Welcome to the external international engagements compliance page.
This page is designed to help faculty comply with the University’s Policy on External International Engagements (Policy) and the international engagement approval process.
To the right, you will find a link to our intake form. Please complete one form for each international engagement.
Below are some FAQs about the approval process, which include roles and responsibilities and the rationale behind the Policy.
International Engagement Approval Process FAQs
This Policy has been implemented in response to concerns raised by the U.S. federal government related to national and research security. An overview of those concerns and the evolving disclosure requirements is located here.
This Policy has been implemented in order to provide a process for the university to prospectively be aware of international activities and for the university to be able to provide faculty with guidance and information as to what disclosures they may need to make to the federal government.
All international engagements will require approval. The only exception is any engagement undertaken directly on behalf of Northeastern in the scope of your employment with the university, such as teaching a class abroad as part of NU-In.
No, you do not need to seek approval to attend an international conference. Please remember that all other university policies related to travel will apply, including the Policy Requiring the Registration of University Travel and the Policy on Clean Computers and Mobile Devices for Travel to Destinations with Heightened Cyber Security Risk.
If the travel is being funded by an external organization, it is prudent to screen the entities and/or individuals funding your travel to ensure they do not appear on any government-wide restricted parties lists. Please contact either your college dean’s office and ask them to perform a screening on your behalf or please contact Research Compliance: researchcompliance@Northeastern.edu.
No, you will not need to see approval through this process for such a short-term visit. However, you will need to screen the entities or individuals funding your travel to ensure they do not appear on any government-wide restricted parties lists. Please contact either your college dean’s office and ask them to perform a screening on your behalf or please contact Research Compliance: researchcompliance@Northeastern.edu.
However if you are presented with an honorary appointment during your visit, you should reach out to firstname.lastname@example.org to discuss if any disclosures need to be made to federal agencies funding your work (either directly or through a subcontract/subaward).
If you will travel please remember that all other university policies related to travel will apply, including the Policy Requiring the Registration of University Travel and the Policy on Clean Computers and Mobile Devices for Travel to Destinations with Heightened Cyber Security Risk.
Yes, we recommend that you also provide the company with a copy of the University’s recommended Consulting Agreement Addendum. It will make it clear to the company that your primary employment and obligations lie with Northeastern and explains how intellectual property rights may be assigned. Many universities offer a similar addendum to their faculty. Asking to include this addendum is consistent with industry practice and most companies will accept it without additional discussion.
Overall, the process should take between 3-10 business days if no translation is required for review of related documents. The timeline for review will be flexible depending on the type of proposed engagement, the risks associated with the engagement and the need to review any contract documents associated with the engagement, including time to translate the materials.
The steps of the process break down as follows:
- Upon receipt of the intake form, Research Compliance reviews the form and related materials and puts together an initial assessment and recommendation within 1-2 days.
- Non-research related engagements, as defined in the Policy, will be sent to the college dean’s designee for final review. Their review and assessment should take 3-5 days.
- Research related engagements, as defined in the Policy, will be sent to the Office of the Provost, Vice Provost for Research Administration. The review and assessment should take 5-8 days, depending on the complexity of the faculty’s funding portfolio, as well as the need to translate any additional documents.
Research Compliance is asking for enough information to help us efficiently assess each case. We will need to understand, at a minimum, the nature of the engagement, any remuneration proposed or received, the duration, the parties and locations involved, and any accompanying documentation.
All the questions on the intake form are required to be answered by you. If you are attaching a contract that will address items like remuneration or duration, you may simply state “see attached”.
The following offices are involved in the process (goes in order through the process):
- Research Compliance: manages the intake and initial assessment process. Research Compliance will make recommendations but does not make decisions on whether or not the engagement is approved.
- Office of General Counsel (OGC): if there is a contract attached to the intake form, OGC will assess the terms and conditions to address potential risks to the university (such as a potential obligation to accept graduate students from specific institutions). OGC provides information, guidance, assesses potential risks, and makes recommendations, but does not make decisions on whether or not the engagement is approved.
- College Dean or Designee: receives Research Compliance’s assessment and recommendation. They will make a decision as to if the engagement is approved for non-research matters.
- Vice Provost for Research Administration: receives Research Compliance’s assessment and recommendation. They will make a decision as to if the engagement is approved for research matters.
- Provost: involved in matters where the initial decision is being appealed by the faculty member. They will render a final decision.
Please provide as much information as you are able to. We know that some information may not be available at the time you seek guidance, but do your best to answer the intake questions, as that will greatly expedite the process.
Research Compliance or another office involved in the process may have follow-up questions about submitted materials. If you answer those questions promptly and thoroughly, that will also support and efficient review.
If you are a faculty member without active research proposals and/or active, externally funded research, you will not need to take any other action.
If you are a faculty member with active research proposals and/or active, externally funded research, you may need to update your biosketch, CV, current and pending or other documentation to support your compliance with applicable federal funding agency policies. Research Compliance will include information on this step in their recommendation and will follow up with you upon acceptance of the engagement to either help you with updating disclosure information, and/or connect you to NU-RES administration, who will help you in communicating to the agencies.
Northeastern will request that a faculty member decline an external engagement in certain circumstances. Such circumstances include, but are not limited to: government-wide prohibitions or restrictions on doing business with the specific entity or individuals; government-wide sanctions related to a specific country (i.e., a proposal to do business in [sanctioned country such as North Korea]); or other circumstances that may pose a legal or reputational risk to Northeastern.
In the unlikely event that a faculty member is asked to decline an engagement, they will be provided with the specific rationale, including citations of any government regulations. In the event that they wish to appeal the outcome, the faculty member is expected to work with Research Compliance to prepare appropriate materials for submission to the Provost, who will make the final decision.
The Addendum is a tool recommended by the University when engaging in external consulting arrangements. It can be used any time you are engaging in an external activity, whether domestic or international. The intention is to make employment and reporting obligations clear to all parties. Several universities offer something similar.
Faculty members who fail to report an international engagement put themselves and the institution at risk. As publicized in recent news coverage, inappropriate international engagements by faculty can result in law enforcement actions taken against individuals, and fines and/or sanctions imposed on universities.
The calculation the university uses to confirm a short-term engagement is: 14 days x 8 hours a day = 112 hours a year during any 12 month period. Even if the pending international engagement is for less than 14 days you are welcome to submit inquiries through this portal. We would be happy to provide feedback and guidance on any risks presented.
Last Updated on July 26, 2021