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Section Overview II. Proposal Preparation Electronic Research Administration (ERA) Systems Proposal Budgeting Allowable Costs Cost Share Proposal Deadline and Authorization Conflict of Interest Research Misconduct Review Boards Export Controls Export Agencies and Regulations. Contact:

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Section overview ii

Section Overview II

Proposal Preparation

Electronic Research Administration (ERA) Systems

Proposal Budgeting

Allowable Costs

Cost Share

Proposal Deadline and Authorization

Conflict of Interest

Research Misconduct

Review Boards

Export Controls

Export Agencies and Regulations


Section overview ii

Contact:

Lisa Jukkala

Manager, Government Contracts/Training

Research & Sponsored Programs

487-2226

[email protected]


Proposal preparation

Proposal Preparation

Inform Research & Sponsored Programs

Review solicitation

Limited submission

Guidelines can be found on web


Proposal preparation continued

Proposal Preparation (continued)

Internal Forms: http://www.mtu.edu/

Transmittal Sheet

Pay attention to special approvals that may be required

Budget Spreadsheet

Cost Share/Matching Support Form – if needed

Conflict of Interest Disclosure Form – if needed


Electronic research administration era systems

Electronic Research Administration (ERA) Systems

Multiple Agency System:

Grants.gov

Allows organizations to electronically find and apply for competitive grant opportunities from all Federal grant-making agencies

Located at: http://www.grants.gov/

Agency Specific Systems:

e Center: U.S. Department of Energy, located at http://e-center.doe.gov/

NSPIRES: National Aeronautics and Space Administration, located at http://nspires.nasaprs.com/external/

ERA Commons: National Institutes of Health, located at https://commons.era.nih.gov/commons/

FastLane: National Science Foundation, located at https://www.fastlane.nsf.gov/fastlane.jsp


Proposal budgeting

Proposal Budgeting

Determine anticipated start date and budget by year or applicable time period.

Direct cost categories may include:

Personnel

GRA stipend rates found on web

Fringe Benefits

Current fringe benefit rates found on web

Equipment/Fabricated Equipment

Travel

Consultants

Materials/Supplies


Proposal budgeting continued

Proposal Budgeting(continued)

Internal/External Services

Subcontracts

Publication Costs

Tuition/Fees

GRA tuition/fee rates found on web

Other Direct Costs

Facilities and Administrative (F&A) Costs

Determined by project function and location

Current F&A rates found on Web


Allowable costs

Allowable Costs

OMB Circular A-21, Cost Principles for Educational Institutions

Principles for determining costs applicable to research and development, training, and other sponsored work under grants, contracts and other agreements with educational institutions

Summary found on web


Cost share

Cost Share

Portion of project costs not paid by the sponsor

Types of cost share:

Mandatory: % or amount required by solicitation

Voluntary:

not required by solicitation

value not disclosed to sponsor

Sources of cost share:

University funds

Faculty academic year time

GACS (guidelines found on web)

External funds

Cost share expenditures must occur in the approved period of performance


Proposal deadline and authorization

Proposal Deadline and Authorization

It is strongly recommended that all internal paperwork and complete proposal be submitted to Research & Sponsored Programs at least 48 hours prior to the proposal mailing or electronic submission deadline.

Board of Control policy requires that all proposals submitted from the University be authorized by a designated University official. Research & Sponsored Programs is the unit responsible for review and submission of all proposals on behalf of Michigan Tech. Principal investigators do not have authority to submit proposals.


Contact joanne polzien director research compliance 487 2902 jpolzien@mtu edu

Contact:

Joanne Polzien

Director

Research Compliance

487-2902

[email protected]

August 23, 2007


Presentation overview

Presentation Overview

Conflict of Interest

Faculty Handbook: 3.1.1 Conflict of Interest/Effort

Faculty Handbook: Appendix B. Conflict of Interest Procedures

Conflict of Interest Disclosure Form

Research Misconduct

Faculty Handbook: 3.3.5 Scientific Misconduct

Faculty Handbook: Appendix F. Scientific Misconduct Procedures

Review Boards

Export Controls


Conflict of interest

Conflict of Interest

Conflict of Interest Coordinator

Dr. David Hand, Civil & Environmental Engineering

487-2777 or [email protected]

MTU’s Transmittal form has a disclosure section that you need to complete.


Conflict of interest1

Conflict of Interest

Conflicts of interest at Michigan Tech are divided into five categories of increasing seriousness:

Category I: Exempt Activities - almost all outside professional activities can pose conflicts of interest, if an honoraria or royalties are received, or conflicts of commitment. But participation in certain traditional professional activities expected of all members of the MTU academic community does not have to be reported or disclosed.


Conflict of interest2

Conflict of Interest

Category II: Professional activities and academic service that pose very little conflict of interest in traditional financial terms, but because they require a commitment of time beyond that normally allowed for consulting relationships can create conflicts of commitment.

Category III: External professional relationships with minimal financial interests, such as consulting relationships or royalty sharing arrangements, outside research contracts and grants, adoption of self-authored textbooks and other learning aids.


Conflict of interest3

Conflict of Interest

Category IV: Outside business activities, including entrepreneurial activities such as ownership of outside companies, that are connected to one’s professional activities within the University and that involve more complex financial relationships.

Category V: Other outside professional activities that create unacceptable conflicts of interest.


Conflict of interest4

Conflict of Interest

Conflict of Interest/Effort Policy can be found at:

http://www.admin.mtu.edu/admin/prov/facbook/ch3/3chap-01.htm#P4_55

Conflict of Interest Procedures can be found at:http://www.admin.mtu.edu/admin/prov/facbook/appb/bapp2.html


Research misconduct

Research Misconduct

Significant departure from commonly accepted practices in the scientific community in proposing, performing or reviewing research, or reporting research, such as fabrication, plagiarism, falsification, deception, misrepresentation, or arbitrary selection of data;

Plagiarism or other appropriation of the work of another individual and presenting it as if it were one’s own or without credit to the originator as is required by commonly accepted practices in the scientific community;


Research misconduct1

Research Misconduct

  • Material failure to comply with funding agency (federal, state, or private, etc) requirements that are uniquely related to the conduct of the research; and

  • Retaliation against a person who, acting in good faith, has reported or provided information about suspected or alleged misconduct.


Research misconduct2

Research Misconduct

Any questions, concerns, or interpretations should be directed to Joanne Polzien in the Research Compliance Office.

A detailed definition for Scientific Misconduct can be found at: www.admin.mtu.edu/admin/prov/facbook/ch3/3chap-31.htm

Scientific Misconduct Procedures can be found at: www.admin.mtu.edu/admin/prov/facbook/appf/fapp.htm


Review boards

Review Boards

IRB

Institutional Review Board - Human Subjects Committee

Dr. Willie Melton, Chair, Dept. of Social Sciences

IACUC

Institutional Animal Care and Use Committee

Dr. Ann MacLean, Chair, School of Forest Resources and Environmental Science

IBC

Institutional Biosafety Committee (Recombinant DNA)

Dr. Shekhar Joshi, Chair, School of Forest Resources and Environmental Science


Review boards1

Review Boards

Information and forms for these committees may be found at: http://www.admin.mtu.edu/research/vpr/review.html

All Applications for research to use human subjects, animals, and R-DNA need to be submitted to the Research Compliance Office for dissemination to the appropriate board/committee for review and approval.


Review boards2

Review Boards

Human Subject Research

All human research conducted at, by, or under the auspices of Michigan Tech, whether funded or not and whether conducted by administrators, faculty, staff, or students, must be reviewed and approved before the research begins.

Exempt - "exempt" does not mean exempt from review - “Exempt" is a determination that the research in question does not meet the requirements of oversight.


Review boards3

Review Boards

Questions to consider:

Is your study a systematic investigation designed to develop or contribute to the body of generalizable knowledge? If yes, then your study is defined as research.

Will you obtain data through investigation or interaction with one or more living individuals, or will you obtain any identifiable private information about a living individual? If yes, then you are using human subjects.


Review boards4

Review Boards

If you answered yes to both questions, then your study is defined as research with human subjects and must be approved by the IRB before you begin recruitment of research participants or data collection.

Please note that survey research, all pilot studies, and oral history research do meet this definition and must be approved by the IRB before you send out questionnaires, interview subjects, or otherwise have contact with potential subjects.


Section overview ii

Contact:

Jay Meldrum

Director

Keweenaw Research Center

487-3178

[email protected]


Export agencies regulations

Export Agencies & Regulations

Export Administration Regulations (EAR)

Department of Commerce, Bureau of Industry and Security (BIS)

Commercial or dual-use items (military/commercial)

International Traffic in Arms Regulations (ITAR)

Department of State, Office of Defense Trade Control (ODTC)

Military items classified on the Munitions List

15 CFR 730.3


Export agencies regulations1

Export Agencies & Regulations

Department of the Treasury

Office of Foreign Assets Control (OFAC)

Department of Justice

Department of Energy

Nuclear Regulatory Commission

Department of Homeland Security

Boarder and Transportation Security

U.S. Customs


Export defined

Export Defined

Sending or taking a defense article out of the United States in any manner, except by mere travel outside of the United States by a person whose personal knowledge includes technical data.

Disclosing (including oral or visual disclosure) or transferring technical data to a foreign person, whether in the United States or abroad (so-called “deemed export”).

15 CFR 730.5; 22 CFR 120.17


Export of items

Export of Items

Important questions:

What is my item?

Where is it going?

Who will receive it?

What will be the end use?

What else do I know about my end user?


Export of items1

Export of Items

General Prohibitions must be checked.

There are 10 General Prohibitions.

No exports to certain persons, countries, end use, and end users.


General prohibitions

General Prohibitions

Denied Persons (Dept. of Commerce)

Parties previously denied export privileges.

Unverified List (Dept. of Commerce)

Foreign parties to transactions, where post-shipment verifications or pre-licensed checks could not be conducted.

Entity List (Dept. of Commerce)

Foreign parties for which there are concerns of possible proliferation activities.

Debarred List (Dept. of State)

Persons convicted of violating or conspiring to violate the Arms Export Control Act


General prohibitions1

General Prohibitions

OFAC Lists (Dept. of Treasury)

Countries against which United States has declared embargo or sanctions.

Countries accused by United States of sponsoring terrorism.

OFAC Lists Primarily Address:

Cuba, North Korea, Libya, Iraq, Iran, Burma (Myanmar), Sudan, Liberia, The Balkans, and Zimbabwe

Diamond Trade, Narcotics, Terrorism, and Weapons of Mass Destruction


Is a license required

Is a License Required?

Assuming no General Prohibitions apply:

If it is not on the EAR or ITAR list of restricted items, no license is required.

If item is on the list and exception applies, no license required.

Even if item is on the list and no exception applies, regulations may not require license for export to country of destination.

Contact Joanne Polzien, 487-2902 for assistance.


Applying for license

Applying for License

Technical data describing export item must be provided.

Purchase order required for export license under ITAR.

If all goes well, license may be obtained in 45-60 days.


Foreign person

Foreign Person

Any natural person who is not a lawful permanent resident or who is not a protected individual.

Lawful Permanent Resident “Green card” = permanent resident.

Student visa = not permanent resident.

22 CFR 120.16


Foreign person1

Foreign Person

Any foreign corporation, business association, partnership, trust, society or any other entity or group that is not incorporated or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of foreign governments (e.g., diplomatic missions).

22 CFR 120.16


University exceptions for deemed exports

University Exceptions for Deemed Exports

No license required under EAR or ITAR for the deemed export of technology that:

is already published or will be published;

arises during or results from fundamental research;

is educational; or

is included in patent applications and communicated to foreign persons under certain conditions.

15 CFR 734.3(b)(3) & 734.7-734.9; 22 CFR 120.10 & 120.11


Published and public domain exceptions

“Published” and “Public Domain” Exceptions

Information is published when generally accessible to the interested public in any form, and including:

Published in any media (Internet, bookstores, newsstands, etc.).

Available in public or university libraries.

Published in patent or patent application.

Released at an “open” conference.

15 CFR 734.7; 22 CFR 120.11


Fundamental research exception

“Fundamental Research” Exception

Basic and applied research in science and engineering, where resulting information is ordinarily published and shared broadly within the scientific community.

Not proprietary research or industrial R&D, the results of which ordinarily are restricted for proprietary reasons or specific national security reasons.

15 CFR 734.8; 22 CFR 120.11


Fundamental research exception1

“Fundamental Research” Exception

Not fundamental research if:

University or its researchers accept other restrictions on publication of scientific and technical information resulting from the project or activity.

Research is funded by the U.S. Government and specific access and dissemination controls protecting information resulting from the research are applicable.

15 CFR 734.8; 22 CFR 120.11


Fundamental research exception2

“Fundamental Research” Exception

Transfer of background proprietary information is not part of the fundamental research and is subject to export regulation.

Still considered fundamental research if sponsor requires prepublication review for removal of background proprietary information or to avoid compromising patent rights.

15 CFR 734.8; 22 CFR 120.11


Mtu policy

MTU Policy

MTU will accept research funding when advance sponsor notification or limited-time (generally < 60 days) sponsor review prior to publication is required for review of intellectual property.

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Fundamental research exception3

“Fundamental Research” Exception

Foreign nationals can work on research projects and write theses, just as United States students can, provided the research qualifies as “fundamental research.”

15 CFR 734.8; 22 CFR 120.11


Educational exception

“Educational” Exception

No license required for information released by instruction in catalog courses and associated teaching laboratories of academic institutions.

If you teach it in an open-enrollment class with no registration restrictions, there is no export license required!

15 CFR 734.9; 22 CFR 120.10


Mtu policy1

MTU Policy

All sponsored projects received by MTU with national security restrictions on publication of results and/or participation by foreign nationals will be administered through Jay Meldrum at KRC.

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Mtu policy2

MTU Policy

In all cases, MTU will not accept projects unless both the Principal Investigator (PI) and unit administrator(s) concur with this decision, and agree to comply, and enforce compliance, with all contract terms and conditions.

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Mtu policy3

MTU Policy

MTU will not under any circumstance accept research funding supporting development of graduate student theses/dissertations when publication is prohibited or requires prior sponsor approval.

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Mtu policy4

MTU Policy

MTU may consider accepting national security publication restrictions when these are immaterial to the conduct of the project or the thesis/dissertation of a student working on the project (such as testing or service projects)

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Mtu policy5

MTU Policy

MTU may consider accepting restrictions on participation by foreign nationals when these are immaterial to the conduct of the project; this determination is to rely heavily on the recommendations of the PI and unit administrator (s).

www.admin.mtu.edu/rgs/research/sprot/policies/natlsecurity.html


Example 1 contract language

Example 1 – Contract Language

GENERAL PROVISIONS OF GRANTS FOR UNIVERSITY TRANSPORTATION CENTERS (UTCs)PI: Tom VanDam

5. Citizenship of Students. Students who receive financial support other than compensation under the UTC Program, including those under consideration for such honorary programs as the UTC Student of the Year Award, must be U.S. citizens or permanent residents of the United States. Should circumstances exist that warrant the support of a foreign national student, prior written approval must be obtained from RITA. The request must contain complete justification for the proposed support of that student.


Example 2 contract language

Example 2 – Contract Language

NSF GRADUATE TEACHING FELLOWS IN K-12 EDUCATION (GK-12)

PI: Alex Mayer, Geological/Mining Engineering & Sciences

Fellows are expected to be supported on any GK-12 award for a minimum of one year and a maximum of two years. Fellows must be citizens, nationals or permanent residents of the United States. Foreign students who hold student visas are not eligible.


Example 3

Example 3

Department of Defense ITAR(§ 120.11(a)(8)

PI: Zhi (Gerry) Tian

Under the definition of this exclusion, information is in the public domain if it is published and generally accessible or available to the public through fundamental research at accredited U.S. institutions of higher learning where the resulting information is ordinarily published and shared broadly in the scientific community (§ 120.11(a)(8)).

However, this definition also provides that University research is not fundamental research if “the research is funded by the U.S. Government and specific access and dissemination controls protecting information resulting from the research are applicable.”


Example 4 dod

Example 4 DOD

PI: Nick Subotic (MTRI)


Example 5

Example 5

Army Research Labs

PI: Craig Friedrich – Mechanical Engineering – Engineering Mechanics

52.004-4408 FOREIGN NATIONALS PERFORMING UNDER CONTRACT (AUG 2004)

In accordance with Title 8 U.S.C. 1324a, local Foreign Disclosure Officers (FDOs) may approve access by foreign nationals working on unclassified public domain contracts for the duration of the contract, provided the foreign nationals haveappropriate work authorization documentation.


Questions

Questions?


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