Office of University Compliance and Integrity

Partnerships with China

SB 1 requires the university to develop processes and/or guidance for limiting gifts and donations from China and for evaluating and reporting academic partnerships with Chinese institutions. In alignment with federal guidance, the People’s Republic of China (PRC) includes Hong Kong and Macau, but excludes Taiwan. 

A minor update has been made to the university’s Gift Acceptance policy to reflect SB 1’s prohibition on gifts, donations, and contributions from the PRC. Additionally, faculty will no longer be allowed to accept funding from the PRC government or entities acting on behalf of the PRC government, including but not limited to research grants from the National Natural Science Foundation of China, Hong Kong Research Grants Council, and/or other PRC government/province sponsors. In addition, Ohio State’s Enterprise for Research, Innovation and Knowledge (ERIK) generally does not recommend approval for researchers to be listed as unfunded study team members, collaborators, or participants on  grants from the PRC unless the researcher, in conjunction with approval from their college leadership, can clearly demonstrate a direct benefit to the university and address any compliance concerns.

Under SB 1, there is an exemption for philanthropic and unrestricted grants as well as tuition from Chinese citizens from the prohibition. Screening processes are already in place to determine if a donation or gift is from the PRC government. 

Academic partnerships have been defined internally as a formal agreement between Ohio State and an academic or research institution located in China. Of the types of agreements listed by Office of International Affairs (OIA), the workgroup determined that any new or renewed Memorandum of Agreement, Memorandum of Understanding, International Cooperative Graduate Degree Agreement, Service Agreement, Affiliation Agreement, and Student Exchange Agreement must be reported to the Chancellor of the Ohio Department of Higher Education (ODHE) if the partnering academic or research institution is located in China. 

Additionally, the ERIK Innovation and Commercialization Office has formal agreements that meet this definition, which include License Agreements, Inter-institutional Agreements, Confidential Disclosure Agreements, Material Transfer Agreements, and Data Use Agreements with academic and research institutions in China. Finally, if a PRC research grant with unfunded Ohio State researchers is ultimately approved by the university, it may meet the definition of an academic partnership and is also reportable to ODHE.  The Office of University Compliance and Integrity (OUCI) will be responsible for reporting any new or renewed partnerships to the Chancellor and will follow the process outlined below.

  1. Within seven days of establishing or renewing a partnership, the impacted unit will email researchintegrity@osu.edu: a copy of the partnership agreement or similar document providing the terms of the partnership if an agreement is not available; statement showing leadership review and support  of the partnership and; documentation of any compliance and/or legal review of the new or renewed partnership. 
  2. ERIK Research Integrity will immediately forward the copy and statement to OUCI, the Office of Government Affairs and the Office of Legal Affairs for their final approval. 
  3. Within 30 days from the date of the signed agreement, OUCI will email the partnership agreement to ODHE and send a copy of the email to the impacted unit and ERIK Research Integrity. 

The university is also ensuring the effectiveness of current safeguards in place to ensure compliance with SB 1 requirements related to conflicts of interest/commitment, export controls, visiting scholar agreements and foreign visitor processes.

Frequently Asked Questions

Will student or scholar financial support through the PRC be impacted by SB 1?

Ohio State can still accept payment for instructional fees, general fees, special fees, cost of instruction, or educational expenses from Chinese citizens under SB 1.

For students/scholars who have received scholarship funds directly to their personal account they may continue to pay tuition and fees at Ohio State, and other valid academic purposes, using these funds.  Ohio State is prohibited from accepting payments from the PRC and the university cannot accept and apply these to the student/scholar account balance.  This includes China Scholarship Council (CSC) funding.

Can I be reimbursed for travel or other expenses incurred while performing scholarly work, attending conferences or professional service in the PRC?

Staff and faculty are permitted to travel to China for academic and scholarly purposes as part of programming supported by the PRC at an academic institution in China. Faculty and staff can continue to directly receive travel reimbursements, conference fee waivers, honorariums and other covered expenses from Chinese institutions. Faculty should update any applicable federal disclosure and support forms as necessary as well as the Ohio State Disclosure Form. If there is a contract involved with the visit, then the University employee should request pre-approval using the Outside Activity Approval Form and only proceed if the activity is approved.

All researchers are encouraged to use Ohio State’s International Risk Assessment Tool to request a review of potential risk associated with foreign institutions prior to engagement. The Office of Secure Research reviews those requests and completes restricted party screenings to determine whether the foreign entity appears on any U.S. government lists of restricted or concerning entities. Secure Research will provide feedback to the Ohio State sponsor regarding potential risks and relevant regulations and policies.

Can I receive a PRC grant?

No, Ohio State is not eligible to receive grants directly from the PRC.  If you were to be named as an investigator, collaborator, key personnel expert, etc., on a research grant funded by the PRC, that would not be allowable under SB 1. This includes support from the National Natural Science Foundation of China. In addition, Ohio State’s Enterprise for Research, Innovation and Knowledge (ERIK) generally does not recommend approval for researchers to be listed as unfunded study team members, collaborators, or participants on PRC grants unless the researcher, in conjunction with approval from college leadership, can clearly demonstrate a direct benefit to the university and address any compliance concerns. 

If a waiver to the general prohibition on unfunded PRC grants is sought, the researcher and college Dean and/or Provost/Executive Director for centers/institutes  should email their explanation of benefits to the university and compliance mitigation plan to researchintegrity@osu.edu for review by the Chief Compliance Officer and the Vice President of Research or their designees. 

Will collaboration with a colleague who works at an academic institution in China without a formal agreement, MOU or funding implications be allowable under SB 1?

SB 1 does not prevent collaboration with individuals associated with an academic institution in China.

Faculty can always proactively use the international risk assessment tool for a personalized review of their activity by the Office of Secure Research and follow up guidance depending on the nature of the collaboration.

Information related to federal agency concerns can be found here: https://go.osu.edu/intl_engagement

How will SB 1 impact faculty’s ability to invite Chinese visiting scholars to campus?

All visiting scholars traveling under a J-1 (exchange visitor) visa will be required to sign a uniform “Visiting Scholar Agreement,” as part of the in-take process in the Office of International Affairs at Ohio State and agree to follow all applicable policies at Ohio State. Additional compliance screens may occur, and additional requirements may be announced as SB 1 implementation continues.

For other visa holders, such as H1-B, the process remains the same; the approval process conducted by Ohio State Human Resources, the Office of International Affairs and the U.S. Department of State will determine the guest’s ability to visit Ohio State.