How is "Visitor" defined? What qualifies as a "Visitor" for Export Control review purposes?
- Visitors are individuals that meet all of the following:
- visiting VUMC campus on a short-term basis (typically less than 1 month),
- not requiring visa sponsorship by VUMC,
- not employed by VUMC.
- DISCLAIMER: IVS forms should be submitted for screening regardless of the visitor's nationality (this includes known-U.S. Persons visiting VUMC from abroad). If requested, you may note in your correspondence with the visitor (or their institution/employer) that the purpose of this screening is necessary to comply with U.S. Export Control Regulations.
The survey below is used to assist with the screening analysis and export compliance review. Submit your completed survey no later than 10 business days prior to the arrival of the visitor.
- International Visitor Screening (IVS) form
For record retention, keep all documentation related to the visit for five (5) years past the last date of recorded activity associated with the visitors.
Visitor Preparation Guidance
- Visitors typically receive an official invitation from a VUMC host department that will allow them to be a guest on our campus (or other VUMC-affiliation location) for a specified amount of time and for a specific academic or research purpose.
- **Preferably, this step would be completed prior to extending an invitation, so as not to have to rescind the offer should the request not be approved.**
- While at VUMC, Visitors should maintain an association with their host faculty member and department that will serve as the intellectual home for the Visitor.
- VUMC EC highly recommends that you, as the Host, provide advanced notification to all relevant departments and individuals of the visitor(s) pending presence to ensure the workspace and any potentially export-controlled information/items, etc. are secured appropriately - prior to the visit. Certain situations may require a license from the federal government before a visitor may see a lab, research results, etc.
- Contact VUMC EC for assistance with screening an entity or individual against the Denied Party Lists (DPLs). VUMC EC will provide a copy of the search records to you upon request. You should keep these results with the project file for five (5) years past the last date of activity on the project.
- In preparation for a visitor's arrival to VUMC, you may also need to contact the VUMC International Tax Office (ITO) for assistance.
- ITO will provide an additional form (known as a Business Visitor Questionnaire or "BVQ") for the visitor to complete (if necessary). Please allow sufficient time for processing.
- To view the questionnaire, or for additional information regarding the BVQ process, please contact ITO at itovumc@vumc.org or visit the International Tax page.
Visitor Considerations
When you are expecting a visitor (colleagues, researchers, students, etc.) at your department, office, lab, etc., it is important to take into consideration what the purpose of their travel is, how their travel is being funded/supported, where they will be going while at VUMC, and (if research-related) what data and/or type of technology or information they will have access to during their visit.
Questions to consider (not exhaustive):
- Is the research or any of the associated technology, lab equipment, etc. export-controlled?
- Is the research or any of the associated technology proprietary in nature?
- Is the individual an employee of a foreign owned company, a subsidiary, or US branch of a foreign company?
- Is the country the individual is from either a Tier 1 or 2 Country of Concern or a sanctioned country, etc.?
- Is the individual, entity, or organization they represent listed on any of the denied party lists (DPLs)?
- Will the visitor be given access to laboratories or clinical areas during their visit?