Office of Research and Economic...

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Office of Research and Economic DevelopmentResearch Administration Meeting

January 28th 2020

AGENDA

Office of Research and Economic DevelopmentResearch Administration Meeting

Welcome and Introductions• Procurement Services

• Export Controls

• Research Management Solutions

• Pre-Award

• Post-Award

• Research Integrity

• Research Information Systems

Project Organizational ChartOffice of Research and Economic DevelopmentResearch Administration Meeting

Welcoming Remarks

• Future Research Administrators Meeting for 2020

• Future meetings will be primarily online• Date(s) to be announced

• Slides will be posted on the Office of Research and Economic Development website after the meeting

Project Organizational ChartOffice of Research and Economic DevelopmentProcurement Services Update

GovQuote University-Wide Rollout Utilization of GovQuote will be mandatory starting on February 28, 2020 If you do not receive an invitation for the GovQuote trainings, please contact Barbara

Cotto Jimenez at [email protected] New process for approving and paying foreign suppliers,please follow the instructions found

at http://finance.fiu.edu/controller/QL_ControllerProceed.html Foreign suppliers are now approved by Procurement Services instead of Tax

Compliance. Payments to foreign suppliers will now be reviewed by Tax Compliance at the voucher

level Please use the new Multi-Level Coaching, Training and Consulting Services ITN

7 Firms selected Moving allowance for new hires vs Lab Moves vs Internal Moves

More information on moving and relocation can be found at http://finance.fiu.edu/purchasing/4contra_employee_moving_guide.html

Working on new catalogs for myFIUmarket Medline Sigma What would you like

mailto:[email protected]

http://finance.fiu.edu/controller/QL_ControllerProceed.html

http://finance.fiu.edu/purchasing/4contra_employee_moving_guide.html


Time Period : 7/1/2019 to 1/16/2020

Details - Non-Conforming Form Processed for Research Related TaskS

No Department NameCount of Offense Sum of Amount to be Paid Description of Goods/Services

1 Biomedical Engineering 1 168.00 Lab supplies1 18,810.78 Mannheimer Foundation Inc

2 College of Arts Science & Educ 1 2,200.00 Contracted work to maintain a remote field experiment in the Bahamas

1 800.00 Respondents for the research study3 Comm Sciences and Disorders 1 914.34 Translation services for research purposes4 Computer Info Sciences 1 97.54 Reagents for experiments

5 Global and Sociocultural Stu 1 1,700.00 Website design for research as part of grant budget

6School of Environment, Arts and Society 1 47,385.00

Accommodations, 300 gallons of fuel, food , boat use + guide for Sawfish/Shark Research

7 Southeast Env Research Ctr 1 12.00

Single Payment Vendor - Purchased ice to keep sample from getting ruined. Out of pocket expenses

8 Tropical Conservation Program 1 22,549.00 Costs for room/board, fuel, boat rental-Conservation Research

9 UGS University Grad School 1 20,773.73 Lead or assist PIs in preparing grant application to NIH

11 115,410.39


The Credit Card Solutions Team is happy to announce FIU’s new partnership with Card Integrity! This company provides a full service, 3rd party expense monitoring solution. Their service will analyze 100% of the University Pcard and Travel & Entertainment Card spend on a monthly basis, incorporating both algorithmic diagnostics and human review with experience in audit and review practices. Card Integrity sets the gold standard in card spend analytics, improving compliance, oversight, and internal controls in university card programs nationwide.

Reporting will include detailed analysis for compliance with the university policies and procedures, including:

They will also provide the university with detailed analytics on performance, patterns, and anomalies, Alert Workbooks, Procurement Workbook, Monthly Summary, Spend by Category, Alerts by Cardholder, and Spend by Cardholder. Reporting will also provide the university with detailed category and supplier reports to strengthen our strategic sourcing.

In Phase II of implementation, we will be providing monthly program overviews tailored to individual department usage to further enhance internal controls and program transparency.

prohibited/non-allowable items potential personal purchases double dipping (Pcard to out of pocket reimbursements) split transactions

weekend transactions


Please review the Supplier or Employee document to determine whether to pay an individual as an employee or an Independent Contractor Found on the Controller’s website

http://finance.fiu.edu/controller/Docs/SupplierEmployee.pdf If there is any question, the individual should be hired as an employee The initial evaluation of whether to pay an individual as a supplier shall be

made by Procurement Services Complex situations may require consultation with the following areas

for a final determination: Tax Compliance, Human Resources, General Counsel

This may delay the supplier registration process All determinations are based upon the actual facts and circumstances of

each case

Supplier or Employee

http://finance.fiu.edu/controller/Docs/SupplierEmployee.pdf


Sponsored Research Exemption vs Sole Source vs BOG Exemption

Per Uniform Guidance Procurement Standards, 2CFR 200.317 - 326 a Sponsored Research Exemption Request is required for one of the following reasons

Noncompetitive purchase specifically approved by sponsor (supplier specifically named in grant/budget) Competition determined inadequate after solicitation with a number of suppliersEmergency PurchasesAttach written justification

If utilizing grant sponsored funds you can not use any of the BOG Exemptions, including FIU’s Sole Source Annual Certification List

Use the Sponsored Research Purchase Exemption RequestUse the Sole Source FormObtain two quotes for purchases under $75,000 Contact Procurement Services to conduct a competitive solicitation for purchases over $75,000

Please contact ORED directly to ensure proper procurement method is followed


Delegated Signature Authority As of March 4, 2019 the Presidents delegate authority is only $1,000,000 for

contracts for the purchase, sale, lease, license or acquisition of commodities, goods, equipment, software and services

Transactions between $500,000 and less than a $1m are reported on a quarterly basis to the BOT Finance Committee

Transactions between $1m and less that $3m require BOT Finance Committee approval

Transactions $3m and over require BOT approval This does not include research contracts

Procurement Services Executive Director’s signature authority is increasing from $100,000 to $500,000, this includes PO approval POs over $500,000 without a contract with an authorized signature will

require the Provost or CFO’s email approval Barbara Manzano and Howard Holness is obtaining delegated authority

to approve POs from $500,000 to $1m


EH&S Compliance for Surplus Items In order to comply with Surplus Property and EH&S regulations and to reduce safety hazards,

the following corrective actions is needed for assets sent to surplus property or transferred between departments Surplus items can not be moved to hallways Surplus items can not be sent to Surplus Property from lab locations with known hazardous

materials and equipment without the proper EH&S clearance form Campus services will not pick up items abandoned on hallways or items from Labs

locations with known hazardous materials and equipment without the proper EH&S clearance form

Assets moved to new locations need to have department property custodial approval Property Control (AM) will cross-reference the pickup location of assets disclosed on

“surplus and transfer forms” with EH&S list of Labs locations with known hazardous materials/equipment and ensure that proper EH&S clearance form is provided

Future actions EH&S, in coordination with Asset Management, Campus Services and Surplus Property, will

increase awareness about the current situation University wide EH&S will continue monitoring safety hazards related with the storage of items on

unauthorized locations


Increase surplus revenue by posting more items online via GovDeals

Reduction of waste with a savings of $ 12,953.00 in only 7 months

Introduction of Surplus Property Teams to increase re-purposing of

assets within departments and from surplus warehouse

Introduction of Receiving Team for paperless delivery notification in real-

time

Export Control Briefing for Research Administration

Florida International University

Fischer & Associates January 28, 2020

Office of Research and Economic DevelopmentExport Controls

1. Summary of federal regulatory objectives

• Federal export control regulations govern:o What scientific instruments, technologies, software and biological materials can be accessed

and/or used by foreign nationals1 studying, visiting, or working in the U.S.o What items can be transferred abroad to certain destinations based on the type of item, end use,

end user and country destinationo Treasury Department’s OFAC regulations govern travel, academic, research and business

transactions with certain sanctioned countries2

• Government agencies restrict engagement (including but not limited to export transactions) with certain individuals and entities identified in the Federal Register, thereby requiring restricted party screening

• “Foreign Influence” security concern: Procurement from Huawei Technologies and other entities listed on NDAA; exposure to sensitive information/IP through China-related research and academic exchange programs; Conflicts reporting; visa screening; IT barriers; IP/Spin-off partners

1 For export control purposes, foreign nationals are defined as those individuals who are not U.S. citizens, Permanent Residents (“Green Card” holders) or recipients of Political Asylum status. Hence, foreign nationals are individuals with temporary immigrant visa status including but not limited to H1-B, J-1, F, and B-visa beneficiaries.2 In addition to the Departments of State, Commerce and Treasury, other agencies also regulate exports, for example Nuclear Regulatory Commission, NASA, and USDA.

14 Office of Research and Economic Development

Export Controls

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2. Current enforcement environment

• Increased focus on Higher Ed and non-academic scientific research institutions

o FIU’s Facility Clearance and NISPOM

o DFARS 7012 Data Security “CUI” requirements• Penalties include federal debarment, monetary penalties, criminal prosecution, revocation of

export privileges: Enforced at institutional and/or individual levels

• Investigations re Chinese scholars and collaborative programs/technology transfer (FBI, NIH,

DOE)


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3. Compliance management among Higher Educational InstitutionsCurrent standard:

• Dedicated export control oversight function (Export Officer/Empowered Official)o Ability to effectively interface with key operational functions and all

academic/research/business areas triggering export requirements

o Campus-wide recognition as the “go-to” resource for export control matters

o Authority to suspend transactions potentially in violation of the regulations


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4. Key message to faculty and staffCompliance processes are intended to be:

• Proportionate to risks; supportive of (not impeding) research, academic and business activities• Sufficiently flexible to accommodate FIU’s increased number of federally-funded, export restricted

programs, data security requirements and international initiatives.


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5. Key Requirements

• Export Commitment Statement that reflects FIU’s compliance program (new webpage)

• Recognizable export oversight function with sufficient visibility into export transactions

• Strategy for accepting export restricted programs; DFARS 7012 data security requirements

• Restricted Party Screening as a well-defined, distributed function

• Classification of international transfers: pre-shipment license determination

• Export licensing of commodities (as needed) + Shipping/Recordkeeping• Identification of ITAR Items and Dual Use Technology through Procurement process (potential

foreign national access restrictions resulting from ITAR release and/or deemed exports)


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5. Key Requirements (continued)

• Technology Control Plans (TCPs) and foreign national licenses (as needed)

• EH & S compliance overlap: BSL-contained materials and risk-sensitive instruments/materials

• I-129B Export Certification (H-1/O-1); J-1/F-1 export-sensitive research assignments

• NDAs and MTAs: advance notification requirements to identify controlled inputs

• International travel with Laptops (stored export controlled data) and tools of trade

• International Visiting Delegation screening protocol

• External party use of laboratories/proprietary service contracts

• Training and Notification Procedure for suspected violations


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6. Sample forms that we use


Resources for Partners

Sponsored Research Administrators

Research Administrators are key partners in export compliance! Often Research Administrators are the first to identify potential export control concerns, and Administrators are instrumental in working with sponsors and other parties to avoid export controls on research.

To help our Research Administration partners, we have pulled together links to specific information, forms, and guidance documents targeted to the interests of Research Administrators. Please do not hesitate to contact Export Control for assistance and help with questions.

Information on Specific Activities•Perform Research•Collaborate with an International Colleague or Entity•Ship Something Abroad•Receive or Use Something Controlled•Travel Abroad

Export Information by Topic

•Export Basics•Export Activities•Restricted Parties•Embargoes and Sanctioned Countries•Controlled Equipment, Items, and Materials•Controlled Information and Software•Classification and Jurisdiction•Foreign Influence

Useful Forms•ePRAF questionnaire- used to create the electronic Proposal Routing Approval Form within Peoplesoft•Export Control Checklist- used for all initial awards to flag potential export control concerns•Agreement Request Form- used for all non-monetary agreements such as NDAs, CDAs (not MTAs)•MTA Request Form- used for all MTA requests

Guidance Documents

•[Insert helpful guidance documents as available]

Helpful FAQ’s



International Shipping FormPlease Read: The purpose of this International Shipping Form is to identify any international shipment, which requires prior export control authorization from U.S. Government export authorities.

In general, this form is only required if you are shipping specialized instruments, software, materials, as well as proprietary technical data which is not intended for the public domain. (Examples of specialized items are those designed to accomplish a particular scientific purpose including but not limited to analytical, detecting, imaging, measuring, positioning, or other specialized scientific purpose; radiation safety equipment; any item radiation-hardened; chemicals and specially formulated raw materials; specialized software to drive this type of equipment; proprietary (non-published) source code; and biological materials (including Biosafety Level 2+ materials).

Ordinary laboratory consumables (standard lab supplies) and standard office supplies, including business computers, can be ignored.

Please complete the form as fully as possible. Questions should be directed to:

Requestor’s Name: Request Date: Department:

Sponsored Project Code (if applicable): Recipient name:

Recipient Address:

Has the consignee(s) been screened through Visual Compliance? Item

description:

Please check to indicate any of the following included in the intended

shipment: Laboratory instruments

Tools (of a specialized mechanical nature)

Samples/prototypes (including fabricated materials) Biological

materials or specimens

Specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.)

Software programs containing or constituting specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)

Technical data related to any of the foregoing Does the shipment contain Hazardous

Materials?

Please identify (if known) the export control classification of the items in this shipment (Provide ECCN or USML Category, or respond “Unknown”):

No

What is the recipient’s intended end use of the items?

Is the export intended as a permanent export or will the item be returned? Will

the recipient re-export the items to a different final recipient? Yes What

is the estimated value of the shipment?Unknown

TRAVEL QUESTIONNAIRE

Introduction

The following questions are intended to identify export control concerns associated with international travel. Please respond Y or N to the following questions. In the event that a particular travel plan appears to trigger an export control concern, of our export control administrators will contact you to make sure that all necessary compliance steps have been taken in advance of your departure date.

Questionnaire

1.Will you be transporting (either through carry-on luggage or checked bags) laboratory instruments, tools, samples, raw materials, or prototypes?

2.Will you be traveling with a portable electronic device containing proprietary export controlled data, or data which is associated with an export-restricted research project or instrument that you have been or are working on currently (even if such data has nothing to do with the purpose of your immediate travel)?

3.Will you be transporting any device that incorporates specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.) or software programs containing or constituting specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)?

4.Will you be providing any specific training or technical assistance to another individual, entity, or governmental institution (or representatives) beyond scientific collaboration in fundamental research?

5.Will your travel plans involve Iran, Cuba, or Syria?

Questionnaire Key

[Note to Export Administrator]: If the Traveler responds to any of the foregoing TRAVEL QUESTIONNAIRE questions with a “Yes,” the following queries in red can be posed in a follow-up phone call, to better understand the scope of the export control implication.]

1.Will you be transporting (either through carry-on luggage or checked bags) laboratory instruments, tools, samples, raw materials, or prototypes?If yes, ask the following:

a. Please list the itemsb. Are you aware of any export controls that apply to the items, including EAR or ITAR classification?c. What will the items be used for?d. Will the items return with you?

i. If not, where will they remain?ii. Who will have custody of the items?

e. Will you be providing any items (temporarily or permanently) to another individual or collaborating institution? If so:

i. Please list the itemsii. Will the transfer be temporary or permanent?iii. Who will be the recipient (institution and individual)?

2.Will you be traveling with a portable electronic device containing proprietary export controlled data, or data which is associated with an export-restricted research project or instrument that you have been or are working on currently (even if such data has nothing to do with the purpose of your immediate travel)?If yes, ask the following:

a. Please describe the datab. Please describe the project or instrument which the data is associated withc. What will the data be used for?d. Do you intend to share the data during your travel?e. If so, with whom?

3.Will you be transporting any device that incorporates specialized scientific software (not including typical operational software such as Microsoft Office, Adobe, etc.) or software programs containing or constituting specialized cryptographic functionality (not including routine commercial laptop cryptographic protection)? If yes, ask the following:

a. Please list the software here by name and version.i. Please describe what the software is used for.ii. Will the software be used by or transferred to anyone else during your travel?iii. If so, to whom?

4.Will you be providing any specific training or technical assistance to another individual, entity, or governmental institution (or representatives) beyond scientific collaboration in fundamental research? If yes, ask the following:

a. Please describe the scope and subject of the training.b. Who will receive the training?

5.Will your travel plans involve Iran, Cuba, or Syria? If yes, ask the following:a. Please describe the scope of your activities related to this countryb. Please list all contacts and institutional affiliations in the country

Visa Applicant/Beneficiary Deemed Export Questionnaire for Sponsored & Non-Sponsored ActivitiesImportant Background: Please read

The United States Citizenship and Immigration Service requires that an employer, when filing an H-1B, H- 1B1, L-1 or O-1 petition, certify that (i) it has reviewed the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce and the International Traffic in Arms Regulations (ITAR) administered by the U.S. Department of State, and (ii) it has determined whether or not a license (prior authorization) is required from either of these Government agencies to allow foreign national employee access to export controlled items or technology (laboratory equipment/research instruments, materials, software or technology/technical data) controlled under the EAR or ITAR. (Please refer to Questions 1 -5 below following the Instructions.)

In the case of J-1 Visa Exchange Students and Visiting Scholars, FIU is also required to determine whether the J-1 visa candidate will be exposed to export control items or technology. (Please refer to Questions 1-5 below following the Instructions.)

The transfer or release to a foreign national of such controlled items by any means is “deemed” to be an export tothe foreign national’s country of citizenship or permanent residence, potentially requiring a U.S export licenseunless a particular authorized license exemption applies.

Instructions: The questionnaire must be answered by the sponsoring faculty member who is directly knowledgeable of the visa applicant/beneficiary's activities, and not by someone acting on behalf of the sponsor who is not directly knowledgably. Please Complete the Information as Possible.

If you do not have the information necessary to complete this Questionnaire and Certification, please contact Mark Green, University Compliance, 305-348-0002 (or by email at [email protected]) to complete the processing of this certification questionnaire. University Compliance - Export Control will work with you to further determine whether the activities intended for the visa applicant require prior export control authorization from a governing U.S. agency or require a Technology Control Plan to temporarily or permanently restrict access by the beneficiary or visa applicant, but only to what is export controlled.

Applicant/Beneficiary:

First Last

/

MM DD

Country of Citizenship:

/

YYYY

Date of Birth:

Current Visa Type (If Applicable):

Name and address of applicants' home country affiliated entity and funding source if different from the affiliated entity (J-1 Applicants only):

Requested Visa Type:

Position to be Held:

First Last

Faculty/Sponsor Information:

Title:

Department:

-

###

-

### ####

Phone:

Email:

1. Will the visa applicant be working in one of the following areas: biomedical sciences, computer sciences, space or space launch sciences, or any engineering or scientific discipline? Engineering or scientific disciplines may include but are not limited to the following: Chemical, Electrical, Semiconductor, Materials Science, Physics, Mechanical, Geophysical, Geospatial, Marine, Meteorological, Astronomy, Nuclear, Artificial Intelligence or Robotics. If so, please provide brief explanation of work assignment(s).

Check one:NO: the assignment will not involve, expose or potentially expose the applicant to any scientific or engineering discipline identified above, or if involved in such scientific discipline, will be acting in a teaching-only capacity, with no research involvement.Please sign and date this form below and click the SEND button, which will route the Form to University Compliance – Export Control for review.

YES: the assignment will involve, expose or potentially expose the beneficiary to a scientific or engineering discipline (including but not limited to one or more of those listed above). You are required to check all the applicable boxes for Questions 2- 5. Where the answer is Yes or Not Sure, this will alert us to a potential deemed export situation that we will promptly review with you and resolve. [Note: any technology that has been invented by FIU or another entity as the result of fundamental research (basic and applied research without conducted without sponsor-mandated publication and/or citizenship restriction) and is the subject of a potential or actual research publication, conference presentation, course curriculum, or patent publication (i.e. already in the public domain) is exempt from deemed export access restrictions.] Upon completion of the Form, please sign and date at the bottom, and then click the SEND button.

2.Will the visa beneficiary/applicant perform any activity under a sponsored research agreement (e.g. grant, CRADA, contract, recharge service agreement, Capstone, etc.) that restricts or prohibits the participation of foreign nationals, i.e. there are no restrictive clauses pertaining to foreign nationals or non U.S. persons participating in the research.

YES NO NOT SURE

3.Will the visa beneficiary/applicant perform any activity under a sponsored research agreement (e.g. grant, CRADA, contract, recharge service agreement, Capstone, etc.) that restricts or prohibits the research team’s right to publish any of the data or research results, except for the sponsor’s right to review and exclude from intended publication proprietary or confidential data that, under the terms of the Agreement, is exempt from publication.

YES NO NOT SURE

4.Will the visa beneficiary/applicant be provided access to any of the following (whether or not actually required for his/her work assignment and whether through hard or soft copy):

•Technical data or information that has been stamped or otherwise designated by the sponsor or collaborating institution as being “export controlled”;

YES NO NOT SURE

•Sponsor or third-party proprietary or confidential information, materials, or software that is the subject of a Non-Disclosure Agreement (NDA) or equivalent confidentiality agreement;

YES NO NOT SURE

•Third party, proprietary technology for the development of cryptography, or source code containing cryptographic functionality;

YES NO NOT SURE

•Third party, proprietary information pertaining to the “use” or “development” or “production” of instruments, materials, software or scientific processes (technology): for purposes of this Question:

-“use” means that the foreign national would be performing one or more of the following types of activities pertaining to a controlled item beyond merely operating the item for its intended purpose: installation, maintenance, repair, and overhaul/refurbishing – based on a proprietary and controlled (non-public domain) manufacturer manual or other equivalent documentation

-“development” means technology pertaining to a sponsor’s proprietary R & D and development project - - i.e. not intended for publication: design research, design analysis, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into a product, or configuration design

-“production” means technology pertaining to sponsor-proprietary product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance.

YES NO NOT SURE

5. In performing the activity under the visa, will the visa beneficiary/applicant be provided access to research equipment, instruments, materials, software, and/or technical data in any form (e.g. blue print, sketches, specifications, documented technology, vendor operational manual/instructions, data results) that is governed under the ITAR.

ITAR covers any item (equipment, instruments, materials, software, and/or technical data as exemplified above) specially designed, developed or modified for military, defense or space applications) and may include such items whether procured from a vendor, or otherwise received by a research sponsor or collaborating research institution. For a list of the high level ITAR categories that identify such defense, military and space items please use this link. For purposes of this certification, “access” means any visual or physical access to the item, regardless of whether such access is actually required by the visa applicant to perform his/her work assignment.

YES NO NOT SURE

In the event that the above-indicated information changes with respect to the visa applicant/beneficiary's activities, please notify University Compliance - Export Control on a timely basis.

Host/Supervising Faculty Member or Business Department Supervisor Signature:

Clear

Continue

Project Organizational ChartOffice of Research and Economic DevelopmentResearch Management Solutions

Cailin Diberto(804)-241-4429

[email protected]

Uber Health for Transporting Research Participants

Project Organizational ChartOffice of Research and Economic DevelopmentPre-Award

Reminder of Conflict of Interest Requirements

Annual Report of Outside Activity/Conflict of Interest (COI):

• As per FIU policy 2370.005, on an annual basis, all FIU employees are required to disclose their outside activities and financial interests on the HR portal available at https://hrapps.fiu.edu/conflict_of_interest/Default.aspx. Please note that any foreign activities or financial interests must be included in said disclosure if applicable.

• The Investigator must either certify that the Investigator has no Significant Financial Interests or disclose the Significant Financial Interests by September 30.

• Any new Significant Financial Interest or material change must be disclosed within thirty days of discovering or acquiring the new Significant Financial Interest.

At proposal stage:

• Any COI must be disclosed at proposal stage by all key personnel via the ePRAF form.

• Please note that the following questions from the ePRAF assist personnel with the process:

https://hrapps.fiu.edu/conflict_of_interest/Default.aspx



At proposal stage continued:

• 21. Have all Investigators on this proposal completed their outside activities and financial interests disclosure form via the HR electronic disclosure portal pursuant to the FIU Conflict of Interest in Research policy #2370.005? An 'Investigator' includes all Key Personnel listed on this ePRAF and anyone responsible for the design, conduct or reporting of the proposed research. Disclosure is required by September 30th annually and also within 30 days of acquiring any new Significant Financial Interest. Please see the FIU Conflict of Interest in Research policy #2370.005 for more details.

• 22. Is there any conflict of interest in relation to this proposed project for any Investigator who will be working on this project? If 'Yes', ORED may require further information and if the project is awarded, a management plan may be required to manage, reduce or eliminate the conflict of interest. Any new Significant Financial Interest or material change must be disclosed within thirty days of discovering or acquiring the new Significant Financial Interest.


Reminder of Conflict of Interest RequirementsAt proposal stage continued:

• 23. If this proposal is being submitted to the PHS, NSF or to a sponsor subject to the PHS Financial Conflict of Interest (FCOI) regulations (list available at http://research.fiu.edu/coi/disclosure/#list) each Investigator must complete the Investigator Report of Financial Interests in Research form on the ORED website at [http://research.fiu.edu/forms/proposal-preparation/financialInterest.pdf] and submit those forms as attachments to this ePRAF at proposal stage. You are reminded that, pursuant to Conflict of Interest in Research policy #2370.005, you must report any newly acquired Significant Financial Interest within 30 days. Has the Investigator Report of Financial Interests in Research form been uploaded as an attachment for each investigator?

• Please note that this required for flow through projects as well (i.e. subaward from other institutions to FIU using PHS, NSF or other sponsors subject to the PHS FCOI regulations.

Subawardees:

• Subawardees are required to make similar certifications at proposal stage via the SubwardeeCommitment Form available at http://research.fiu.edu/documents/forms/proposal-preparation/subrecipientCommitmentForm.pdf

http://research.fiu.edu/documents/forms/proposal-preparation/subrecipientCommitmentForm.pdf


Reminder of Conflict of Interest RequirementsSubawardees continued:

•



Key Points:

• Annual disclosure is required via HR portal by September 30th annually and also within 30 days of acquiring any new Significant Financial Interest.

• All COI questions must be answered on the ePRAF at proposal stage.

• PHS and NSF Investigator Report of Financial Interests in Research Form must be completed at proposal stage and uploaded into the ePRAF and reaffirmed at award stage.

• Subawardee Commitment Forms must be provided for all subawardees at proposal stage.

• Award funds will not be released until all required documents are provided any conflicts are addressed.


Anti-Trafficking Policy

New Policy:

• Anti-Trafficking Policy went into effect on August 8, 2019.

• Policy is available at https://policies.fiu.edu/policy/876.

• This policy applies to any portion of a federally funded contract or subcontract if the estimated value of the supplies acquired or services required to be performed outside the United States exceeds $500,000 ("a Qualifying Program").

• For a Qualifying Program, it is required by federal law that an anti-Trafficking compliance plan be in place for the University and any University contractors or subawardees.

• For a Qualifying Program, the Principal Investigator of the subject project must contact ORED who will work with Human Resources and the Principal Investigator and any other University unit, as needed, to create a tailored compliance plan specific to the Qualifying Program.

• If requested, a copy of the project specific plan shall be provided to the federal sponsor officer. Qualifying Program specific compliance plans must be appropriate to the size and complexity of the federally funded project and to the nature and scope of the activities to be performed.

https://policies.fiu.edu/policy/876


NSF Issuance of a Revised Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 20-1)

New PAPPG:

• New Proposal and Award Policies and Procedures Guide (PAPPG) will become effective on 6/1/20.

• Key changes at this time that are of interest to proposal submitters include:

• The use of an NSF-approved format in submission of the biographical sketch and current and pending support documents, including the use of SciENcv, once the PAPPG (NSF 20-1) becomes effective;

• Guidance on the usage of SciENcv and our institutional plan for supporting this new requirement will be forthcoming

• New requirement for providing e-mail documentation of Program Officer approval for the submission of RAPID and EAGER proposals; and

• Clarifications to current and pending support coverage.



New PAPPG continued:

• May 2019 draft version of the current and pending support section was as follows:

• Current and pending support information must be separately provided for each individual designated as senior personnel on the proposal through use of an NSF-approved format. Information must be provided about all current and pending support, including this project, for ongoing projects, and for any proposals currently under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual. All projects and activities, current or proposed, that require a time commitment from the individual must be reported, even if the support received is only in-kind (such as office/laboratory space, equipment, supplies, employees, students). The total award amount for the entire award period covered (including indirect costs) must be provided, as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior personnel involved.

• Sources of support include Federal, State, local, foreign, public or private foundations, non-profits, industrial or other commercial organizations, consulting, or internal funds allocated toward specific projects.



New PAPPG continued:

• NSF will be holding a webinar on 2/6/20 to discuss these changes. Details on the webinar are available at https://nsfgrantsconferences.com/pappg-webinar-20/

• After the webinar ORED will release additional details

https://nsfgrantsconferences.com/pappg-webinar-20/


Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components

NIH Notice NOT OD-19-114

• Notice was released on July 10, 2019 and is available at https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html

• Council on Governmental Relations (COGR) has shared the following key reminders associated with this important notice

• Complete and accurate reporting of research support from internal and external sources, and the relationship to NIH funding, is critical for NIH and grantee institutions to assess scientific and budgetary overlap, and availability of time to commit to NIH funded projects.

• Reporting Consulting and Outside Professional Activities• Key personnel must disclose funding for all research activities, regardless of where the

research will be carried out.

• Outside activities that are not considered research do not appear to require reporting to NIH.

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html



NIH Notice NOT OD-19-114 continued• Training Awards, Gifts, and Prizes / Institutional Support

• Key personnel must disclose start-up packages and support for research from entities other than the applicant institution, even if the research will be carried out at another institution; and institutional grants and awards that are “separately budgeted and accounted for” per the Uniform Guidance.

• Key personnel are not responsible for disclosing start-up packages from the applicant institution in any form; gift funds that meet the formal definition of a gift; endowed chair funds and other endowment allocations.

• Reporting In-Kind Support• Key personnel must disclose in-kind resources that are uniquely available to key

personnel (office/laboratory space, equipment, supplies, employees) including those available outside the applicant institution; details about in-kind personnel who are expected to work directly on a proposed project; report details of in-kind support in the Facilities and Other Resources section or in Other Support section of the application; report details of individuals who have expended at least one month of effort during the year (compensated or uncompensated) in the annual report (no change).



NIH Notice NOT OD-19-114 continued

• Key personnel are not responsible for disclosing institution-wide resources such as core facilities or shared equipment that are made broadly available.

• Reporting of Appointments and Affiliations• Key personnel must disclose affiliations or appointments that are likely to be cited in NIH-

funded publications in the biosketch section of the application.

• Foreign Component• Prior approval is required before initiating a new “foreign component” per current NIH

policy (no change).

• The Foreign Component must meet two criteria, per the NIH:• A portion of the project will be conducted outside of the U.S., and• The institution must determine if the activities are considered significant.• If both criteria are met, then there is a foreign component.



NIH Notice NOT OD-19-114 continued• Foreign Component

• Some examples of activities that may be considered a significant element of the project include, but are not limited to:

• collaborations with investigators at a foreign site anticipated to result in co-authorship

• use of facilities or instrumentation at a foreign site• receipt of financial support or resources from a foreign entity

• If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.

• Informal collaborations with international researchers could meet the NIH definition of a Foreign Component; therefore, it is not always apparent to ORED when a foreign component arises.

• Please remind your PIs about this NIH requirement so both PIs and the institution can comply with this NIH requirement.


Department of Energy Public Access Plan

DOE Office of Science Reminder• Please note that DOE awards have a requirement, as a term and condition of the award, to

submit to DOE the final peer-reviewed accepted manuscripts for any published journal articles based on work supported by DOE awards

• Submissions are to be made to the DOE corporate E-Link system (https://www.osti.gov/elink/) and it is expected that recipients will submit final peer-reviewed accepted manuscripts as soon as they are accepted for publication, but no later than one-year after the date the journal article is published online, and before closeout. After the one-year period, final peer-reviewed accepted manuscripts will be made available through DOE PAGES and OSTI.GOV.

• When publishing work that is supported by a DOE award, it is important to remember to acknowledge DOE and the award appropriately. Requirements for acknowledgement of federal support can be found at https://science.osti.gov/Funding-Opportunities/Acknowledgements.

• A DOE produced video detailing instructions on the submission of the final peer-reviewed accepted manuscripts for published journal articles is available at https://www.youtube.com/watch?v=1o3B835Cf84

https://www.osti.gov/elink/

https://science.osti.gov/Funding-Opportunities/Acknowledgements

https://www.youtube.com/watch?v=1o3B835Cf84


ePRAF Updates

ePRAF Updates• On January 22, 2020 the following updates were released in PeopleSoft on the electronic

proposal routing approval form (ePRAF)

• Preeminent/Emerging Preeminent Programs• A new section has been added to the proposal section of the ePRAF to capture proposals

associated with Preeminent and Emerging Preeminent Programs. The section has a pick list of the available programs to be selected. The field should be left blank if the proposal being submitted is not associated with a Preeminent or Emerging Preeminent Program. Please note that responses to the Centers and Institutes section is still required in the project screen for those projects that are associated with a Center or Institute.

• Requirements from federal funding agencies require additional questions on the ePRAF:

• 6. Did you disclose on the sponsor’s current and pending support form (or similar other form which may be required by the sponsor) all financial resources, whether federal, non-federal, foreign, commercial or institutional, available or to be provided in direct support of project personnel’s research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards?


ePRAF Updates

ePRAF Updates Continued• Requirements from federal funding agencies require additional questions on the ePRAF:

• 9. Will this be an HHS funded study that involves cooperative human subject research (i.e., more than one collaborating institution/site)? If yes, all institutions that are engaged in conducting research with human subjects will need to use a Single IRB. More information: http://research.fiu.edu/irb/single-irb

• 19. Do you currently have any affiliations (whether paid or unpaid and even if described as honorary or adjunct) with foreign entities or foreign governments, including any talent programs (e.g. programs in which you have been recruited by a foreign entity)? If yes, please provide additional details in the comment box.

• 20. As part of this project, will the sponsor be providing any information under a non-disclosure agreement (NDA) or other confidentiality agreement, which is both proprietary and export controlled, or which you believe will require federal data security requirements (e.g. NIST 800-171 controlled unclassified information)? If yes, please provide additional details in the comment box.

http://research.fiu.edu/irb/single-irb


Guidance Regarding Foreign Influence and Research

Foreign Influence and Research• This is an evolving topic that encompasses not just research (funded and unfunded) but other

aspects of higher education.

• ORED has created a website to summarize guidance from key agencies that fund research at FIU with detailed guidance and communication from the NIH, NSF, DOE, DOD, NASA as well as institutional resources in regards to this topic.

• The site is available at http://research.fiu.edu/guidance-regarding-foreign-influence-and-research/#ored.

• Key reminders on this topic:

• Disclosure of foreign support: ORED proposal and award personnel will continue to work with PIs at proposal and just in time (award) stages to confirm that all key personnel have listed all pending proposals and active awards and to inquire that all foreign components and “other support” have been properly disclosed. If a researcher has any questions or needs to disclose any previously undisclosed foreign support they should contact Robert Gutierrez, Assistant Vice President for Research at [email protected].

http://research.fiu.edu/guidance-regarding-foreign-influence-and-research/#ored



Foreign Influence and Research• Participation in foreign government-sponsored talent programs. Researchers are reminded that

participation in a foreign government sponsored talent program may jeopardize your ability to receive future federal funding for research or your ability to collaborate with U.S. government agencies. Additionally any such participation must be disclosed via the institution’s Report of Outside Activities/Conflict of Interest System and such participation must be approved institutionally prior to engaging in such activity.

• Please note that federal agencies do not have a unified definition of what constitutes a foreign talent program. As such, ORED encourages you to contact Robert Gutierrez, Assistant Vice President for Research, to discuss offers for research which will be awarded to you as an individual (not through FIU) which may require frequent travel to or extended stays in the foreign country from which the offer of research support originated since these are possible indicators that the activity could constitute a government-supported foreign talent program.

• Collaborating with international subawardees. ORED has established formal procedures for administering both domestic and foreign subawards. All subrecipients are subject to a risk assessment and restricted screening process as set forth in ORED operating procedures. Subawards with foreign entities are subject to additional monitoring given the inherent risks associated with projects carried out abroad. Contact Regnier Jurado, Director of Research Management Solutions, with any questions related to foreign subawards.



Foreign Influence and Research

• Report Inventions and Intellectual Property. Researchers are reminded to promptly report inventions and intellectual property (IP) disclosures to the Office of Technology Management and Commercialization in accordance with sponsor requirements and institutional policies and procedures. See http://research.fiu.edu/ored/otmc/ for further guidance.

• Export Control Compliance Researchers are reminded of their continued responsibility to adhere to export control requirements as detailed in the University’s export control policies and procedures (see list of policies below) as well as any project specific Technology Control Plans (TCPs) which may be implemented for their specific projects.

• ORED is collaborating with other units at the University on this evolving topic and the guidance will continue to be updated as relevant information becomes available.


Guidance on Salary Limitation for Grants and Cooperative Agreements FY 2020

At this time NIH has not issued a FY 2020 notice, however, indication from the Agency for Healthcare Research and Quality (AHRQ) is that the Executive Level II salary level will be $197,300.

The NIH 12 month appointment salary cap for applications will be $197,300. The NIH salary cap for nine month appointments will be prorated to $147,408.

A formal notification will be sent out to FIU’s research community when the NIH issues the FY2020 notice.


Additional Guidance on the NIH Policy on the Use of a Single Institutional Review Board for

Multi-Site Research

The purpose of this Notice is to inform the research community of the NIH requirement to adhere to the Revised Common Rule to use a single IRB for NIH-supported multi-site studies conducting research at more than one domestic site. NIH has prepared this interim guidance on issues that are impacted by 45 CFR 46.114. More information about the Revised Common Rule Cooperative Research Provision may be found at https://www.hhs.gov/ohrp/regulations-and-policy/single-irb-requirement/index.html.

Guidance on OHRP’s Determination of Exception to the Required Use of a Single IRBOn November 22, 2019, as permitted by 45 CFR 46.114(b)(2)(ii), the Office for Human Research Protections (OHRP) announced in the Federal Register its determination of exception for two categories of research from the required use of a single IRB to review cooperative research under the Revised Common Rule. Relevant OHRP exception categories for NIH-supported cooperative research include the following circumstances:

a. the NIH single IRB policy does not apply, and the research was initially approved by an IRB before January 20, 2020, or

b. NIH excepted the research from its single IRB policy before January 20, 2020

https://www.hhs.gov/ohrp/regulations-and-policy/single-irb-requirement/index.html


New NIH "FORMS-F" Grant Application Forms and Instructions Coming for Due Dates on or after May 25, 2020

The following application forms include substantive changes (i.e., new/deleted/modified fields). All other forms include only an OMB expiration date change.

•PHS 398 Career Development Award Supplemental Form•PHS 398 Cover Page Supplement•PHS Assignment Request form•PHS Fellowship Supplemental Form•PHS Human Subjects and Clinical Trials Information•SBIR/STTR Information

Applicants must use FORMS-F application packages for due dates on or after May 25, 2020 and must use FORMS-E application packages for due dates on or before May 24, 2020. Applications submitted using the wrong forms for their intended due date will not be reviewed.


Requirement for ORCID iDs for Individuals Supported by Research Training, Fellowship, Research Education, and Career

Development Awards Beginning in FY 2020 The purpose of this Notice is to inform the research community of the requirement to adhere to the NIH, AHRQ, and CDC that individuals supported by research training, fellowship, research education, and career development awards will be required to have ORCID iDs (Open Researcher and Contributor Identifiers) beginning in FY 2020.

Background and Related InformationORCID iDs are unique, persistent digital identifiers that distinguish individual investigators and can be used to connect researchers with their contributions to science over time and across changes of name, location, and institutional affiliation. These free identifiers are assigned and maintained by the non-profit organization ORCID.

ImplementationThe requirement for ORCID identifiers will be implemented through the appointment process for those appointed to institutional awards and through the application process for those applying for individual awards. Beginning with receipt dates on or after January 25, 2020, the requirement for ORCID identifiers will be enforced at the time of application for individual fellowship and career development awards.


Vendor/Professional Fees

Definitions:

• Consultant: An individual whose expertise is required to perform an element of the project.

• Subaward: An entity whose expertise is required to perform an element of the project and goes beyond their routine business operations.

• Professional Fee/Vendor: Provides similar goods and services to multiple customers as part of their routine business operations.

Key Points:

• If consultant will use his/her consulting company, then the proper contracting mechanism could potentially be a Subaward.

• Professional Fee/Vendor agreement is initiated at the department level via the TCM system.

• Any relationship that fits the FIU definition of Nepotism must be disclosed at the proposal stage and then addressed at the award stage.


ORED FORMS

UPDATED:

• Subaward Commitment Form

• PHS and NSF Investigator Report of Financial Interests in Research Form

FORTHCOMING:

• Subaward Request Form

• Material Transfer Agreement

• Project Transfer Request Form

Project Organizational ChartOffice of Research and Economic DevelopmentPost-Award

Certified Research Administrator (CRA)Study session for exam May 2020

Commence March 19, 2020

• Sessions are once a week for 1 ½ hours for 8 weeks

• Organized around the CRA Body of Knowledge

• Designed to assist in targeting study areas to prepare for the CRA exam

• 250 multiple choice questions – testing time 4 hours• Passing 70% or 175 correct multiple choice questions

• Eligibility requirements for the exam• Bachelor’s Degree and 3 years experience• Associates Degree and 5 years experience• No degree and 6 years experience with additional approval

• Email [email protected] if interested in joining the study session in March 2020


Updating FIU Research Certificate Course PowerPoint Slides

The Course is comprised of twelve modules from proposal preparation through project close-out and research compliance obligations.

Revisions to the course format are in process.

As the PowerPoint Slides are updated they will be posted to the learning management system.

Information can be found at http://research.fiu.edu/training/racc/

http://research.fiu.edu/training/racc/


Guidance Supplement to Property Control Manual

A draft document “Guidance Supplement to Property Control Manual” includes an Overview and Steps for the procurement of accountable property, also referred to as Other Capital Outlay (OCO)

Project Organizational ChartOffice of Research and Economic DevelopmentResearch Integrity

• New Conflict of Interest Research Committee (COI-RC)• Composed of staff, faculty, and Dean (or Dean’s designee) of the

subject investigator’s college• Reviews potential or actual financial conflicts of interest in research• Develops and reviews monitoring plans for managing conflicts

• Responsible Conduct of Research• New boilerplate language for proposal submissions• Includes overview of FIU’s formal RCR training and suggestions for

describing informal RCR instruction• Adaptable to different types of grant submissions• http://research.fiu.edu/proposal-preparation/templates


• Cooperative Research and Single IRB Changes

• New Requirement: Federally funded cooperative human research receiving initial IRB approval on or after 01/20/20 must use a single IRB review.

• Proposal Submissions: Need to include a Single IRB plan (will not impact review score, but award won’t be released without a plan).

• Reviewing IRB: Identified by the department/agency supporting or conducting the research or proposed by the lead institution.

• Exceptions to Requirement: International sites, tribal nation sites, or studies that received initial IRB approval prior to 01/20/20.

• Single IRB Web Page: http://research.fiu.edu/irb/single-irb


• Single IRB Reliance Process

• For FIU to Rely Upon an External IRB: • Submit an “IRB Reliance Request Form” in TOPAZ• This creates a “shell” version of the study• Researchers must keep the shell study active for duration of

project (amendments, renewals, etc.).

• For an External Institution to Rely Upon FIU IRB:• List external researchers in FIU IRB Approval Form in TOPAZ• Upload a completed and signed “External Site IRB Reliance

Request Form”

• IRB Reliance Web Page: • http://research.fiu.edu/irb/irb-reliance-requirements


• Upcoming IRB Training Workshop• IRB Overview – Obtaining Approval• When: February 13th (2 PM – 4 PM)• RSVP here: http://research.fiu.edu/rcr/workshops

• Upcoming IACUC Training Workshop• IACUC – Ethics in Animal Use• When: March 5th (2 PM – 3 PM)• RSVP here: http://research.fiu.edu/rcr/workshops

• Upcoming RCR Training Workshop• RCR – Responsible Conduct of Research in the Digital Age• When: March 13th (2 PM – 3:30 PM)• RSVP here: http://research.fiu.edu/rcr/workshops

Project Organizational ChartOffice of Research and Economic DevelopmentResearch Information Systems

Scholarly Data Initiatives

• Introduction to Scholars@FIU, ORCID, and ScienCV

• Coordinated effort currently underway with ORED, the University Libraries and the Office of the Provost/Panther180 team to develop the following:

• Communications/Infographics

• Workshops

• Additional resources on FIU websites


Scholars@FIU

• Scholars@FIU – A discovery platform for FIU’s expertise and scholarly output.

• Located at https://scholars.fiu.edu

• Currently in a soft launch phase. Over twenty potential additional data sources to be integrated during 2020.

https://scholars.fiu.edu/


ORCID


ScienCV = Science Experts Network Curriculum Vitae


ScienCV Biosketch Form


Linking External Accounts


ScienCV

• SciENcv is available at:

http://www.ncbi.nlm.nih.gov/sciencv

• SciENcv video overview:

http://youtu.be/PRWy-3GXhtU

http://www.ncbi.nlm.nih.gov/sciencv

http://youtu.be/PRWy-3GXhtU

Project Organizational ChartOffice of Research and Economic DevelopmentClosing Remarks / Adjournment

Closing Remarks

• Questions• Adjournment• Don’t forget to sign the sign-in sheet

Office of Research and Economic...

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