Grant Review, Co-Authorship and Other Customary Academic Activities in an International Environment

Guidance to Faculty and Principal Investigators Regarding International Activities

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May I review grants and proposals for international colleagues or foreign organizations?

In general, you can participate in the grant and proposal review process, but there are certain internal and external requirements that apply depending upon the particulars of your review activities. First, if you have received compensation to perform the reviews or if the reviews have taken a substantial time commitment, then you must report the activity to MIT as part of the outside professional activity (OPA) disclosure process.  Second, you may need to disclose your review activities in connection with applications for federal funding, particularly if you are conducting reviews for foreign universities or organizations.  Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed. This information may need to be included in your curriculum vitae or biosketch or in the current and pending or other support portion of the application or subsequent progress reports. If you have specific questions, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation.  Third, if you receive compensation greater than $5,000, then you may need to report this compensation as part of the financial conflict of interest disclosure process if you apply for external funding through MIT.

If you are contemplating becoming a grant or proposal reviewer for a university or organization in China, Russia, North Korea or Iran, then you should contact research-compliance-help@mit.edu to get assistance in determining whether the parameters of your engagement could be considered by the U.S. government as participation in a “foreign government-sponsored talent recruitment program.” The U.S. government identifies talent recruitment programs involving the foregoing countries as of heightened risk, and some federal agencies prohibit funding recipients from participating in these countries’ talent recruitment programs and/or impose special disclosure requirements on reviewer activities.

Lastly, if you are considering serving as a grant or proposal reviewer for a foreign university or organization, then you should also contact exportcontrolhelp@mit.edu, and the export control team can screen the organization against U.S. sanctions lists and also advise on other potential export control risks.

February 19, 2021

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May I serve as a thesis advisor or co-advisor for students at foreign universities?

Yes, but you should be aware of certain internal and external requirements. First, you must report any academic advising activities with an outside educational institution as part of MIT’s outside professional activity (OPA) disclosure process. Second, you may need to disclose your outside academic advising activities in connection with applications for federal funding, particularly if you are advising a student at a foreign university.  Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed. This information may need to be included in your curriculum vitae or biosketch or in the current and pending or other support portion of the application or subsequent progress reports. If you have specific questions, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation. Third, if you receive compensation greater than $5,000, then you may need to report this compensation as part of the financial conflict of interest disclosure process if you apply for external funding through MIT.

If you are contemplating becoming an advisor to students at a university in China, Russia, North Korea or Iran, then you should contact research-compliance-help@mit.edu to get assistance in determining whether the parameters of your engagement could be considered by the U.S. government as participation in a “foreign government-sponsored talent recruitment program.” The U.S. government identifies talent recruitment programs involving the foregoing countries as of heightened risk, and some federal agencies prohibit funding recipients from participation in these countries’ talent recruitment programs and/or impose special disclosure requirements on academic advising activities.

Lastly, if you are considering serving as a thesis advisor or co-advisor for a foreign university, then you should also contact exportcontrolhelp@mit.edu, and the export control team can screen the organization against U.S. sanctions lists and also advise on other potential export control risks.

February 19, 2021

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May I serve as an external referee on a doctoral thesis committee for students at foreign universities?

Yes, but you should be aware of certain internal and external requirements.  First, if you received compensation for this activity or if it involved a substantial time commitment, then you must report it as part of MIT’s outside professional activity (OPA) disclosure process.  Second, you may need to disclose your doctoral thesis committee activities in connection with applications for federal funding, particularly if you are serving in this capacity at a foreign university. Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed. This information may need to be included in your curriculum vitae or biosketch or in the current and pending or other support portion of the application or subsequent progress reports. If you have specific questions, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation. Third, if you receive compensation greater than $5,000, then you may need to report this compensation as part of the financial conflict of interest disclosure process if you apply for external funding through MIT.

If you are contemplating becoming an external referee on a doctoral thesis committee at a university in China, Russia, North Korea or Iran, then you should contact research-compliance-help@mit.edu to get assistance in determining whether the parameters of your engagement could be considered by the U.S. government as participation in a “foreign government-sponsored talent recruitment program.” The U.S. government identifies talent recruitment programs involving the foregoing countries as of heightened risk, and some federal agencies prohibit funding recipients from participation in these countries’ talent recruitment programs and/or impose special disclosure requirements on academic advising activities.

Lastly, if you are considering accepting a doctoral thesis committee position or other engagement with a foreign university or organization, then you should also contact exportcontrolhelp@mit.edu, and the export control team can screen the organization against U.S. sanctions lists and also advise on other potential export control risks.

February 19, 2021

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May I collaborate informally (i.e. on an individual-to-individual basis without a signed agreement between MIT and the collaborator’s institution) or co-author a paper with other academics around the world?

Yes.  However, when working informally with those outside the U.S., please be aware of the following:

  • You should contact exportcontrolhelp@mit.edu, and the team there can work with you to ensure that any physical items, software or technical information you need to send internationally is exported in accordance with U.S. laws.
  • Under U.S. sanctions laws, even informal collaborations may present compliance issues if you are collaborating with a colleague in countries that the U.S. has comprehensively sanctioned— Iran, Cuba, North Korea, Syria or the Crimea region of Ukraine. There are also some persons and entities, including certain universities and research institutions, that are subject to special sanctions by the U.S. government. The export control team (exportcontrolhelp@mit.edu) can screen your potential collaborators against U.S. sanctions lists and also help if you are considering an informal collaboration with someone in the above countries.
  • In addition to sanctions and export control concerns, if you are sharing research data or materials (either sending or receiving) with an outside party, please go to https://nda.mit.edu/ to explore the need for a confidentiality, data use, or material transfer agreement to protect your data and your research.
  • Finally, if your informal collaborations— whether domestic or international— relate to research you are pursuing under a federal award, you may need to disclose these activities in the proposal or in future progress reports.  Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine which of your activities must be disclosed.

February 19, 2021

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May I involve MIT students in my international collaborations?

Yes. MIT’s sponsored research and collaborations regularly involve support for student researchers. Please see the response to "May I collaborate informally or co-author a paper with other academics around the world?" for general guidance regarding any informal international collaboration activities.

February 19, 2021

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May I share the publicly available results of my MIT research throughout the world?

Yes. Research results that are ordinarily published and shared broadly are considered the results of “fundamental research” and are not subject to U.S. export control restrictions.  All on‐campus research conducted by MIT is structured as fundamental research. Note, however, that the shipment of any physical item (e.g. a prototype, compound, or physical model) is subject to U.S. export control restrictions even if created or used in the course of fundamental research. Certain encryption software may also require special consideration. If you intend to ship physical items or transmit encryption software internationally, please contact exportcontrolhelp@mit.edu.

February 19, 2021

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