Disclosing Foreign Support and International Activities

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Policy No.: 8014
Effective Date: 06/26/15
Revised Date:
Reviewed Date:

Disclosure Requirements for Research to Occur at International Institutions without UNMC Funding

Basis for Policy

Statutes, regulations and University policies include:

  • Nebraska Conflict of Interest Statute at Neb. Rev. Stat. §49-1493 et. seq.
  • Bylaws of the Board of Regents of the University of Nebraska Sections 3.10, 3.45 and 3.8
  • Board of Regents Conflict of Interest Policy, RP-3.2.8
  • Board of Regents Patent & Technology Policy, RP-4.4.1 and RP-4.4.2
  • UNMC Policy No. 8010, Conflict of Interest
  • UNMC Policy No. 6100, Direct Cost
  • UNMC Policy No. 1049, Outside Employment
  • UNMC Policy No. 8005 Export Control
  • UNMC Policy No. 8006, Code of Conduct
  • Uniform Guidance Cost Principles, 2 CFR 200 (formally OMB circular A-21 “Cost Principles for Educational Institutions”)
  • U.S. Department of State - International Traffic in Arms Regulations (ITAR) 22 CFR 120-130
  • U.S. Department of Commerce - Export Administration Regulations (EAR) 15 CFR 700-799
  • U.S. Department of the Treasury - Office of Foreign Assets Control (OFAC) 31 CFR 500-599
  • U.S. Foreign Corrupt Practices Act (FCPA) 22 CFR 709

Policy

Any UNMC employee who wishes to engage in research physically located at an international institution and the funding for such research is not processed through Sponsored Programs Administration must: 1) complete the International Project Questionnaire regarding the terms of the research and 2) obtain permission to conduct such research prior to its commencement. This policy is to assure the employee is aware of and maintains compliance with the aforementioned federal and state laws, as well as Board of Regent and university policies, in order to protect both the researcher and UNMC from statutory and regulatory penalties. The International Project Questionnaire is to be submitted to the Compliance Officer, the Vice Chancellor for Research and the Vice Chancellor of Business and Finance.

Permission to engage in such research will require an executed inter-institutional agreement with the international institution detailing the research engagement and terms of the relationship, such as intellectual property rights. The Vice Chancellor for Research and the Vice Chancellor of Business and Finance must both sign the agreement. Violation of this policy shall subject an employee to corrective action up to and including termination of employment or academic disciplinary action, including dismissal.

Additional Information

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