International Research of Concern (IROC) FAQs
Will international collaborations still be allowed?
Yes. The policy does not prohibit international collaboration generally. However,
international research activities will receive additional scrutiny to ensure compliance
with federal requirements and research security standards.
Will I need to disclose foreign collaborators?
Yes. Researchers must identify key personnel, institutional affiliations, international
collaborators, and research locations as part of proposal submissions and ongoing
project oversight.
What if I add an international collaborator after a project is funded?
The policy requires investigators to report changes in personnel, institutions, and
other project elements that may affect compliance determinations.
If my research changes after funding, what should I do?
Investigators are expected to continuously monitor their work and report significant
changes in study aims, collaborators, institutions, or risk profiles through applicable
institutional procedures.
Are there penalties for non-compliance?
Yes. Failure to comply with policy requirements may result in:
- Suspension or termination of awards
- Revocation of federal funding
- Up to five years of ineligibility for federal life sciences funding
- Additional actions authorized under federal law and regulations