Agency Update: Foreign Collaborations and Research Security FAQ
Quick Summary
- Changes to policies regarding foreign collaboration and research security have sparked many questions among investigators applying for federal funding.
- Key personnel creating biosketches and Current and Pending Support documents in SciENcv need to complete updated research security training to maintain compliance.
- Foreign collaborations are highly valuable to UC Davis research, but additional steps may be required to maintain compliance for federal funding.
- NIH has unique requirements regarding Foreign Components and International Subawards that will require additional documentation.
Recent changes to federal agency policies regarding foreign collaboration and research security have sparked many questions from the UC Davis research community. In particular, the PDS team has been fielding questions regarding how these changes impact ongoing and proposed projects, as well as steps that investigators need to take to be compliant with the new guidance. Here, we share answers and resources to address the most frequent questions regarding foreign collaborations and research security.
In this Agency Update, you'll find information on:
- Research Security
- Foreign Collaboration
- NIH-Specific Guidance for Foreign Associations
- Where to get help on campus
Answers to questions about research security
Who needs to complete research security training?
Agencies requiring personnel documents that are created using SciENcv updated their annual research security training requirements in April, 2026. Currently, Department of Energy (DOE), National Aeronautics and Space Administration (NASA), National Institutes of Health (NIH), National Science Foundation (NSF), and United States Department of Agriculture (USDA) require SciENcv for biographical sketches and current and pending support forms. So, all personnel generating these documents using SciENcv for a proposal, RPPR, or JIT request will need to complete the training.
What research security training do I need to do complete?
PIs, co-investigators, and other key personnel should complete the CITI Research Security Training (Combined Course) to be compliant. This training is completed online and should take 1-2 hours to complete. IMPORTANTLY: Do not use the UC Davis LMS course.
Additionally, every 2 years all key personnel must complete the UC Ethics and Compliance Briefing for Researchers.
Additional resources
The PDS team recently posted an analysis on Changes to Research Security Requirements that includes instructions on how to access the correct CITI training for SciENcv compliance.
Answers to questions about foreign collaborations
Can I still work with international partners?
Yes! Recently, Chancellor May wrote a letter Reaffirming Commitment to International Community at UC Davis. International collaborations are highly valuable to UC Davis research. Recent changes in federal policy mean that there may be additional steps that you need to take when working with global partners.
International collaboration does require researchers and institutions to assess the level of risk for certain types of interactions and determine how those risks can be mitigated. The UC Davis Office of Research provides a useful checklist to help researchers review potential international collaborations before and during a project that receives federal funding. And NIH developed a decision matrix for assessing potential foreign interference for personnel on funded projects.
What types of international activities need to be reported?
Professional international activities should be reported to both the university and the agency to which you're submitting a proposal. Examples of foreign activities that need to be reported include, but are not limited to, funding from international organizations, courtesy appointments at foreign institutions, consulting activities, unique access to data hosted overseas, and hosting scholars who are paid by foreign entities. Federal agencies vary in the exact manner of reporting of international activities, but they often require disclosing international professional interactions whether funded or not. When in doubt, follow the UC Davis Office of Research Foreign Activity guidance.
How do I disclose international activities?
You can report outside and international activities to the university through UC Davis Outside Activities Reporting System (OATS). For more information about what should be reported, read the UC Davis Office of Research discussion of Foreign Activity and reporting in OATS.
Where do I report my relationships with foreign organizations in my grant proposal?
There are many places across proposal documents where relationships with foreign organizations can be disclosed, including biographical sketches, Current and Pending Support, and Facilities and Other Resources documents. Where you report international associations will depend on the nature of your affiliation. This NSF Implementation Guidance for NSPM-33 provides excellent guidance on where in a proposal different types of resources and associations should be reported (both domestic and international).
What is a foreign talent recruitment program?
NSF defines a foreign talent recruitment program as "Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.”
While foreign talent recruitment programs can be permissible, programs tied to prohibited sponsors, involving concealment, data transfer, recruitment obligations, or conflicting work may be malign and require review. The UCOP website describes what constitutes malign foreign talent recruitment. When in doubt, reach out to the Office of Research for assistance.
Is there anything I need to know about foreign travel, even if only for a conference?
When planning international travel, be aware of steps you should take to protect your research data, follow export control laws, and register your trip with UC Davis to manage security and compliance risks. For example, do not travel with unpublished data, sensitive intellectual property, or unnecessary files on your laptop or phone. And do not log into secure institutional servers or access controlled databases while connected to foreign internet networks. Consult UC Davis Export Controls or Global Affairs for more complete information on country risks, equipment, data, restricted-party screening, and travel security.
Is there a list of prohibited organizations?
The U.S. government has determined that the behavior of certain entities warrants restrictions based on national security and other foreign policy interests. Projects funded by the federal government are prohibited for collaborating with these entities. The list of prohibited organizations for all federal agencies is the same. Here is a link to the list on the NSF website.
NIH-Specific Guidance for Foreign Associations
The National Institutes of Health have unique reporting requirements and funding mechanisms for international collaborations.
How do I disclose foreign entities on my NIH proposal?
Disclosure of international affiliations to NIH will differ depending on the role of the association in your grant proposal.
- If your proposed project has a Foreign Component (definition and examples below), then you will need to complete a Foreign Justification, and upload it in Field 12 Other Attachments in your proposal.
- If an international organization is serving as a subaward on your proposal, then you will also need to use the PF5 mechanism unless instructed otherwise.
What is considered a Foreign Component?
NIH considers a foreign component to be "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.”
Below are examples from NIH of what may and may not be considered a foreign component.
May Be a Foreign Component | May Not Be a Foreign Component |
| Foreign site recruitment | Foreign travel for consultation |
| Foreign specimen / data collection | A collaborator who moved overseas after the work was completed |
| Use of foreign lab facilities | Foreign vendors providing routine services |
| Work performed by a foreign collaborator | Foreign co-author providing minor editorial feedback |
| Co-authorship |
Even if your project may NOT include a foreign component, it is best to declare the activity in the Foreign Justification upload and explain why it does not meet the definition of a foreign component. The UC Davis Proposal Development Services team has more guidance on NIH Foreign Justifications and Foreign Components (includes links to templates).
When do I use a PF5 funding mechanism?
If the foreign entity will serve as a subaward of your proposal, then you will need to use the PF5 funding mechanism. NIH will begin requiring the PF5 mechanism for all applications due on or after September 25, 2026. Read the August 28, 2026, NIH announcement regarding this new requirement here.
The UC Davis Proposal Development Services team has detailed information on using the PF5 mechanism, for both UC Davis investigators and their foreign collaborators.
Still have questions?
Agency rules and co-authorship guidance can be inconsistent. For additional help, contact Proposal Development Services, Sponsored Programs, the Office of Research [Denise Ehlen], or Export Control before deadlines. UC Davis investigators can also view slides from the August 28, 2026 Team Research Forum on Foreign Components and Research Security.