International Research and Engagement

Federal agencies have released a mix of broad and targeted information on foreign activities and disclosure obligations. These include:

• Circulating "Dear Colleague" Letters:
  • Letter from NIH Director on agency's steps to mitigate inappropriate influence
  • Letter from NSF Director on updates to improve disclosure
  • Letter from Under Secretary of Defense on DOD steps to protect research
• Releasing revisions or additions to existing policy:
  • NIH Notice NOT-OD-19-114: Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interest and Foreign Components
  • DOE Order 486.1: Foreign Talent Recruitment Programs

DOD Memo: Actions for the Protections of Intellectual Property, Controlled Information, Key Personnel and Critical Technologies

WPI encourages its faculty to engage in foreign collaborations, but it is important to understand reporting obligations related to these activities. If unsure, err on the side of transparency when considering or reporting a foreign activity. The following guidance is provided so that faculty are aware of what they have to disclose, where they have to disclose, and who to contact for internal assistance.

Foreign Components of research include locations outside of the U.S. where a significant scientific element or segment of a project is performed, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended outside the U.S.

Principal Investigators should review current projects to ensure that all Foreign Components have been disclosed through progress reports and final technical reports, and to obtain prior approval when adding a Foreign Component to an existing federal award.  All new proposals must include a clear description of all Foreign Components. Sponsors have varying requirements to disclose foreign components, so it is important to understand each sponsor's proposal instructions before submission.

Please contact the Office of Sponsored Programs if you have questions.

Other Support, sometimes referred to as "current and pending support" or "active and pending support" typically includes all resources, regardless of monetary value, available in direct support of an individual's research endeavors. Principal Investigators should review each funding application to ensure that all Other Support is disclosed as required by their federal sponsors, and that it is reported in the proper section of the application. Federal agencies closely review Other Support to ensure that no time commitment or budgetary overlap exists, and that there is no scientific duplication.  

For more detailed information on how to how to disclose Foreign Components and Other Support to NIH, NSF and DOD, please consult the OSP website.

U.S. export laws regulate the shipment, transfer, or disclosure of physical exports, technical data, and software to foreign countries or to foreign persons, including our students and faculty, and entities within the U.S. Federal export regulations govern shipments and releases of certain sensitive commodities, technologies, and software to non-U.S. locations and persons. In addition, economic sanctions rules can significantly affect educational and research activities involving Cuba, Iran, Syria, North Korea, and the Crimea region of Ukraine.  These laws aim to protect U.S. national security, economic interests, and foreign policy.  Moreover, these laws restrict exports to certain entities and individuals, including some academic institutions in some countries, as well as the sharing of technologies with individuals affiliated with those entities while in the United States. 

Faculty and staff who engage in any of these activities should be aware of export controls and how they apply in each case.  For more information, please refer to our Export Control Guidelines.  Also, Gabe Johnson, WPI's Export Control Officer, is available to provide training, or review individual situations upon request. 

Academic Visitors are individuals supported by other academic institutions or companies (foreign or domestic) who receive an invitation from a WPI host school or department to be a guest on our campus for a specified amount of time and for a specific academic or research purpose. WPI fully supports the hosting of foreign visitors for academic or research collaborations. 

Departments are responsible for verifying the eligible visa status of their visiting scientists, and certain visa statuses are not eligible to serve as visiting scientists. Please contact International Faculty and Scholars Services for assistance with any visa-related issues. International visitors are a welcome addition to our campus, and the University supports such collaborations. Visitors (foreign or domestic) who are working alongside University personnel are expected to have on file with their department an offer letter prior to work being undertaken.

The University's process for hiring visiting researchers and post-docs is managed by The Vice Provost for Research.  Please contact Camille Bouchard-Chhoeuk for assistance. 

Intellectual property (IP) refers to innovations that the law protects from unauthorized use by others. Main forms of IP include patents, copyrights, trademarks, and trade secrets. In an international research setting, IP protects the following: drugs, devices, software codes, curriculum, reagents, and data. Faculty and staff should report inventions and disclose Intellectual Property that may need to be protected through the Office of Technology Commercialization.  You may also want to refer to WPI's IP policy for further information about WPI's processes regarding disclosing and protecting intellectual property. 

Patents are contracts between the governments and inventors: In the case of the U.S., disclosure in exchange for the right to exclude others from making, using, selling, offering for sale the invention in the U.S., or importing the invention into the U.S. In addition, patents are geographically restricted (filed country by country where protection is desired), and administered by a country's patent office. Therefore, U.S. patents do not protect IP outside of the United States. Further, publicly disclosing an innovation

before appropriate patent application filing may prevent an innovator's ability to obtain patent protection on that discovery in international settings. 

U.S. Copyrights are a form of protection provided by U.S. law to the authors of "original works of authorship," including software. Copyright protection automatically arises once an original effort has been fixed in a tangible medium, and can be registered with the U.S. Copyright Office of the Library of Congress.

Protection against unauthorized use in a particular country depends on the laws of that country. Many countries offer protection to foreign works under certain conditions that have been greatly simplified by international copyright treaties and conventions. The United States has copyright relations with most countries throughout the world, and as a result of these agreements, we honor each other's citizens' copyrights.

Trademarks and Service Marks refer to words, names, symbols, devices, or any combination of these used, or intended to be used, in commerce to identify and distinguish the goods or services of one manufacturer or seller from those sold by others, and to indicate the source of the goods or services. Trademarks can be renewed forever as long as they are being used in commerce. Trademark rights are geographically restricted and are administered by each country's trademark office.

The Office of Technology Commercialization 

is available for any questions related to intellectual property, patents, copyrights, or trademarks.

WPI through its Division of Advancement cultivates and manages relationships with contributors, alumni, and other constituents to generate support for teaching, research and public service.  All gifts and donations meant to benefit WPI are subject to accounting rules and other federal reporting requirements, such as section 117 of the Higher Education Act.  This Act requires academic institutions such as WPI to report foreign gifts and contracts that meet certain dollar thresholds to the U.S. Department of Education on a bi-annual basis. 

Gifts and donations can be monetary or in-kind and must be reviewed, approved, and processed through Advancement so that the University can properly account for the funds and manage the important relationships that are behind each gift or donation.  Please contact Advancement with questions about gifts or donations.