Investigators who conduct research outside the United States may encounter regulations and policies different than those that govern research in the U. S. Regulations may differ in the areas of human subjects, taxation, employment, real estate, licensing, or other matters. Additionally, U.S. export-control laws and regulations may apply to research activities that take place outside the U.S. and that involve the use of technology or the development of certain items (e.g., products, goods, hardware, software, and materials). Because of these differences, Harvard researchers must be aware of their individual responsibilities when conducting research abroad, including the possibility of formal approval by the Provost’s Office.
For guidance on reporting, disclosing, or requesting prior approval for sponsored research that includes a foreign component refer to OVPR’s Guidance for Researchers in Addressing Faculty Disclosure and Intellectual Property, Section 4.c-d. To assist in the determination of whether or not a particular international activity or collaboration rises to the level of a Foreign Component, please reference the “NIH Foreign Component Researcher Decision Guide” accessible from the OVPR Foreign Component Guidance webpage.
Investigators who conduct research outside the United States may encounter regulations and policies different than those that govern research in the U. S. Regulations may differ in the areas of human subjects, taxation, employment, real estate, licensing, or other matters. Additionally, U.S. export-control laws and regulations may apply to research activities that take place outside the U.S. and that involve the use of technology or the development of certain items (e.g., products, goods, hardware, software, and materials). Because of these differences, Harvard researchers must be aware of their individual responsibilities when conducting research abroad, including the possibility of formal approval by the Provost’s Office.
Policy Contacts
Matthew Fox, J.D.
Senior Research Compliance Officer, OVPR
International Research Project Planning Guide
Investigators who conduct research outside the United States may encounter regulations and policies different than those that govern research in the U. S. Regulations may differ in the areas of human subjects, taxation, employment, real estate, licensing, or other matters. Additionally, U.S. export-control laws and regulations may apply to research activities that take place outside the U.S. and that involve the use of technology or the development of certain items (e.g., products, goods, hardware, software, and materials). Because of these differences, Harvard researchers must be aware of their individual responsibilities when conducting research abroad, including the possibility of formal approval by the Provost’s Office.
This resource provides faculty and administrators with clear, simple guideposts for international projects, including the policies, guides and contacts at Harvard to learn more (download PDF here).
Due to the complexities associated with international projects, you should always consult with your local research administrator and/or one of the offices below regarding potential and proposed projects abroad – the earlier, the better.
Harvard’s Global Support Services (www.globalsupport.harvard.edu) is available to provide tools and guidance on international business operations.
Hosting Foreign Visitors
Visitor Participation Agreements
Harvard’s research policies cover all individuals who perform work under the University’s auspices, including visitors. Thus, in addition to the Participation Agreement, there are several forms of Visitor Participation Agreements. For information on who should sign which form, see the PA and VPA Guidance. Once signed, the Visitor PA should be scanned and linked to the visitor’s personnel record in GMAS. If no such record exists (i.e., if the visitor will not receive an appointment with a Harvard ID number and card), you may wish to create one for the limited purpose of archiving the Visitor PA, so that it can be retrieved when needed.
Because visitors may be differently situated with respect to pre-existing obligations that may relate to their research, alternative forms of the Visitor PA, as described and made available for download below, have been designed to accommodate their various needs, depending on the type of organization, if any, from which they are visiting Harvard.
Click on the Visitor type that best describes your visitor for the appropriate form:
TYPES OF VISITORS
From For-Profit Organizations (U.S. and foreign)
For visitors from companies or other for-profit organizations anywhere in the world, you may view and download the “HARVARD UNIVERSITY VISITOR PARTICIPATION AGREEMENT for visitors from for-profit organizations (U.S. and foreign)” by clicking here.
From Foreign Non-Profit Institutions/Unaffiliated Individuals
For visitors from foreign non-profit institutions OR for visitors who are not affiliated with any university, research institution, hospital, company or other organization, i.e., who are self-employed or unemployed, you may view and download the “HARVARD UNIVERSITY VISITOR PARTICIPATION AGREEMENT for visitors from foreign non-profit institutions and for unaffiliated individuals” by clicking here.
From U.S. Non-Profit and Governmental Institutions
For visitors from U.S. non-profit and governmental institutions, except for medical centers affiliated with Harvard Medical School,* you may view and download the “HARVARD UNIVERSITY VISITOR PARTICIPATION AGREEMENT for visitors from U.S. non-profit and governmental institutions OTHER THAN the Harvard-affiliated medical centers” by clicking here.
From Harvard-Affiliated Medical Centers
For visitors from one of the medical centers affiliated with Harvard Medical School, you may view and download the “HARVARD UNIVERSITY VISITOR PARTICIPATION AGREEMENT for visitors from Harvard-Affiliated Medical Centers” by clicking here.
From U.S. Government Agencies/Institutions
For visitors employed by the U.S. Government, you may view and download the “HARVARD UNIVERSITY VISITOR PARTICIPATION AGREEMENT for Visitors employed by the U.S. Government” by clicking clicking here.
RELATED GUIDANCE
Acknowledgement of Risk and Release of Claims
In addition to the VPA, non-Harvard personnel who visit Harvard laboratories where certain hazards (e.g. chemical, radioactive, biological agents or heavy machinery) may be present may also be required by the lab to complete the “Acknowledgement of Risk and Release of Claims” form. Not all visitors who sign a VPA are required to complete this form. Only visitors to labs where certain hazards are present who are NOT:
- Harvard Students
- Harvard Employees
- Employees of one of the 15 teaching hospitals and institutes associated with the Harvard Medical School
Completion of the form confirms that the visitor understands the nature of the risks and indicates that they have health insurance of their own and will release Harvard from any claims in the event they are injured as a result of working in Harvard laboratories.
RELATED RESOURCES
Provostial Review of International Activities
What’s essential: Harvard values the global nature of its community, and reveres its relationships with international researchers and institutions, and continues to actively work to protect longstanding principles of openness in research and collaborative exchange of ideas. Researchers and staff must be aware that certain engagements involving international collaborations and funding require heightened scrutiny, and should be cognizant of the shared obligation to safeguard the integrity of University research, and to protect funds, intellectual property, and sensitive data and information developed by or managed at Harvard.
How to comply: The University has developed criteria outlining specific types of international projects and research that require central review by the Office of the Vice Provost for Research (OVPR), and may also require decanal review, and/or review by additional offices and committees. Additionally, for sponsored research, there are specific project components that must be reviewed at the school level, and recorded in GMAS in the International Collaborations and Activities Approval section. Depending on the scope of work, these international activities may require review by OVPR and other relevant offices. It is important to include as much context and detail as possible when submitting such projects, otherwise the process will be delayed while school-level and central reviewers attempt to collect pertinent information.
Why it’s important: Funders, especially federal sponsors, require that certain activities be disclosed in proposals and other documentation, or directly to a program officer, depending on the activity and timing, and it is imperative grant managers and reviewers have the opportunity to work with researchers to ensure all appropriate information is provided. In a small number of cases, international collaborations and activities, if not managed properly, may result in loss of funding, violation of export control laws, or legal jeopardy to the University and its researchers. Accordingly, the University encourages all researchers and administrators to take steps to ensure that documentation and information submitted to funders is both transparent and in full compliance with relevant policies and regulations.
Resources:
- Provost Criteria for Review (and guidance)
- Sponsored research: International Collaborations and Activities
- Faculty Disclosure Guide
- International Project Planning Guidance
- Export Controls Guidance: Specially Designated National List Screening Process and Monitoring
- Provost Review Guidance on Countries of Concern (CoC)
Committee: Any proposals not submitted to a sponsored programs, IRB, or gifts office may be sent directly to Ara Tahmassian (617-495-9797), Rachel Talentino (617-495-9829), and Shaira Kochubaeva (617-496-5974) before the proposal is filed with potential funders. Certain proposals may require review by the University Committee for Special Review of Sensitive Collaborations.