International Collaboration and Engagement

Each School of the University must establish a procedure to review, approve, assess, and monitor their international collaborations. Schools also assess, monitor, and review projects smaller than those UCIPS considers, and informs UCIPS of those dispositions as requested.

HGSE has established its local CIPS (Committee on International Projects and Sites) to provide review and oversight in order to:

• Ensure that faculty proposals are first reviewed and subsequently monitored by those with closely related standards, interests, and concerns;
• Ensure sponsored funding standards, if applicable, are being met, including federal funding requirements for international activities;
• Provide clear standards of review and approval at the school;
• Provide scholarly and practical advice to HGSE Principal Investigators (PIs) and research unit seeking to conduct international activities; and
• Consolidate numerous University and school reviews for international activities that meet the criteria above, such as reviews for Export Control compliance, Restricted Party Screening, OVPR Provostial Review, UCIPS Review, GMAS International Collaboration and Activities approval, International Travel policies, etc.

HGSE-CIPS objectives, scope, standards, and procedures determine if an international project or activity warrants submission to HGSE-CIPS for review. 

CIPS Review is Required when: 

1. The project involves substantial engagement and coordination with non-US organizations, such as a foreign funder or foreign in-country partners who will perform substantive portions of the work, either as subcontractors or vendors, where “substantive” is defined as including any one of the following:
   1. Involving work conducted outside of the US where foreign individuals must be hired, either directly using Harvard Global or another PEO, or indirectly, using a subcontract or vendor agreement with a foreign entity.
   2. Involving a formal subaward where a portion of the work is being performed outside of the US.
   3. Involving work where contractual or informal collaboration with one or more foreign partners, organizations, or funders is required (or a necessary condition) to conduct in-country work, such as being granted permission to enter and observe in certain sites. One primary example would include needing foreign government approval to conduct in-country work, such as human subjects research in-country.
   4. Involving work where confidential information, such as data with certain expectations for terms of use, is being exchanged – either received or given or both.
   5. Involving any work in a Country of Concern.
   6. Any work with international activities which would otherwise necessitate an agreement be put in place between Harvard and the international entity or individual. Some examples include where a project’s work is heavily contingent upon the in-country partners activities in order to execute the project, or where any single partner or entity who serves as a “hub” of an entire network of connections that are essential to the project’s operation and success.
2. The project involves a non-U.S. “presence” for the School, which may mean any of the following:
   1. A resident presence of significant duration by at least one HGSE faculty members, employees, staff members, post-doctoral fellows, or students are assigned and placed for a period of six months or longer;
   2. Establishment of any new international site, where "new international site" refers to both longer term placement of HGSE individuals above and/or real estate, including offices and research space, outside the U.S. that is leased for HGSE use for a period of six months or longer; or
   3. or, in the case of professional outreach activities such as the Programs for Professional Education (PPE), the program or institute will be conducted at a site outside the United States)
3. The project may pose particular international risks for the School, the University, its faculty, students, or staff, such as engagement with a Country of Concern or a currently recognized high-risk geographic area or in-country partners and/or individuals.

For CIPS requests pertaining to activities to be covered by grant funding (internal or external), the CIPS request should be submitted at least ten (10) business days before the grant proposal is due to the funder or before an IRB protocol is filed with CUHS, whichever is sooner. 

For CIPS requests not related to sponsored funding, the CIPS request should be submitted with sufficient time for review and approval (e.g., at least 14 business days) before the international activity can occur.  In no case should international activity which falls under this policy occur prior to the CIPS approval.

To submit a CIPS request, please complete this form and submit it to CIPS at CIPS@gse.harvard.edu

The current committee members are:

• Bertrand Schneider (chair), Assistant Professor of Education
• Vesall Nourani, Assistant Professor of Education
• Liao Cheng, Lecturer on Education
• Tiffany B. Blackman (Staff), Senior Director of Research Administration

The CIPS Workflow document  shows the various stages of review. Standing HGSE CIPS meetings for review of international projects occur periodically throughout the year. They are typically held from 11am-12pm on the 1st Tuesday of the month, and may occur virtually or in-person as needed. However, depending on the nature and volume of requests, the Committee may review issues prior to formal meetings.

The U.S. federal government has a number of controls in place that limit the export of technical data, goods, and commodities to other countries. Certain types of goods and technologies are especially sensitive, particularly those with potential military applications, and certain countries are under economic embargoes that influence both direct exportation and "trans-shipment" through another country.

While most HGSE researchers would not encounter export control issues due to Harvard's fundamental research exemption, a basic knowledge of export controls is essential to HGSE researchers working internationally. Even if it may be inadvertent, non-compliance with the federal regulations covering export controls can have significant consequences not only to the investigator, but to the entire University.

Export control issues or questions should be referred to: Tiffany B. Blackman, Senior Director for Sponsored Projects.

A quick overview of potential issues is provided here. The Harvard School of Public Health has the most user-friendly and comprehensive treatment of export controls, which you can view here.

A Harvard IRB must approve all human subjects research conducted abroad by, in collaboration with, or under the direction of Harvard faculty.  Even unpaid consultations with foreign collaborators who are engaged in human subjects research requires Harvard IRB review if the Harvard researcher expects to be an author on any paper that results from the research or receives any information that would identify a human subject. 

Human subjects inquiries should be referred to HGSE’s assigned IRB Reviewer. 

Harvard’s Global Support Services provides tools and guidance  to help schools, faculty, and staff complete their international projects within the bounds of Harvard policies.

Registration with International SOS is required for all Harvard affiliates—faculty, staff, students, and researchers traveling internationally with Harvard sponsorship, on University business, or on a University-related trip.

There are specific rules relating to travel charged to Federal Awards; please review the Office of Sponsored Programs guidance in addition to the Harvard University Travel Policy (including Appendix G) and the Sponsored Expenditures Guidelines.

When traveling internationally on sponsored funds, ensure:

1. Lowest Economy Airfare booking,
   1. Fly America Act compliance for federal awards: book the lowest rate air fares on U.S. Flag carriers,
      • Open Skies Agreement allows the use of foreign carriers under specific conditions (does not apply to Department of Defense-supported activities),
   2. Purchase airline tickets using the Harvard Travel Portal,
   3. Register with International SOS, and
   4. Ensure compliance with Harvard travel policies and reimbursement, including
      • Harvard’s combined business/personal travel requirements. 

International collaborations are also addressed in Harvard’s Research Security Program. Research Security training is a key part of this program, with the aim of increasing awareness and making sure that risks are recognized, reported, and handled by the right offices. Research Security Training is required for all Harvard faculty engaged in federally funded research and grant proposals.