International Collaboration: Publication and Reporting
International Collaboration and Publication and Reporting Guidance
Federal sponsors are becoming increasingly concerned about foreign collaborations giving rise to publications funded by the US as evidenced by several US Government reports issued citing US co-authorship or co-funding with Chinese co-authors as evidence of undue foreign influence: DoD/DoW- Fox in the Henhouse | Select Committee on the CCP, DoE- Containment Breach: US DoE Failures in Research Security and Protecting Taxpayer-Funded Research from Foreign Exploitation and NASA- Research Security for America's Future in Space: NASA's Enforcement of the Wolf Amendment. Caltech authors and awards were cited in the DoD report.
Caltech has developed this Collaboration and Publication and Reporting Guidance for Caltech Researchers to aid you in navigating collaborations and co-authorships.
Guidance on Collaborative Relationships/Publications and Co-authorships
- General Scientific Discussions
- Conferences and Meetings
- All Contributors have only US Affiliations and the Research is Performed Entirely in the US and the Collaboration → Publication
- Visitor with Foreign Affiliation is a Contributor to Research Performed Entirely in the US, and the Collaboration → Publication
- Contributor has Left US and now has Foreign Affiliation After Completing all Research in the US and the Collaboration → Publication
- Most Contributors are in the US and have US Affiliations, Some Contributors are in Foreign Country(ies) and have Foreign Affiliation(s) and the Collaboration → Publication
- Most Contributors in a Foreign Country(ies) and have a Foreign Affiliation(s), and Some Contributors are in the US and have US Affiliations and the Collaboration → Publication
Collaboration Reporting Requirements
General Scientific Discussions
Scientific discussions regarding unpublished research with scientists and engineers who are foreign persons and/or have Foreign Affiliations.
(1) Discussions in the US regarding Research: Scientific discussions OK if regarding published/publishable research (FRE) 1,2.
(2) Discussions "outside" 3of the U.S. regarding Research: No scientific discussions about unpublished research with persons on or affiliated with an entity on a US Restricted Parties (RP) List4, even if the subject matter is not controlled.
(3) Not MFTRP: Confirm that the general scientific discussion cannot be construed as participation in a Foreign Talent Recruitment Program. (i.e., Ensure no commitments/remuneration/reward associated with the discussion with a person or entity from a country of concern).
See "General" guidance above, and:
- As long as general scientific discussions regarding research do not constitute a bilateral policy, program, order, or contract, they are permitted.
- However, these scientific discussions regarding research must also not involve discussions about bilateral collaboration between NASA and Chinese entities. https://science.nasa.gov/researchers/sara/faqs/prc-faq-roses/
See "General" guidance above, and:
Confirm that the general scientific discussion cannot be construed as collaboration. No collaboration with persons or entities on the Restricted Parties lists is allowed.
See "General" guidance above, and:
- Confirm that the general scientific discussion cannot be construed as collaboration that may require prior approval as a foreign component.
See "General" guidance above.
See "General" guidance above.
See "General" guidance above, and:
Confirm that the general scientific discussion cannot be construed as collaboration. No collaboration with persons or entities on the Restricted Parties lists is allowed.
Conferences & Meetings
Attending Conferences and Meetings
(1) Open Conference: The conference/meeting must meet the criteria for open conference and not be an MFGTRP, per CHIPS & SCIENCE5
(2) Federal Funds Used for Travel: Foreign Travel may Require Approval for use of federal funds to pay for travel. Confirm requirements with your award documents.
(3) Conference in the US: If open conference/meeting is IN THE US, it is generally fine, as long as research is subject to FRE (subject matter is not controlled).
Conference "outside" 3 US: If open conference is OUT OF US OR HOSTED BY A FOREIGN ENTITY IN THE US: Researcher must perform Restricted Parties Search (RPS) for hosting institution. If host Institution is a RP, consider who the attendees are and the consequences of sharing information with these individuals. If your award prohibits collaboration with RP, then you may have to refrain from attendance.
(4) RP Collaborators/Co-authors: Avoid collaboration/co-authorship with persons or entities on RP list
(5) Use ORCiD: Include your ORCiD, if possible, with any published abstract or conference proceeding.
See "General" guidance above, and:
- The conference cannot be a conference with only Chinese participants
- NASA must approve of use of NASA funds to pay for Foreign Travel
- The conference cannot be a conference hosted at a RP institution
See "General" guidance above, and:
- DoD may require approval for use of DoD funds to pay for Foreign Travel
- DoD may require reporting to and/or approval of Foreign Travel (e.g., as a contractual term of Award or as Requirement in Risk Mitigation Plan)
- As appropriate, acknowledge DoD funding and Award Number.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Confirm that participation in conference cannot be construed as collaboration with persons or entities on the Restricted Parties lists. Collaboration with RP is prohibited.
See "General" guidance above, and:
- Reimbursed Foreign Travel must be reported in DFIC- possible SFI (FCOI)
- Confirm that the presentation/abstract/collaboration cannot be construed as collaboration that may require prior approval as a foreign component.
- As appropriate, acknowledge PHS/HHS/NIH funding in accordance with the Steven's Amendment8
- Do not send US funding to Foreign Entity unless approved by the Agency.
See "General" guidance above.
See "General" guidance above, and:
- Reimbursed Foreign Travel must be reported in DFIC- possible SFI (FCOI)
- As appropriate, acknowledge DoE funding and Award Number.
See "General" guidance above, and:
Dear Colleague letter July 2024 expands risk review and provides prohibitions.
- Confirm that participation in conference cannot be construed as collaboration with persons or entities on the Restricted Parties lists. Collaboration with RP is prohibited.
- As appropriate, acknowledge NSF funding and Award Number.
All Contributors have only US Affiliations and the Research is Performed Entirely in the US → Publication
ALL collaboration/research takes place entirely in the US, by people in the US, there are no publication restrictions (FRE), and all authors are still in the US with US affiliations. There are no Foreign Affiliations listed in publications.
(1) No Gratuitous Authorship. Do not provide gratuitous authorship.
(2) No Unwarranted Acknowledgement. Do not acknowledge a sponsor if that sponsor's funding was not used for the project reported in the publication.
Steven's Amendment: If appropriate to acknowledge PHS/NIH, DoL, DoEd sponsor, follow Steven's Amendment 8acknowledgement requirements.
(3) Use ORCiD: Include your ORCiD with all publications.
(4) RP Collaborators/Co-authors: Avoid collaborations (including co-authorship) with anyone on a Restricted Parties List.
(5) Report US Affiliation: All authors should report US affiliation where the research was done.
See "General" guidance above, and:
- Acknowledge NASA Funding and Award Number.
- Avoid collaborations/publishing where there is only one foreign author and they are from PRC.
See "General" guidance above, and:
- Acknowledge DoD funding and Award Number.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Report Publications on RPPR.
- No collaboration with persons or entities on the Restricted Parties lists is allowed.
See "General" guidance above, and:
- Acknowledge PHS/HHS/NIH funding in accordance with the Steven's Amendment8
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Report Publications on RPPR.
See "General" guidance above, and:
- Acknowledge USDA funding and award number.
- Note: Caltech must certify that the investigator has not been part of a MFGTP for the past 10 years.
- USDA has general research security disclosure and training requirements, but they do not currently speak to publication.
- Guidance RE: Publications/Collaborations anticipated.
See "General" guidance above, and:
- Acknowledge DOE funding and award number.
- DOE has a subject matter specific Risk Matrix. It does not speak to publications,etc.
- Risk Matrix and guidance re publication/collaboration anticipated.
See "General" guidance above, and:
- Acknowledge NSF funding and award number.
- Dear Colleague letter July 2024 expands risk review and provides prohibitions. No collaboration with persons or entities on the Restricted Parties lists is allowed.
- Generalized Risk Matrix coming soon. Risk Review has been limited to Quantum Information Science. TRUST Program reviews Appointments, Affiliations and Support.
- Active Collaboration Review and additional FY27 SBIR/STTR Risk Matrix anticipated.
Visitor with Foreign Affiliation is a Contributor to Research Performed Entirely in the US, and the Collaboration → Publication
ALL collaboration/research takes place entirely in the US with a foreign visitor or visitor from a foreign entity (Foreign Affiliation) conducting some portion of that research in the US. The Visitor is an author and their Foreign Affiliation is listed in publications
No visitors or visitors with current affiliations with an entity on a US Restricted Parties List or visitors who are active in a Foreign Military from a country of concern will be approved to conduct research at Caltech. All Visiting Researchers should be approved through VAR.
----------------------------------------------------
If the Collaboration is anticipated to lead to Publication:
(1) No Gratuitous Authorship. Do not provide gratuitous authorship.
(2) No Unwarranted Acknowledgement. Do not acknowledge a sponsor if that sponsor's funding was not used for the project reported in the publication.
Steven's Amendment: If appropriate to acknowledge PHS/NIH, DoL, DoEd sponsor, follow Steven's Amendment 8acknowledgement requirements.
(3) Use ORCiD: Include your ORCiD with all publications.
(4) RP Collaborators/Co-authors: Avoid collaborations (including co-authorship) with anyone on a Restricted Parties List. Confirm there is no RP funding used and acknowledged.
(5) Report Visitor Affiliation: If Visitor has Foreign Affiliation, confirm that they and their affiliated institution are not on RP list and that no RP funding was used, before proceeding with publication. If RP or RP funding, contact Associate Vice Provost for Research Policy and Compliance for guidance.
If there is a Visitor who has an Affiliation with an Entity from a Foreign Country, they would be considered as research collaborations conducted partially in a foreign country, even though the research was conducted in the US (because the visitor would report their foreign affiliation in a publication)
See "General" guidance above, and:
- Acknowledge NASA funding and Award Number.
- The proposed collaboration cannot be a bilateral one with a Chinese Entity.
- If there are multiple foreign entities7, confirm that the entities are not RP.
- If visitor or entity is placed on a RP list after arrival and the visitor is from China, collaboration must end and appointment must be terminated.
See "General" guidance above, and:
- Acknowledge DoD funding and award number.
- Report Publications on RPPR.
- Confirm there is no RP funding.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- PI should have a documented explanation for all Foreign Affiliations, especially if Visitor leaves and takes residence at a Restricted Party Institution.
See "General" guidance above, and:
- Acknowledge PHS/HHS/NIH funding in accordance with the Steven's Amendment8
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Report Publications on RPPR.
- If Visitor has Foreign Affiliation, NIH may consider this a "Foreign Component" that requires pre-approval. Contact Research Security or Office of Sponsored Research for guidance.
- PI should have a documented explanation for all co-authors with Foreign Affiliations.
See "General" guidance above, and:
- Acknowledge NSF funding and award number.
- Dear Colleague letter July 2024 expands risk review and provides prohibitions. No collaboration with persons or entities on the Restricted Parties lists is allowed.
- Generalized Risk Matrix coming soon. Risk Review has been limited to Quantum Information Science. TRUST Program reviews Appointments, Affiliations and Support.
- Active Collaboration Review and additional FY27 SBIR/STTR Risk Matrix anticipated.
Contributor has Left US and now has Foreign Affiliation After Completing all Research in the US and the Collaboration → Publication
ALL collaboration/research was completed in the US, by people in the US, there are no publication restrictions (FRE), but some authors have left US and now have Foreign Affiliations. The Contributor is an author; however, their affiliation on the publication must be the US institution where the research was conducted.
If the Collaboration is anticipated to lead to Publication:
(1) No Gratuitous Authorship. Do not provide gratuitous authorship.
(2) No Unwarranted Acknowledgement. Do not acknowledge a sponsor if that sponsor's funding was not used for the project reported in the publication.
Steven's Amendment: If appropriate to acknowledge PHS/NIH, DoL, DoEd sponsor, follow Steven's Amendment 8acknowledgement requirements.
(3) Use ORCiD: Include your ORCiD with all publications.
(4) RP Collaborators/Co-authors: Avoid collaborations (including co-authorship) with anyone on a Restricted Parties List. Confirm there is no RP funding used and acknowledged.
(5) Report US Affiliation: Since all research was completed in the US, Collaborator/Co-author should report US (e.g. Caltech) Affiliation. Persons who have left Caltech after research is complete, must report Caltech affiliation on the publication. Such Co-authors can include a comment that the individual has since moved to "New (Post-Caltech) Affiliation." If Collaborator/Co-author currently has a Foreign Affiliation, confirm that they and their affiliated institution are not on RP list and that no RP funding was used, before proceeding with publication. If RP or RP funding used, contact Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
- Acknowledge NASA funding and Award Number.
- If Co-author leaves, and has new Foreign Affiliation, confirm that the entity is not on a RP list.
- If there is only one author, they leave the US and are now affiliated with a Chinese entity, Caltech NASA funded PI cannot continue collaboration with that person.
See "General" guidance above, and:
- Acknowledge DoD funding and award number
- Report Publications on RPPR.
- Confirm there is no RP funding.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Some Caltech Awards Do Not Allow Continued Collaboration if the collaborator has left the US. If your award has such a condition, you may not continue to share data/manuscripts with the researcher who has left the country.
- Persons who have left Caltech, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- PI should have a documented explanation for all Foreign Affiliations, especially if co-author is now at Restricted Party Institution.
See "General" guidance above, and:
- Acknowledge PHS/HHS/NIH $ in accordance with the Steven's Amendment8
- Report Publications on RPPR.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Persons who have left Caltech, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- Inclusion of a Foreign Affiliation may result in questions as to whether the foreign institution is a foreign component. Contact Research Security or Office of Sponsored Research for guidance.
- PI should have a documented explanation for all Foreign Affiliations, especially if co-author is now at Restricted Party Institution.
See "General" guidance above, and:
- Acknowledge NSF funding and award number.
- Dear Colleague letter July 2024 expands risk review and provides prohibitions. No collaboration with persons or entities on the Restricted Parties lists is allowed.
- Generalized Risk Matrix coming soon. Risk Review has been limited to Quantum Information Science. TRUST Program reviews Appointments, Affiliations and Support.
- Active Collaboration Review and additional FY27 SBIR/STTR Risk Matrix anticipated.
Most Contributors are in the US and have US Affiliations, Some Contributors are in Foreign Country(ies) and have Foreign Affiliation(s) and the Collaboration → Publication
MOST research was done in the US, by people in the US, there are no publication restrictions (FRE), SOME research was done in Foreign Country, by persons Foreign Affiliations. The Contributors with Foreign Affiliations should be authors; however, ensure that no foreign contributors or their foreign affiliations are on restricted parties lists.
If the Collaboration is anticipated to lead to Publication:
(1) No Gratuitous Authorship. Do not provide gratuitous authorship.
(2) No Unwarranted Acknowledgement. Do not acknowledge a sponsor if that sponsor's funding was not used for the project reported in the publication.
Steven's Amendment: If appropriate to acknowledge PHS/NIH, DoL, DoEd sponsor, follow Steven's Amendment 8acknowledgement requirements.
(3) Use ORCiD: Include your ORCiD with all publications.
(4) RP Collaborators/Co-authors: Conduct RPS Screening on all authors and their current affiliation institutions. Avoid collaborations (including co-authorship) with anyone on a Restricted Parties List. Confirm there is no RP funding used and acknowledged. If RP, reconsider collaboration (consider publishing separately).
(5) Report Collaborator Affiliation: If Collaborator has Foreign Affiliation, confirm that they and their affiliated institution are not on RP list and that no RP funding was used, before proceeding with publication. If RP or RP funding, contact Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
- No NASA funding can be used for any bilateral collaboration with someone affiliated with a Chinese Entity6.
- If there are multiple foreign countries involved (three at least, but preferably four or more), you may proceed if no party is on the RP list- see below:
- Conduct RPS screening of foreign collaborators/co-authors and their affiliated institutions. If RP, do not begin collaboration. If discovered at time of pubication that there is RP person, entity or funding, reconsider collaboration (publish separately) and/or contact the Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
- RPS Screening of Foreign Collaborators/Authors and their Affiliated Institutions. If on RPS, reconsider collaboration (publish separately)
- Some Caltech Federal Awards Do Not Allow collaboration on a project with individuals outside of the US, including continued collaboration with a person who has left Caltech. Confirm that your award allows for collaboration. If your award has a prohibition on collaborations outside the US, you may not continue to share data/manuscripts with the researcher outside of the US or who has left the country.
- Confirm there is no RP funding.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- If acceptable, per above criteria, acknowledge DoD funding and award number.
- Report Publications on RPPR.
- Persons who have left Caltech where the research was conducted, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- PI should have a documented explanation for all Foreign Affiliations, especially if co-author is at Restricted Party Institution.
See "General" guidance above, and:
- Possible Co-authorship with person in a foreign country: Co-authorship could be a collaboration that is considered a Foreign Component9 by PHS/NIH. Foreign components require prior approval from PHS/NIH. Contact Research Security or Office of Sponsored Research for guidance.
If Foreign Collaboration is approved:
- Acknowledge PHS/HHS/NIH funding in accordance with the Steven's Amendment8
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Report Publications on RPPR.
- Persons who have left Caltech after conducting research, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- PI should have NIH Approval documented and a documented explanation for all Foreign Affiliations.
If Foreign Collaboration is not approved:
- Contact the Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
- Acknowledge NSF funding and award number.
- Dear Colleague letter July 2024 expands risk review and provides prohibitions. No collaboration with persons or entities on the Restricted Parties lists is allowed.
- Generalized Risk Matrix coming soon. Risk Review has been limited to Quantum Information Science. TRUST Program reviews Appointments, Affiliations and Support.
- Active Collaboration Review and additional FY27 SBIR/STTR Risk Matrix anticipated.
Most Contributors in a Foreign Country(ies) and have a Foreign Affiliation(s), and Some Contributors are in the US and have US Affiliations and the Collaboration → Publication
MOST research is conducted outside of the U.S. by persons with Foreign Affiliations, and only SOME research was done in US, there are no publication restrictions (FRE). The Contributors with Foreign Affiliations should be authors; however, ensure that no foreign contributors or their foreign affiliations are on restricted parties lists.
If the Collaboration is anticipated to lead to Publication:
(1) No Gratuitous Authorship. Do not provide gratuitous authorship.
(2) No Unwarranted Acknowledgement. Do not acknowledge a sponsor if that sponsor's funding was not used for the project reported in the publication.
Steven's Amendment: If appropriate to acknowledge PHS/NIH, DoL, DoEd sponsor, follow Steven's Amendment 8acknowledgement requirements.
(3) Use ORCiD: Include your ORCiD with all publications.
(4) RP Collaborators/Co-authors: Conduct RPS Screening on all authors and their current affiliation institutions. Avoid collaborations (including co-authorship) with anyone on a Restricted Parties List. Confirm there is no RP funding used and acknowledged. If RP, reconsider collaboration (consider publishing separately).
(5) Report Collaborator Affiliation: If Collaborator has Foreign Affiliation, confirm that they and their affiliated institution are not on RP list and that no RP funding was used, before proceeding with publication. If RP or RP funding, contact Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
- No NASA funding can be used for any bilateral collaboration with someone affiliated with a Chinese Entity6.
- If there are multiple foreign countries involved (three at least, but preferably four or more), you may proceed if no party is on the RP list- see below:
- Conduct RPS screening of foreign collaborators/co-authors and their affiliated institutions. If RP, do not begin collaboration. If discovered at time of pubication that there is RP person, entity or funding, reconsider collaboration (publish separately) and/or contact the Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
Reconsider Collaboration/Publication, especially if Foreign Affiliation is with Restricted Party.
- Conduct RPS Screening of all Foreign Collaborators/Authors and their Affiliated Institutions. If on RPS, reconsider collaboration and publish separately if federal funding is used.
- Some Caltech Federal Awards Do Not Allow collaboration on a project with individuals outside of the US, including continued collaboration with a person who has left Caltech. Confirm that your award allows for collaboration. If your award has a prohibition on collaborations outside the US, you may not continue to share data/manuscripts with the researcher outside of the US or who has left the country.
- Confirm there is no RP funding.
- Do not send US funding to Foreign Entity unless approved by the Agency.
- If acceptable, per above criteria, acknowledge DoD funding and award number.
- Report Publications on RPPR.
- Persons who have left Caltech where the research was conducted, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- PI should have a documented explanation for all Foreign Affiliations, especially if co-author is at Restricted Party Institution.
See "General" guidance above, and:
Reconsider Collaboration/Publication, especially if Foreign Affiliation is with Restricted Party.
- Conduct RPS Screening of all Foreign Collaborators/Authors and their Affiliated Institutions. If on RPS, reconsider collaboration and publish separately if federal funding is used.
- Possible Co-authorship with person in a foreign country: Co-authorship could be a collaboration that is considered a Foreign Component9 by PHS/NIH. Foreign components require prior approval from PHS/NIH. Contact Research Security or Office of Sponsored Research for guidance.
If Foreign Collaboration is approved:
- Acknowledge PHS/HHS/NIH funding in accordance with the Steven's Amendment8
- Do not send US funding to Foreign Entity unless approved by the Agency.
- Report Publications on RPPR
- Persons who have left Caltech after conducting research, must report Caltech affiliation on the publication. They can include a comment that they have since moved to "New (Post-Caltech) Affiliation."
- PI should have NIH Approval documented and a documented explanation for all Foreign Affiliations.
If Foreign Collaboration is not approved:
- Contact the Associate Vice Provost for Research Policy and Compliance for guidance.
See "General" guidance above, and:
Reconsider Collaboration/Publication, especially if Foreign Affiliation is with Restricted Party.
- Conduct RPS Screening of all Foreign Collaborators/Authors and their Affiliated Institutions. If on RPS, reconsider collaboration and publish separately if federal funding is used.
- Dear Colleague letter July 2024 expands risk review and provides prohibitions. No collaboration with persons or entities on the Restricted Parties lists is allowed.
- Acknowledge NSF funding and award number.
- Generalized Risk Matrix coming soon. Risk Review has been limited to Quantum Information Science. TRUST Program reviews Appointments, Affiliations and Support.
- Active Collaboration Review and additional FY27 SBIR/STTR Risk Matrix anticipated.
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.