Offices VPR Home

Foreign Collaborations

UT Health San Antonio Policy

Collaboration with foreign entities must be approved prior to starting research.

Disclose foreign collaborations using ERMS-COI

In some circumstances, the Health Science Center may be required to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in research, collaborate with a foreign company, or share research results with foreign nationals.

Learn more about Export Controls below

National Institutes of Health Policy

The NIH requires recipients of their funding to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.  A foreign component is defined as: The existence of any “significant scientific element or segment of a project” outside of the United States.

Learn more about NIH Foreign Components

Federal Export Control Guidance

The Department of Commerce Export Administration Regulations (EAR) and the Department of State’s International Traffic in Arms Regulations (ITAR) restrict the export of certain technology or technical data, such as military applications or commercial applications that may also have value in a military context, oversees and to foreign nationals working in or visiting the United States. In some circumstances, the Health Science Center may be required to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in research, collaborate with a foreign company, or share research results with foreign nationals. The Treasury Department’s Office of Foreign Assets Control (OFAC) regulates trade embargoes, sanctions, and travel restrictions and restricts exportation of information and research articles to embargoed entities and persons.

These regulations, in place for more than two decades, carry a range of potential penalties, including fines and imprisonment, for individuals who violate them. This page provides guidance to the Health Science Center faculty, students, and staff so that they may recognize when the regulations may apply and when an export or OFAC license may be required in connection with research. In case of questions, contact either Melanie Zuñiga Rapp, Manager, COI & Research Integrity, 2-6838 or zunigam5@uthscsa.edu.

Health Science Center Guidance on U. S. Export Control Regulations (PDF). 
This memo, issued by Dr. Andrea Giuffrida, Vice President for Research, provides an overview of the federal laws and regulations on export controls as they may relate to Health Science Center research Activities.

Export Control Certification Form (PDF)

Export Controls PowerPoint Training (PDF) 
National Security Decision Directive 189 (NSDD 189)

Export Adminstration Regulations (EAR)

International Traffic in Arms Regulations (ITAR)

  • Defense Trade Controls – Reference Library 
    Regulations (ITAR-22 CFR Parts 120-130; ITAR Amendments, Arms Export Control Act (AECA), Defense Trade Security Initiatives (DTSI) 
    Licensing (Country-related, COMSAT, Notices/Initiatives/Statements, Guidelines/Instructions, Licensing forms) 
    Miscellaneous (Notifications and Reports to Congress, remarks by the Assistant Secretary)
  • 22 CFR Section 121.1 
    Title 22 of the Code of Federal Regulations, Foreign Relations; Chapter 1, Department of State, Section 121.1, The U. S. Munitions List (General)

Office of Foreign Assets Control (OFAC)

Regulatory Offices

Other Resources