International Collaboration: Publication and Reporting
Collaboration Reporting Requirements
Guidance is provided for:
Travel
It is common to travel outside the US for conferences or in support of collaborative efforts. Some U.S. federal agencies have instituted travel reporting requirements associated with federal awards. Typically, these require all international travel, both personal and business, by all individuals involved with the research efforts under an award prior to such travel. There may be additional reporting requirements for travel to countries of concern. For additional travel guidance see: International Travel Guidance and Export Travel Guidance
Biosketch
It is also common to have an affiliation with a collaborator institution/entity, such as a visiting professorship, member of a scientific advisory board or honorary appointment. These affiliations should be reported to sponsors in your Biosketch and to Caltech through your DFIC. If an affiliation is with a foreign institution/entity, care should be taken to ensure it is not with an entity on the restricted parties list or that the relationship could be considered a Malign Foreign Talent Recruitment Program.
Current/Pending/Other Support
U.S. Federal Agency Sponsors require that contributions to research (whether or not US federally funded) be reported as other support. This includes contributions of visitors or foreign collaborators. Please See: Transparency in Research: Federal Agency Disclosure Requirements - Caltech Office of Research Policy
Foreign Component
When conducting research using PHS/NIH funds, researchers should note that PHS/NIH considers collaborations with investigators at a foreign site anticipated to result in co-authorship as a possible foreign component and, as such, requires prior approval. Please see: NIH Notice NOT-OD-26-084 Reminder – Definition of Foreign Components
Risk Mitigation
As part of U.S. Federal Agency foreign engagement risk review for new awards (and sometimes, renewals), all publications for the last 4-10 years (depending on agency) and all patents are reviewed for foreign authors or authors with foreign affiliations and foreign funding sources. Should any of these be with a person or an entity/institution on a restricted parties list, the sponsor will likely require certification that you will not continue collaboration with such person or entity/institution.
Authorship
As a general rule, researchers should take care not to include authors (foreign or domestic) who have not contributed substantially to the paper and should not include anyone gratuitously as an author or in the acknowledgements if they have not contributed. Likewise, authors should not cite gratuitously to federal funding if none was used in support of the reported research. Several sponsors have issued new terms and conditions (including on renewals of existing awards) restricting collaborators in foreign countries from conducting or collaborating on research or collaboratively writing a publication stemming from the federally funded research. For further guidance, see agency specific requirements, above.
Footnotes
1:
Fundamental Research means research in science, engineering, or mathematics, the results of which ordinarily are published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons. Prepublication review is conducted solely to ensure that publication would not compromise patent rights, so long as the review causes no more than a temporary delay in publication of the research results AND/OR Prepublication review is conducted by a sponsor of research solely to insure that the publication would not inadvertently divulge proprietary information that the sponsor has furnished to the researchers. 15 CFR 734.8 https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-734/section-734.8
2:
INSIDE the US: General scientific discussions with non-US parties are always permissible when they focus on fundamental research and information in the public domain.
3:
OUTSIDE OF US: Using Visual Compliance, scan all potential collaborators from Russia, Iran, Syria, N. Korea, China, Cuba, and Venezuela (Countries of Concern) as they are either embargoed or otherwise heavily regulated.
4:
US Restricted Parties (RP). Restricted Parties Screening (RPS): Federal restricted party lists are lists of people, companies, institutions or foreign5 agencies that the U.S. Government has identified as being of concern to U.S. national security. The federal government maintains several lists of restricted parties, which it routinely updates. Some examples are the Department of Defense (DOD) 1286 List, the Bureau of Industry and Security (BIS) Denied Persons list, BIS Entity List and the Office of Foreign Asset Controls (OFAC) Specially Designated Nationals and Blocked Persons list. Caltech has a paid subscription with a commercial entity that can be used to search all these lists. Contact [email protected] for access to this search engine. As a preliminary screen, researchers can use https://www.trade.gov/data-visualization/csl-search and https://sanctionssearch.ofac.treas.gov/ and https://sanctions-finder.com/. These sites may also be helpful if traveling. If there is a "hit" please contact [email protected] as soon as possible.
5:
Open Conference: International conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law are considered an open conference; https://rt.cto.mil/wp-content/uploads/2025/03/Sec-10631-and-10632-of-CHIPS-and-Science-Act.pdf When attending a conference abroad, consider the host institution and ensure it is not on the RPS list. Consider the subject matter and who you are engaging with. You may not share non-public information with people from Countries of Concern or those on the RPS list. When hosting a conference abroad, scan participants in Visual Compliance to ensure they are not from Countries of Concern or otherwise on the RPS List. Conferences must meet the criteria for open conferences."
6:
Chinese Entity: A Chinese national or an individual from/representing a Chinese university, institution, business, government, or other entity who is NOT a Caltech student, postdoc, staff or faculty.
7:
Caltech personnel, including students, postdocs, staff and faculty, who are foreign persons (e.g. here on a visa) CANNOT count as an additional foreign entity as part of a collaboration. For example, including a regular (not visiting) German Caltech student as a participant cannot transform a bilateral agreement between a Caltech Chinese Entity visitor and Caltech into a multilateral agreement.
8:
Steven's Amendment, Public Law 101-166, Section 511: SEC. 511. When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds, including but not limited to State and local governments, shall clearly state (1) the percentage of the total costs of the program or project which will be financed with Federal money, (2) the dollar amount of Federal funds for the project or program, and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources.
9:
Definition of Foreign Components NOT-OD-26-084: Most instances of co-authorship represent a foreign component. The NIH recognizes, however, that certain contributions are so minor that they do not constitute an actual collaboration. For example, the provision of a single reagent might not be a collaboration but could result in co-authorship. In addition, occasionally co-authorship arises through indirect association, such as when an NIH-funded researcher and a foreign researcher both independently work with the same domestic collaborator but only learn of this fact when a manuscript is prepared describing the work. In all cases, NIH recipients should report foreign co-authorship to the funding Institute or Center as soon as they are aware of it to determine what steps, if any, need to be taken.