAQ 5a, above.  However, certain export restrictions may apply. For more information, see FAQ 1b and visit RCT’s Economic Sanctions website.

d. I have NASA funding.  Are there special considerations?

Yes. Since 2011, NASA funding has been subject to a specific restriction that prohibits NASA from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no- exchange-of-funds arrangement.  If you are hosting a visiting student or postdoc who is affiliated with a Chinese institution, they cannot be involved with your NASA project(s). More information is available in NASA’s PRC FAQ for ROSES.

Factors to consider include, but are not limited to, the following:

1. Is the non-U.S. university a restricted entity (see FAQ 1a above)?  If yes, contact the Office of Research Compliance and Training (RCT) for guidance as soon as possible.

2. Is the non-U.S. university located in a comprehensively sanctioned country (see FAQ 1b above)? If yes, contact RCT as soon as possible.

3. Do you have a clear understanding of why you are being offered the appointment and what is expected of you?

4. Are the requirements for the appointment or contract consistent with Columbia’s conflict of commitment policy? See the Faculty Handbook and Appendix III.

5. Is this a titled and paid appointment or affiliation? Under the Faculty Handbook, prior approval by the relevant chair, and dean, director, or executive vice president is required for any appointment or affiliation with an institution of higher education, academic medical center, or research institute outside of Columbia, if the appointment or affiliation is both titled and compensated.

6. Is there an appointment letter or contract? If so, does the agreement allow you to terminate it? Does it have any provisions that are inconsistent with scholarly norms, e.g., unusual authorship or affiliation requirements?

7. Have you disclosed the appointment or affiliation in Rascal, in your Annual Financial Interest Report? This disclosure is required even for unpaid affiliations and appointments.

8. Is the engagement a consulting activity that involves conducting research or is related to your research portfolio?  If so, funding agencies may require you to disclose the consulting as Current and Pending (Other) Support, under “proposals and active projects.”

9. If there is an appointment letter or contract, and you receive NIH funding, have you included a copy of the agreement as part of the Other Support submission, and also uploaded the agreement in Rascal?  Other funders may also ask to review the agreement on a case-by-case basis.

10. Have you included the appointment or affiliation on your Biographical Sketch submitted to your funding agencies? This is a critical disclosure obligation.

If you have questions about how to handle specific appointments or affiliations, please contact your SPA project officer.

Any funding for research at Columbia must go through the appropriate University office. These offices ensure that the provisions of any gift or funding agreement align with University policy, protecting both the researcher and the University. If the funding is in the form of a gift, the gift agreement must be reviewed and signed by the Office of Alumni and Development, through your school’s development officer. If the funding is in the form of a sponsored project grant or contract, the Office of Sponsored Projects Administration must review and sign the agreement. Other agreements are handled by Columbia Technology Ventures, the Clinical Trials Office, or the Office of General Counsel.

If you are unsure whether the project is a gift or a grant, contact your SPA Project Officer for guidance.

If you are invited to be the principal investigator on funding at an entity other than Columbia, the Faculty Handbook requires you to obtain prior approval from your department chair, school, and from the Executive Vice President for Research.

Finally, any resources for research available to you, whether at Columbia or elsewhere, must be disclosed in your Other Support or Current & Pending Support disclosures to federal funding agencies.

Federal legislation defines a “malign foreign talent recruitment program” as:

A. Any program, position or activity compensated with cash or in-kind compensation such as complimentary foreign travel, honorific titles, career advancement opportunities, where the compensation is in exchange for one or more of the following:

1. Unauthorized transfer of intellectual property, materials, data products, or other nonpublic information developed through U.S. Federal funding to a foreign government or entity affiliated with a foreign country;

2. Being required to recruit trainees or researchers to participate in the program or activity;

3. Establishing a lab or company or accepting a faculty position or other employment if these activities are in violation of standard terms and conditions of a federal award;

4. Being unable to terminate the contract except in extraordinary circumstances;

5. Requiring commitments that limit the capacity to carry out a U.S. federal award or would result in substantial overlap or duplication;

6. Being required to apply for or successfully receive funding from the sponsoring foreign government’s funding agencies, with the foreign organization as the recipient;

7. Being required to omit acknowledgement of the recipient institution (i.e., Columbia University), or the U.S. federal research agency sponsor, contrary to institutional policies or standard award terms and conditions;

8. Being required to withhold information about participation in the program and not to disclose it to the U.S. funding agency or to Columbia; OR

9. Having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the award.

AND

B.

1. A foreign country of concern (“FCOC”) or an entity based in a FCOC, whether or not directly sponsored by the FCOC;

2. An academic institution on the NDAA 2019 Section 1286(c)(8) List; or

3. A foreign talent recruitment program on the NDAA 2019 Section 1286(c)(9) List.

Be aware that recently-passed U.S. legislation (“CHIPS and Science Act”) prohibits participation in such programs for individuals who receive federal research funding.  If you are considering an invitation that may meet any of the above criteria, please contact the Office of Research Compliance and Training for guidance.

In recent years, the U.S. Government has raised concerns that certain countries, including China, may present elevated risk to U.S. national and economic security. These concerns include diversion or misuse of U.S. exports by entities in China, including certain Chinese universities, and China’s military-civil fusion (MCF) strategy, which seeks to fuse China’s civilian research and commercial sectors with its military and defense sectors.  According to the U.S. Government, China implements its MCF strategy in various ways, including by requiring its research universities to perform military-related R&D activities.

In response to these concerns, the U.S. has imposed additional restrictions on China, including export restrictions on Chinese universities and research institutions (see FAQ 1a) and China’s semiconductor and supercomputer sectors. U.S. funding agencies may also scrutinize China-related activities and request and review additional documentation related to such (e.g., letter of appointment; collaboration agreement; consulting contract). These U.S. policies and requirements are continuing to change in response to evolving geopolitical conditions.

Columbia researchers can engage in activities with colleagues and universities/ institutions in China, subject to meeting all disclosure obligations as described in the FAQs above and all applicable U.S. laws and regulations.  If a proposed activity is higher risk (e.g., it involves a restricted entity in China; the Columbia researcher plans to send samples to China; the university may be a “military end user”; it involves the semiconductor/ supercomputing sectors in China), additional review is required and compliance procedures may need to be put in place to mitigate the risks. If you have questions or concerns about activities involving China, please contact the Office of Research Compliance and Training for additional guidance. 

The concerns described above focus on actions by the government of China. It is critical to ensure that researchers with China connections are not stigmatized or discriminated against in any way in the face of the overall increased scrutiny of higher education interactions with China. Columbia University is committed to providing a learning, living, and working environment free from discrimination and harassment and to fostering a nurturing and vibrant community founded upon the fundamental dignity and worth of all of its members. Anyone with concerns regarding prohibited activity is encouraged to report them to the Equal Opportunity and Affirmative Action Office. 

If any person identifying him/herself as a federal, state, or local law enforcement officer or agent contacts you whether on campus or off, in your capacity as a Columbia employee (i.e., about a matter related to Columbia work), and asks you to provide non-public documents, records, files, data or other materials, or wants to meet with you to talk about Columbia business, you should direct the officer or agent to the Office of General Counsel. If you are presented with a subpoena seeking Columbia documents or other information or wanting to meet with you regarding Columbia business, you must forward the subpoena immediately to the Office of General Counsel, which will respond on the University’s behalf.