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. 

Minor updates will be 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 federal funding from the PRC, including research grants from the National Natural Science Foundation of China. 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 ODHE if the partnering academic or research institution is located in China. OIA will be responsible for reporting any new or renewed partnerships to the Chancellor.

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.

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.

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.