Johns Hopkins University values an open and diverse education and training environment that fully supports federally funded research and international collaborations. Vice Provosts Denis Wirtz and Jon Links have previously explained the balance we must strike between open collaboration and our obligations to our federal funders. JHU is committed to both protecting U.S. research and innovation and to complying with U.S. Government directives and disclosure regulations.
Increased concern has been expressed through both legislative actions and agency regulations about protecting national security and U.S. economic interests when taxpayer dollars fund the University’s work. It is important that we be responsible stewards of these funds and ensure that we are mindful of protecting intellectual property and know-how, as required by the terms of our funding.
Below we provide guidance and resources regarding University compliance obligations.
|Faculty members must not accept offers of appointments at outside institutions (e.g., universities, institutes of higher education, research institutes, corporations or similar organizations) until written approval is granted by the faculty member’s respective Dean’s Office. In some cases, the commitment to the outside institution may require a reduction in the faculty member’s FTE appointment at the University. Faculty members should complete the standard request form for their division and submit it to their Department Administrator and/or Chair for review before an appointment can be considered.Once the review is complete, the application will be forwarded to their Vice Dean. The Dean’s office will coordinate the review with other offices and make a final decision regarding the proposed appointment.|
|Please follow the links below for the specific instructions and application forms for each division of the University:|
-Carey Business School (CBS)
-Johns Hopkins School of Public Health (JHSPH)
-Krieger School of Arts and Sciences (KSAS)
-School of Advanced International Studies(SAIS)
-School of Nursing – Foreign and Domestic Institutions(SON)
-School of Nursing – Outside Institution(SON)
-School of Medicine (SOM)
-Whiting School of Engineering (WSE)
Johns Hopkins values and seeks to enhance our education and training activities with international partners and students. To successfully nurture such engagements, faculty need to be attentive to a variety of reporting requirements which stem from both University policy and funder requirements. All outside activities—even uncompensated activities—that are related to university duties must be reported.
Proposals Be thorough and complete in accounting for all forms of research support, including from foreign sources and gifts. If you have an affiliation with another institution and receive access to labs or equipment there, you must include that in all proposals. If any of the work of your award is done through your affiliation at a foreign institution, you must also obtain prior approval for this foreign component. You need to work through your research administration office on seeking that approval.
Conflict of interest (COI) and Conflict of Commitment (COC) Disclose financial interests and outside professional activities via eDisclose – both annually and within 30 days of acquiring new interests as required by JHU Policy.
You must disclose outside activities, whether or not compensated, and financial interest if they are related to your “institutional responsibilities.” Institutional responsibilities may include, among other things, research, teaching, clinical care/practice, and administrative responsibilities. Disclosure is required so the School can review outside interests and activities for conflict of interest and conflict of commitment.
For Sponsor Specific Guidance, see the Current and Pending, or Other Support Page: JHU Guidance on Completing Sponsor Forms.
Under the NIH Grants Policy Statement, a Foreign Component is defined as “The performance of 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.”
Examples of activities that would meet this definition include, but are not limited to:
- The involvement of human subjects or animals
- Extensive foreign travel by recipient project staff for the purpose of data collection surveying, sampling, and similar activities
- Any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country
Examples of other grant-related activities that may be significant are:
- Work scope performed in a foreign location, either funded by the federal sponsor or by other sources, domestic or foreign
- Collaborations with investigators at a foreign site anticipated to result in co-authorship; (e.g., research data generation, data analysis, etc.) by a foreign supported scientist or student, who had previously been visiting the grantee institution and reported as Other Support, upon their return to their foreign home institution, would require prior approval for as a foreign component
- Sharing of data with a foreign collaborator can become a foreign component if it results in a publication when the analysis of the data at a foreign site is part of the scientific conclusions of your federally funded project
- Use of facilities or instrumentation at a foreign site
- Receipt of financial support or resources from a foreign entity
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.
Other sponsors have similar requirements to disclose foreign components.
All foreign components should be disclosed on proposals, progress reports and final technical reports. There are multiple ways in which foreign components must be disclosed:Identifying a “foreign component” in a grant application or Just in Time submission
- Listing a “non-U.S. performance site”
- Identifying foreign relationships and activities in a biosketch
- Checking “yes” to the question on the Coeus Questionnaire Q1055 “Will your project require the involvement of any foreign country, its citizens or organizations”
Please note that adding a new foreign component requires prior approval by the sponsor.
Foreign Talent Programs
Participation in a foreign talent program, such as China’s Thousand Talents Program, is an issue that is being examined with a great deal of scrutiny by the federal government. Foreign talent programs are defined as “any foreign-state-sponsored attempt to acquire US scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States” (see Department of Energy (DOE) Order 486.1).
Most of the federal government’s attention has focused on programs originating in China, but talent programs have also been associated with other governments. There is no particular formula or format for these programs and each one can be unique. Typically, the entity reaches out to an investigator directly via email, letter, contract, application, or some other invitation to join. The invitation to join the program will contain opportunities, such as a faculty appointment at a foreign university or institute, funding, resources, space, or other enticements to become affiliated with the talent program. In return, there is often an obligation for the investigator to provide research results, data, technology, or information from other funded research programs.
Unless the sponsor prohibits involvement in a foreign talent program (such as the Dept. of Energy), any involvement in these programs must first be approved in accordance with faculty member’s school policy and subsequently reported in Current and Pending Support or Other Support.
The NSF has defined foreign government talent programs as programs where a foreign state provides compensation (which can include titles, research funding or other consideration) in exchange for the faculty member sharing their knowledge and expertise to the foreign country. The NSF definition can be seen here.
It can be difficult for faculty to determine whether an invitation from a foreign institution might actually be part of a foreign government talent recruitment program, especially in countries where the universities are run by the government. The Center for Security and Emerging Technology (CSET) has created public catalogue of available information about Chinese Talent Recruitment Programs which would likely fall within the DOE and NSF definitions. To learn more, visit this page.
To ensure that intellectual property is protected and, when required, appropriately reported to sponsors, promptly disclose to the Johns Hopkins Technology Ventures Office the creation of Intellectual Property or potential inventions.
The University recognizes the benefit of collaborating with visitors from other institutions and organizations and regularly has individuals visit to engage in scholarly activities. The Visitor’s Policy outlines the requirements governing the appointment of all Visiting Professors, Visiting Scholars and Visiting Students, and the screening of all visitors to the University.
In addition to restricted party screening, it is important to be diligent in evaluating the nature of any potential visiting collaborators. Visitors with extended stays, or who do not have the appropriate background for the anticipated research activity, must be carefully scrutinized, including that their access to Johns Hopkins space and systems is appropriate for the proposed work. Any activity that raises suspicion should be thoroughly evaluated in consultation with your Dean’s Office.
Regulations around export controls are complex and constantly evolving, and there are several issues to be considered before engaging in a wide range of export-controlled activities. Consult the University’s Export Controls Compliance Office if you have any export control related questions.
For example, several countries are under comprehensive federal embargo (Cuba, Iran, North Korea, Syria, and the Crimea Region of the Ukraine). Travel to/from these countries/territories should be disclosed to the Office for Export Controls Compliance as soon as possible in advance of the anticipated activity to ensure appropriate clearance can be obtained.
Research or other work that is contemplated with foreign persons—whether that work is performed in the U.S. or abroad—and has not already been disclosed in Coeus needs to be brought to the attention of the Export Controls Office for export control and sanctions programs screening.