Form 10 Modification for Faculty Working or Conducting Research Abroad and Engagement with China FAQ
A Message to Cornell University Faculty
From Wendy W. Wolford, Vice Provost for International Affairs, and Emmanuel P. Giannelis, Vice Provost for Research
As you are likely aware, there continues to be increased levels of scrutiny on university-related international activities. Some of these concerns are country-specific but many pertain to research, teaching or engagement in any international location. We have considerable resources and services on campus to help you navigate local regulations abroad. To aid you in this process we have implemented an important change for users of Form 10 (Proposal Approval and Routing Form) for any international research projects that go through the Office of Sponsored Programs (OSP).
Details on the Form 10 Modification:
Form 10 now has a "Foreign Activities" checkbox: if your project involves any work outside of the U.S., check the “Foreign Activities” box, and a new “Click to Add Foreign Activities Addendum” button will appear. Selecting this button will generate a supplemental page with seven questions about the nature of the foreign activities contemplated. If your project includes elements such as...
- Hiring a foreign national or U.S. citizen to work in another country
- Leasing research or office space in another country
- Work in (or with) China or India
- Setting up an institute or center in another country
- Ongoing operations or regular travel (you or your staff or students connected to your project) outside the U.S.
- Transactions with (including travel to) a sanctioned or embargoed country (Cuba, Iran, North Korea, Sudan, Syria, Venezuela)
- Shipments to another country
...your Grant and Contract Officer (GCO) will forward the Form 10 and Foreign Activities Addendum to Global Operations and Export Control Office. They will determine whether additional steps should be taken to ensure that the project is carried out in accordance with all local regulations and as seamlessly as possible. These offices will follow up with the Principal Investigator and provide advice or resources, as applicable, on export controls, hiring and operational practices, health and safety, and financial and legal matters.
If the offices above find any problematic issues related to the project’s international activities, they will be flagged for review and resolution before an award can be accepted.
The revised Form 10 and associated instructions can be found on the Research Services website. The new foreign activities checkbox is located in the compliance section of Form 10. Please discard old versions of Form 10 and use this revised version going forward. Please send any feedback and questions to email@example.com.
Don’t forget that we emailed you last fall with additional requirements, recommendations and resources; those are still available here.
The offices of the vice provost for international affairs and the vice provost for research have also created a more detailed set of guidelines specifically for faculty engaging in and with China. This FAQ is meant to be clear and thorough and provides contact information for offices across campus in case of further questions.