International Relationships and Activities

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Last Updated: March 12, 2021


 Penn State's publishing collaborations in the last five years.


The U.S. Government has expressed serious growing concerns regarding inappropriate influence by foreign entities over federally funded research (see Sources below).  One issue that has moved to the forefront is the failure of federally-funded researchers at U.S. institutions to disclose their relationships and activities with foreign institutions and funding agencies. Several Federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.

Penn State encourages international collaborations, but it is important for our investigators to be transparent about their foreign relationships and activities.  Penn State’s Office of the Senior Vice President for Research (OSVPR) has compiled the following information to provide guidance and resources to remind Penn State researchers of their compliance obligations to federal sponsors.


Rising Concern (Background)

  1. The National Institutes of Health (NIH) issued a Notice on July 10, 2019, reminding research institutions that NIH-funded researchers must “report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap” (NOT-OD-19-114). Other Support includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” To learn more, refer to the NIH guidance on the subject of protecting U.S. biomedical intellectual innovation.
  2. The Department of Defense (DoD) issued a memo on March 20, 2019, outlining disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements. A second memo was issued October 10, 2019, providing additional updates on the DoD’s efforts to address this issue.
  3. The National Science Foundation issued a Dear Colleague Letter on July 11, 2019, outlining its plans to “address emerging risks to the nation’s science and engineering enterprise.”
  4. The Department of Energy issued a memo dated January 31, 2019, stating its intention to prohibit "all DOE funding recipients" from participating in "foreign talent recruitment programs of countries determined sensitive by DOE." A DOE directive dated June 7, 2019 mandated that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs” on new DOE contracts and subcontracts.  An updated directive was approved on September 4, 2020 along with an accompanying FAQ. The new version includes a restriction on receiving employment, funding, other support, or gifts from any “Foreign Country of Risk.” The restriction applies to funding coming directly to the investigator in addition to funding being run through the institution. The restriction also applies to financial support for laboratory personnel, participation of student and visiting researchers supported by other sources of funding, and “in kind” contributions, such as provision of office/laboratory space, equipment, supplies, or employees. Effective November 2020, DOE began issuing financial assistance agreements (grants and cooperative agreements) which restricted project participants from participating in certain foreign-government sponsored talent recruitment programs.
  5. As a reminder, NASA has long-standing restrictions on using NASA funds to enter into agreements “to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement” (grant restrictions, contract restrictions). An associated FAQ can be found here.


Best Practices for Disclosing Foreign Relationships and Activities

While most international collaborations are perfectly acceptable and encouraged, we urge researchers to err on the side of transparency. OSVPR aims to work closely with the Associate Deans for Research (ADRs) at the Colleges and Commonwealth Campuses to ensure they can provide the best advising for each scenario.

The items below contain guidance regarding the types of relationships and activities that Penn State researchers are expected to disclose:

1. Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports. Adding a new foreign component to an NIH grant requires NIH prior approval (NIH's Grants Policy Statement Section Under the NIH Grants Policy Statement, a Foreign Component is defined as “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" [emphasis added]. The definition of “foreign component” (which can be found here) may include a large number of collaborative activities, including “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.” Other sponsors have similar requirements to disclose foreign components.

There are multiple ways in which foreign components can be disclosed, e.g., 

  • Identifying a “foreign component” in an NIH grant application;
  • Listing a “non-U.S. performance site”;
  • Identifying foreign relationships and activities in a biosketch;
  • Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
  • Financial resources should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. For example, if a researcher with a 9-month appointment spends two months at a university outside of the U.S. during the summer conducting research under a foreign award, that activity should be disclosed.

Principal Investigators (PIs) should review all pending proposals and active awards to ensure that all foreign components have been disclosed. If a PI identifies an omission or error in a previously submitted proposal, the PI should contact the Office of Sponsored Programs ( to have the error corrected.

2. Penn State researchers should ensure they disclose all applicable “Other Support” as required by federal sponsors.  “Other Support” may include resources and/or financial support, domestic or foreign, available in support of a researcher’s research endeavors. Such support should be disclosed on an “Other Support” or “Current & Pending” form. Sponsor guidelines may specify that all sources of support be disclosed, regardless of whether they are awarded through Penn State, through another institution, or provided directly to the researcher himself or herself. (Specific guidance for NSF and NIH can be found here.

An issue that is garnering a great deal of scrutiny by the federal government is participation in foreign talent programs, such as China’s Thousand Talents Program. Not only should participation in a foreign talent program be disclosed to federal sponsors, Penn State researchers should also reach out to their ADR to discuss such activity, even if they’ve previously disclosed their participation to other university officials. Depending on an individual’s research portfolio, he or she may be advised to terminate his or her affiliation with the foreign talent program.

Most federal sponsors will have their own guidance on how to complete “Other Support” forms. To generate a preliminary list of your pending proposals and active grants, please click the “Current & Pending Report” button at (See screen capture below.) This reporting function will identify any proposals, grants, or contracts that have been processed through Penn State, but it will not capture other activity (i.e., research performed outside of Penn State). It is ultimately the responsibility of the individual researcher to ensure that the report of Other Support is complete and accurate to the best of his or her knowledge.



Again, PIs should review all pending proposals and active awards to ensure that all Other Support has been disclosed. If a PI identifies an omission or error in a previously submitted proposal or progress report, they should contact their College Research Administrator to have the error corrected.

3.  Significant financial interests received from any foreign entity, including governments and universities, must be disclosed, per Penn State policy RP06 for review by Penn State’s Conflict of Interest Program. The definition of “significant financial interest” is included in RP06, which requires disclosure of remuneration from foreign entities greater than $5K including “Sponsored Travel” greater than $5K received in a 12-month period. If you are unsure whether a particular interest or remuneration meets this definition, please contact the Conflict of Interest Program at

4. Disclose all foreign consulting and other outside business activities as required in policy AC80. A few common examples of outside business activities include consulting, teaching courses at outside organizations, or entrepreneurial ventures related to your area of research.  

5. Detailed guidance regarding foreign travel can be found here.

6. Contact the Office of Information Security regarding any compromised accounts or other IT threats at

7. Promptly report inventions or intellectual property to the Office of Technology Management:


It protects everyone’s interests – the Federal government, Penn State, individual researchers, and their international collaborators – to have international relationships disclosed and vetted to determine if there are any potential conflicts of commitment, duplications of research, and/or diversion of intellectual property in the performance of federally funded research.

In extreme cases, failure to disclose all relationships could result in the termination of funding for a project and potential ineligibility for future funding. Noncompliance can also threaten not only the funding for individual projects, but overall funding for the University and from federal appropriations as a whole.

How to Get Assistance

Faculty members should be encouraged to contact their Associate Dean for Research for an initial discussion regarding any foreign affiliations related to their research efforts. Questions regarding individual grants and contracts can be directed to the Office of Sponsored Programs ( Specific questions regarding export compliance can be directed here or here.


Do these issues only apply to NIH grants?

No. The Department of Defense, the National Science Foundation, and the Department of Energy have also issued statements regarding this issue. Given the current U.S. Government focus on this issue, we anticipate similar guidance, statements, or requirements will be forthcoming from other funding agencies.

Please see the Background section above for additional details.

Do I need to make disclosures related to the work of my graduate students if they are foreign nationals? Does this affect Postdoctoral scholars?

In most cases, there is no reason to disclose participation of foreign students or postdocs on sponsored research, especially if all such work will be performed in the U.S. However, classified and export controlled projects will be subject to foreign national restrictions. It may be possible to employ certain foreign nationals on controlled projects after appropriate licenses and/or exemptions are secured. Please contact Penn State's Export Compliance Office for more information on such cases. There are no foreign national restrictions on “Fundamental Research” projects. (See RA40 for a definition of “Fundamental Research.”) However, there may be cases where working with a student or postdoc might be considered a “foreign component,” if that student or postdoc is performing effort in a foreign country. NIH defines a foreign component as “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."


What is Penn State doing to address the issue?

Penn State is working with the Council on Governmental Relations (COGR), an association of research institutions, to provide feedback and suggest policy improvements and clarifications around this issue.

Among the suggestions made by the advisory committee to the NIH was to update policies and forms to make requirements more explicit, and clarify when nondisclosure constitutes research misconduct. The Dec. 13, 2018 Report of the Advisory Committee to the NIH Director can be found here:

Can I add disclosures to current projects or proposals?

Yes – contact OSP at to have your application corrected.


Sources Updated on July 21, 2020.

Senate and Congressional Sources

Sen. Grassley’s response letter to NIH, Jan. 8, 2019

Senate Commitee on Finance letter from Chuck Grassley to NSF Director France A. Córdova, April 15, 2019

Senate Committee on Finance: "Grassley Probes Foreign Threats to Taxpayer-Funded Research at Defense Department," April 2, 2019

Sen. Chuck Grassley’s letter to NIH, Oct. 24, 2018

Aug. 13, 2018: H.R. 5515 Sec. 1286: National Defense Authorization Act's initiative to protect researchers from undue influence and security threats

National Institutes of Health (NIH)

NIH Guidance

NIH Definition of Foreign Component

NIH Definition of Other Support

NIH Application Instructions (Foreign Components mentioned on page 66)

NIH Guidance on Investigator Disclosures of Foreign Financial Interest

Protecting U.S. Biomedical Intellectual Innovation

NIH Communications and articles

NIH response letter to Sen. Grassley, Dec. 21, 2018

NIH presentation on Foreign Influences on Research Integrity (Dec. 13, 2018)

Aug. 20, 2018 Letter from NIH to research institutions regarding increased disclosure

July 10, 2019: "Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components"

March 30, 2018 Letter from NIH to research institutions regarding disclosure of foreign financial interests

National Science Foundation (NSF)

NSF Dec. 2019 report (compiled by JASON), "Fundamental Research Security" 

NSF Statement on security and science dated Oct. 23, 2018

Department of Energy (DOE)

June 7, 2019 DOE Directive regarding Foreign Government Talent Recruitment Programs

Department of Defense (DoD)


Federal Bureau of Investigations (FBI)

Foreign Government-Sponsored Talent Recruitment Plans (PDF)

FBI Report on the risks to academia (PDF)


Other articles or communications

Feb. 7, 2019, NIH asks inspector general to investigate 12 allegations of foreign influence in U.S. research