- A foreign university will pay an investigator directly to participate on a research project as a consultant (this requires approval from the University).
- An academic (non-honorary) title, such as “professor” or “research professor," is conferred at a foreign institution. This requires the approval of the investigator’s Chair and/or Dean. Approval is required whether or not the investigator is compensated.
- Recruitment into a foreign “talents” program (e.g., 1000 Talents Plan). If an investigator is considering, or is contacted by, such a program, s/he should notify his/her Dean and/or the Office of the Provost for guidance.
- Federal legislation has been considered that would bar individuals who have participated in such programs from receiving grant funding from the Department of Defense. There is some concern that this proposed ban could be revived and/or broadened to include other federal granting agencies, such as the Department of Energy.
- An investigator will take an extended absence overseas while employed at the university (i.e., not on sabbatical or other leave). This generally must be approved by the university in advance, and for a limited period of time. Payment from sponsored sources for any such time must be carefully monitored and fully disclosed to, and acknowledged/approved by, the funding agency and UM.
- Export of data/materials to a foreign entity. This may be done with an appropriate Material Transfer Agreement or Data Use Agreement/Data Transfer Agreement, subject to the export control rules of EAR (Export Administration Regulations; Bureau of Industry and Security, Dept. of Commerce) and/or ITAR (International Traffic in Arms Regulation; Department of State). If an investigator takes or sends equipment, hardware, software, or related technical data abroad, or shares it with foreign persons (e.g., students) even if it stays in the US, a federal export license may be required prior to export. A principal investigator on a project that is subject to publication and/or personnel restrictions, or who intends to take or send such items abroad, must consult with the Office of Export Control and Compliance.
- An investigator forgets to disclose a financial interest, but self-discloses the violation. While this is a policy violation, it is preferable that it be discovered via self-disclosure rather than via audit by the university (or worse, by a federal agency). If the non-disclosed interest is a conflict of interest with federally (HHS)-sponsored research, HHS policy (and usually, university policy) requires that UM conduct a retrospective review of the research to check for the introduction of bias.