Plan for International Activities
International activities for even just a few weeks can trigger tax, regulatory, and other operational requirements that can have a significant impact on both individuals and the University. Conditions vary by location and situation.
While all international activities require at least a quick assessment to ensure appropriate support and attention both from New York and the host country, longer-term projects will require a higher level of planning and operational support.
The International Activity Planning Tool is one planning resource.
Columbia departments might first consider partnering with each other when working in the same international locations. In cases where Columbia has limited experience or no presence in a particular country, it might be possible to explore collaboration with other institutions. The International administrative Working Group is one resource to assist in planning and to ensure appropriate review and approvals within the University.
With a Columbia Partner
When possible, working with a partner already operating in the host country can mitigate administrative complications. This is especially true when both partners are Columbia units. When an established partner shares and assists with start-up requirements (such as employing staff, banking, and leasing real estate), the new international activity can save costs and concentrate on the academic, research or service aspects of the project.
Columbia has established a network of global centers that are regionally based and might be appropriate to serve as the hub abroad for a University department's activity.
For additional information visit the Columbia Global Centers website.
With Other Organizations
A partner may be a host-country organization (often, but not always, a university) or a multinational entity with an established presence in the country (including payroll, bank account, office space, and established relationships with local vendors). In some cases, the partner may only provide administrative services for a fee. It is important that the partner be trustworthy and has similar goals.
The partnership arrangement will typically be set out in a written agreement. Depending on the nature of the relationship, this may be a service agreement, a subcontract, or a memorandum of understanding (MOU).
Consult with your Dean’s office or Research Administrator on your department's internal proposal review requirements, which should be met prior to submission to Central Administration.
Submission of Proposals
Applications for sponsored programs, which include proposals for research and service projects, must be submitted to your department's assigned Sponsored Projects Administration (SPA) Project Officer (visit SPA's website for project officers) at least five business days prior to a sponsor’s application deadline. SPA must review the proposal’s budget and other administrative components for compliance with University and sponsor requirements.
The University has formed an International Research Committee to review international programs meeting certain criteria. Each SPA Project Officer will assess proposals to determine if they meet these criteria.
If the sponsored project will involve human subjects, the applicant should consult the Institutional Review Board (IRB) prior to grant application submission to SPA, to determine the appropriate time to submit an IRB protocol for review. The project must be approved by the IRB before the research can be conducted, if awarded by the sponsor. The IRB can assist the applicant in determining the proper steps to take to obtain the approval in a timely manner.
For additional information regarding the Columbia University IRBs, visit the CU IRB website.
For additional details regarding international proposals, review the procedures outlined in The Sponsored Projects Handbook.
Programs are reviewed for their academic value, feasibility, and sustainability. By design, this review occurs early on before administrative details are worked out. Consult with your Dean’s office about unit-based review requirements.
For undergraduate programs, consult the Columbia University Center for Undergraduate Global Engagement. The Center will assist with submitting the course for review to the Faculty Committee on Instruction for Columbia College and the School of General Studies, where appropriate.
Research with Human Subjects
Investigators conducting research with human subjects in foreign countries must be aware of and abide by all applicable Columbia polices related to international activities, as well as research-related requirements of the foreign site. Columbia’s Institutional Review Boards (IRBs) are responsible for the review, approval, and oversight of all research that involves human subjects.
The IRB Standard Operating Procedures, and the International Research/Export Control webpage maintained by the Office of RCT, provide additional information. Due to additional requirements, approval of research to be conducted internationally may take additional time.
IRB review of international research raises additional considerations relating to local laws, institutional commitments and regulations, standards of professional conduct and practice, cultural norms, and local community attitudes (relative to the study site). Physical, social and psychological risks may vary from those in the New York City communities within which the Columbia campuses reside, i.e., from the area “local to” the CUIMC and CU-MS IRBs.
Challenges may be raised when assessing the risks and benefits of research conducted internationally if adequate knowledge of the local setting is not provided. Care must be taken to ensure that the cultural norms of the host country are respected and that the participants will not suffer adverse consequences from participation, such as being subjected to retaliation from local authorities or the local community.
To that end, evaluation of the protocol by a review board local to the study site, consultation with an expert in the respective country, and/or other means to obtain knowledge of the local context is required. If sufficient information about the proposed research site, to satisfy the IRB’s requirement for knowledge of the local context, is not provided in the submission, it will be requested as part of the administrative pre-review.
In general, if local ethics committee approval is required, it should be obtained after review by the CU IRB. If local ethics committee review is conducted before the CU IRB review, the approved consent document(s), explanation of issues raised by the local committee during its review, if available, and approval letter from the local committee should be considered in the CU IRB review.
If CU IRB review occurs before the local ethics committee review, CU approval to commence study procedures would be contingent upon receipt of the approval by the local ethics committee, which should employ standards that are appropriate for Columbia’s Human Research Protection Program (HRPP).
While Columbia encourages international activities, only certain individuals are authorized to enter into legally binding agreements or perform official business transactions on behalf of the University, domestically and internationally.
Agreements for international activities are reviewed by the same University resources that review U.S. based contracts. For example, the authority to enter into and sign agreements for sponsored research is in most cases handled by Sponsored Projects Administration (SPA). Other international academic programs are handled directly by the Office of the Provost with assistance of the Columbia University Center for Undergraduate Global Engagement. Gifts are overseen by the University's Office of Alumni and Development and procurements of goods and services by Columbia Purchasing.
Columbia University departments may establish a university bank account only by first obtaining written approval from the Executive Vice President for Finance or the Treasurer. This condition applies to all University bank accounts, regardless of how the account is named, and whether or not the account uses the Columbia University name or the name of any school, department, center, institute, program, affiliate, or the name of any other entity or person.
For additional information, refer to the Bank Account Policy.
Departmental Authorization Function (DAF)
DAF Administrators should assign appropriate authority for in-country transactions.
DAF Administrators are the only individuals authorized to delegate DAF authority and approve the creation, modification or deletion of DAF authority within their designated units. University DAF authority is assigned for transactions, such as approval of purchase requisitions, invoice payments, payroll transactions, journal entries, and Purchasing Card (P-Card). For certain transactions, DAF authority is based on dollar thresholds that limit spending.
For more information regarding DAF, refer to the Departmental Authorization Function (DAF) Policy.