Foreign Scholar Appointments
The UMD Research Security Office (RSO) reviews all appointment requests of non-U.S. researchers for risk factors that an appointment might not further the University’s mission and the U.S. national interest or might pose legal risks to the University or the host faculty member. The UMD appointment process includes a check point for the RSO to “screen” individuals who are neither a Citizen nor Permanent Resident (a.k.a. “Green Card”) of the U.S. to ensure the University is in compliance with any applicable US export laws and, when applicable, to conduct a risk assessment based on provided information and open source research. The RSO must approve the foreign visitor request before the department sends an invitation to the foreign visitor, submits an unpaid or paid appointment to the PHR system, and before OIS applies for a visa. The screening request can only be submitted following completion of a Questionnaire about the visitor which includes the following fields:
- Individual demographic information;
- Current employer information (where applicable);
- Outside sources of funding supporting visit (i.e. salary, grants, scholarships, etc.);
- Anticipated visit dates;
- Scope of work including any research under UMD contracts or grants
The RSO relies on the scope of work input for the risk assessment. For H-1B applicants, the Office of International Affairs relies on this information for the Export Control Attestation. It is essential that this information is provided by the faculty host, who has knowledge and oversight over the visit. Other individuals completing the request on behalf of the Host should maintain a record of the responses provided by the faculty host.
The RSO checks the name of all individuals and the individuals’ foreign employer (if applicable) against a US government database of sanctioned countries, entities, and individuals. The RSO also reviews the Questionnaire responses. The purpose of the screening and Questionnaire is to verify that there are no sanctions or export control licensing requirements applicable to the visit.
In instances when the individual is a citizen of an embargoed, sanctioned, or military end use/end user licensing required country, the individual’s CV is reviewed, including use of available open source material, to identify, for example, any government affiliations or participation in talent programs. When elevated risk factors are identified, the faculty host is notified and may withdraw the invitation request or initiate an escalated risk-assessment with the Research Security Office. This assessment includes completion of a Risk Assessment Form with fields regarding the area of research to be conducted, assessment of potential risks and possible mitigation, as well as an analysis of potential benefits. This Form is reviewed by the RSO. If, after this review, the RSO determines the risks are acceptable and can be mitigated, approval will be provided; however, if the RSO determines the risks remain elevated, an escalation process will begin with the risk assessment of the host and of the RSO provided to the host’s leadership for review, discussion, and possible decision. In the unlikely event that a decision is not agreed to at this time, the decision process will continue to escalate to the highest levels of UMD leadership if the RSO continues to assess the risk is greater than the capability to mitigate.