FAQs
Frequently Asked Questions
NU-RES Administration/Pre-Award
You can find the NU Facts sheet here.
- First, are you eligible to be a Principal Investigator?
- The privilege to act as a Principal Investigator (PI) or a Co-Principal Investigator (Co-PI) on an externally-funded project is automatically conferred upon all Northeastern faculty members. Those without a faculty appointment must work with their college administration to determine if the college’s policies and procedures allow the college to confer temporary PI status. By approving the ePAWs record, the college will convey to NU-RES that they approve of the named PI. Please see attached guidance.
- Choose a funding opportunity
- Where do you want to apply? Do you have an agency in mind or do you need to find an opportunity?
- Funding Opportunities lists various search engines that can assist you
- Once you have your opportunity in hand, get familiar with the proposal requirements.
- Read the directions, most proposals are rejected simply because the directions were not followed correctly!
- Use either ePAWs and the sponsors submission portal, or our proposal submission application COEUS
- Visit our Proposal Preparation webpage for more info…
- Proposals must be submitted to the Office of Research Administration and Finance no later than 5 business days before the sponsor’s deadline
- This allows us to review your proposal and make sure you haven’t missed anything and that your submission will receive the complete sponsor review that it deserves
- We understand that there are a lot of elements that go into creating a great proposal, so please contact your school’s Grant Officer with your questions – we are here to help you!
Program staff are your primary source of information for scientific, funding and programmatic matters, and they can advise you regarding:
- An institute/center’s potential enthusiasm about your research area
- Potential application topics
- The appropriate FOA through which to apply
- Investigator-initiated research: topics of interest and new scientific directions
- Additional information about an initiative such as a request for applications or program announcement
- Requirements for special areas such as human subjects and vertebrate animal research
- The appropriate study section to request in your cover letter
Yes, they are busy people. So we recommend you e-mail them first rather than play phone tag.
- data through intervention or interaction with the individual, (such as, interviews, surveys, clinical testing, or any other physical intervention or personal interaction), or,
- identifiable private information.
Legal requirements to protect human subjects apply to a broader range of research than many investigators realize. Protections are required for research that uses:
- Bodily materials, such as cells, blood or urine, tissues, organs, hair or nail clippings, even if you did not collect these materials.
- Residual diagnostic specimens, including specimens obtained for routine patient care that would have been discarded if not used for research.
- Private information, such as medical information that can be readily identified with individuals, even if the information was not specifically
collected for the study in question. Research on cell lines or DNA samples that can be associated with individuals falls into this category.
Please visit the Office of Human Subject Research Protection for more information.
Open Skies Agreements – U.S. currently has Open Skies Agreements in effect with European Union, Australia, Switzerland, and Japan.
As of January 1, 2021, The United Kingdom (U.K.) is no longer a member of the EU. Consequently, the Open Skies Agreement with the EU does not pertain to the U.K. Travelers must use a U.S. Flag Carrier to travel from the U.S. to the U.K. and not a U.K. airline (e.g., British Airways), unless they use a different Fly America Act exception. Travelers may continue to use an EU agreement for travel from the U.S. to the U.K. as long as the flight stops in the EU prior to arrival in the U.S. or the U.K.
To learn more visit the Policies and Guidelines page.
- First, are you eligible to be a Principal Investigator?
- All NU faculty are automatically eligible, all others must request temporary PI status.
- Choose a funding opportunity
- Where do you want to apply? Do you have an agency in mind or do you need to find an opportunity?
- Research Development’s funding resources page lists various search engines that can assist you.
- Once you have your opportunity in hand, get familiar with the proposal requirements.
- Read the directions, most proposals are rejected simply because the directions were not followed correctly!
- Is it being submitted electronically? Read the funding opportunity announcement to determine submission requirements.
- Does your solicitation requires a paper submission? Check out our fact sheet on the Policies & Guidelines webpage.
Questions about your solicitation should be directed to your Grant Officer; questions about the ePAWs application should be directed to NU-RESHC@northestern.edu.
NU-RES Finance/Post-Award/Compliance
Allowable and Unallowable Expenses
- 78010 Study Subject Payments/Incentives
- 74600 Participant Support Costs – Stipends
- 74601 Participant Support Costs – Other
Find your point of contact on our Contacts webpage and select the resource based on department (for Research Administration related questions), College (for Research Finance related questions), or Subject Matter Expert.
Banner
- Financial Planning, Strategy, and Analytics Office
- Requesting Banner Finance Access
- Cognos Access Request Form
For Cognos training, visit the Cognos Training Calendar and sign up for a session.
Closeout Process
Cost Sharing
Cost Transfers
Facilities and Administration Costs
General
Progress Reporting
Salary-Related
Time and Effort Reporting
Travel
Compliance
Export Control
Export controls apply to virtually all fields of science and engineering and restrict both physical shipments and electronic transmission of information. These laws apply to all activities – not just sponsored research projects.
The goal of export controls is to protect national security interests, including promoting and protecting critical U.S. intellectual property and technology.
Exports include:
- Physical shipments of items to a foreign country or
- Transmission of controlled information out of the U.S., no matter the mode of transmission (i.e. Dropbox, email, courier, etc.)
- Releasing or otherwise transferring (including verbally or visually) controlled technology to a foreign person in the U.S. (a “deemed export ”)
- Transferring registration, control, or ownership of certain controlled items to a foreign person, or
- Use or application of controlled technology on behalf of or for the benefit of any foreign person or entity, either in the U.S. or abroad.
The following categories of information are exempt from export controls:
- Fundamental Research: defined as “basic and applied research” in science and engineering. The results of Fundamental Research are ordinarily shared broadly within the scientific community. Research that falls under this exclusion may still be subject to export controls if it involves physical shipments outside the U.S. or creating tangible items/devices.
- Published (publicly available) information and Software: Information that is published and publicly accessible in books or periodicals or information that is presented at a conference, meeting, seminar, trade show or other open gathering is considered to be in the public domain. An open gathering is one in which members of the general public are eligible to attend and attendees are permitted to take notes.
- Published Educational Information: Most course material taught in U.S. universities is published in the course catalog and is not subject to export control regulations
.
- Shipments of physical items outside of the U.S., such as research equipment, materials, and biologicals
- Research involving military technology, spacecraft, satellites, nuclear energy or export-controlled items or information
- Development of encrypted software
- Transfer of controlled information or equipment to foreign nationals in the U.S. or abroad (where no license exception applies)
- Presenting unpublished research/data (where no license exception applies)
- Traveling to a sanctioned or embargoed country
- Using any US Munitions List (USML) defense article or related technical data
A brief prepublication review (e.g., 30 days), is permissible to confirm that any future publication would not inadvertently divulge proprietary information provided to the PI/researcher.
The rule does not apply to a foreign national who is considered a “US Person” by virtue of:
- permanent resident status (i.e., a “green card” holder); or
- U.S. citizenship; or
- status as a “protected person” under U.S. law (i.e., refugees, asylees).
If you are planning to go to a country that is listed on the University’s list of Countries with a Heightened Cybersecurity Risk, you will be asked to take a loaner laptop, per the University Policy on Travel to High-Risk & Sanctioned Destinations.
An export license may be required for collaboration or travel to some destinations with a comprehensive embargo if a general license is not available., This license application process can take 3 to 4 months and approval is not guaranteed.
This directive establishes national policy for controlling the flow of science, technology, and engineering information produced in federally funded fundamental research at colleges, universities, and laboratories. NSDD 189 established that fundamental basic and applied research results (except certain encrypted source code) are exempt from export controls (EAR or ITAR) and thus may be shared broadly with non-U.S. persons without specific government authorization (i.e. an export control license). NSDD 189 allows U.S. persons to benefit from collaborations with a global community of scholars.
Northeastern does what it can to ensure that fundamental research activities are clearly defined as outside the scope of the EAR and ITAR, consistent with its commitment to the free and open exchange of ideas, but there are occasions when the exclusion does not apply, including when working on certain types of government contracts. Confidential technical information received from an outside party, such as a government or industry sponsor, generally does not fall within the fundamental research exclusion.
The Policy on Openness in Research* discourages researchers from accepting restrictions on publication or personnel access. Before a researcher accepts certain types of controlled unclassified information (CUI), such as export-controlled, or covered defense information, technical data, or agrees to publication or access restrictions, the researcher must consult Research Compliance to assess the risks and develop an appropriate Technology Control Plan.
*Research activities at KRI, LLC are exempt from this policy.
International Engagement
The new policy provides a process for the university to prospectively be aware of international activities, enabling and for thefor the university to provide faculty with guidance and information about what disclosures they may need to make to the federal government.
If the travel is funded by an external organization, it is prudent to screen the entities and/or individuals funding your travel to ensure they do not appear on any government-wide restricted parties lists. Contact Research Compliance or your college dean’s office and ask them to perform a screening on your behalf.
All other university policies related to travel will apply, including the Policy Requiring the Registration of University Travel and the Policy on Computers and Mobile Devices for Travel to Destinations with Heightened Cybersecurity Risk.
If you are presented with an honorary appointment during your visit, reach out to researchcompliance@northeastern.edu to discuss if any disclosures need to be made to federal agencies funding your work (either directly or through a subcontract/subaward).
The steps of the process break down as follows::
- Upon receipt of the intake form, Research Compliance reviews the form and related materials and puts together an initial assessment and recommendation within 1-2 days.
- Non-research related engagements, as defined in the Policy, will be sent to the college dean’s designee for final review. Their review and assessment should take 3-5 days.
- Research related engagements, as defined in the Policy, will be sent to the Office of the Provost, Vice Provost for Research Administration. The review and assessment should take 5-8 days, depending on the complexity of the faculty’s funding portfolio, as well as the need to translate any additional documents.
All the questions on the intake form are required to be answered by you. If you are attaching a contract that will address items like remuneration or duration, you may simply state “see attached.”
- Research Compliance: manages the intake and initial assessment process. Research Compliance will make recommendations but does not make decisions on whether or not the engagement is approved.
- Office of General Counsel (OGC): if there is a contract attached to the intake form, OGC will assess the terms and conditions to address potential risks to the university (such as a potential obligation to accept graduate students from specific institutions). OGC provides information, guidance, assesses potential risks, and makes recommendations, but does not make decisions on whether or not the engagement is approved.
- College Dean or Designee: receives Research Compliance’s assessment and recommendation. They will make a decision as to if the engagement is approved for non-research matters.
- Vice Provost for Research Administration: receives Research Compliance’s assessment and recommendation. They will make a decision as to if the engagement is approved for research matters.
- Provost: involved in matters where the initial decision is being appealed by the faculty member. They will render a final decision.
Research Compliance or another office involved in the process may have follow-up questions about submitted materials. If you answer those questions promptly and thoroughly, that will also support and efficient review.
If you are a faculty member without active research proposals and/or active, externally funded research, you will not need to take any other action.
In the unlikely event that a faculty member is asked to decline an engagement, they will be provided with the specific rationale, including citations of any government regulations. In the event that they wish to appeal the outcome, the faculty member is expected to work with Research Compliance to prepare appropriate materials for submission to the Provost, who will make the final decision.
CUI
The CUI program was established to create consistency across U.S. Government agencies in how CUI is marked and safeguarded, and to provide clear expectations to contractors regarding required protections. The National Archives and Records Administration (NARA) implements and oversees the CUI program to ensure compliance. The CUI Program is implemented through 32 CFR 2002 “Controlled Unclassified Information.”
Classified information is excluded from the CUI program because it is subject to other rules and authorities.
The CUI Registry maintained by NARA is an online repository for government-wide guidance regarding CUI classification, policy and practice.
The following are examples of CUI that Northeastern faculty may encounter in the course of their work:
- Critical Infrastructure Information
- Defense-Information (Covered Defense Information), including
- Controlled Technical Information (CTI)
- DoD Critical Infrastructure Security Information
- Naval Nuclear Propulsion Information
- Unclassified Controlled Nuclear Information (UCNI) – Defense
- Export Controlled items, information, and software
- Financial Information (i.e. budgets)
- Intelligence
- Law Enforcement Information
- Transportation Information
- Private Records, such as
- Genetic or health information
- Personnel records
- Student records
- Procurement and Acquisition Records
- Controlled Technical Information DoD ONLY – marked with one of the Distribution Statements B through F, in accordance with DoD Instruction 24 and the associated guidance document)
For awards with the Defense Federal Acquisition Regulation (DFARS) & Federal Acquisition Regulation (FAR) clauses listed below that do not specify NIST standards but require the safeguarding of CUI, an individual TCP will be required:
- 52.204-21 Basic Safeguarding of Covered Contractor Information Systems – This would be equivalent to tier 1 CMMC, a TCP may not be required if the contract only has this clause, and doesn’t include the other clauses
- 252.204-7008 Compliance with safeguarding covered defense information controls
- 252.204-7012 Safeguarding covered defense information and cyber incident reporting
- 252.204-7019, 252.204-7020, 252.204.21 Notice of NIST DOD Assessment Requirements and Contractor Compliance with CMMC.
Research compliance will also work with you to review any additional requirements, including establishing a Technology Control Plan (TCP) to ensure the CUI is appropriately managed.
Name | Contact | |
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Amanda Humphrey Director of Research Integrity & Export Controls |
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Jeff Seo AVP for Research Compliance |
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Lissette Gilster Export Control & Logistics Analyst |
They will work with you to either answer your questions or connect you with stakeholders in the University to help work through your questions.
Research Security FAQs
The NIH identified three areas of concern: diversion of intellectual property; peer reviewers inappropriately sharing confidential information on grant applications; and failure of researchers at NIH-funded U.S. institutions to disclose substantial resources from other organizations, including foreign governments. These concerns have been shared by other funding agencies.
The federal government is concerned that foreign talent recruitment programs may be used to acquire, legally and illegally, U.S. government-funded scientific research in order to dominate high technology sectors currently led by U.S. entities. As described by the FBI, these programs target individuals who are working in technological fields of interest to the foreign government, offering competitive salaries, state-of-the-art research facilities and/or honorific titles in an effort to encourage the transfer of ideas and intellectual property. The Thousand Talents Program and the Russian Federation’s Mega Grants are examples of foreign talent recruitment programs.
NSF: Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have a monetary value. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students. In-kind contributions not intended for use on the project/proposal being proposed also must be reported. Current and pending support information must be provided for this [proposal], 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.
NIH: Other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant [application]. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.). Other support does not include training awards, prizes, or gifts. Other support is requested for all individuals designated in an application as senior/key personnel-those devoting measurable effort to a project. Information on Other Support is not specifically requested for Program Directors, training faculty, and other individuals involved in the oversight of training grants since applicable information is collected in other sections of a training grant application. It is also not requested for individuals categorized as Other Significant Contributors.
If you are involved in or are invited to participate in a foreign program, you should obtain guidance from your college’s associate dean for research and Research Compliance.
However, classified and export-controlled projects will be subject to foreign national restrictions. It may be possible to employ certain foreign nationals on controlled projects after appropriate licenses and/or exemptions are secured. Please contact Research Compliance for more information on such cases.
The Department of Energy requires prior approval of all foreign national participation or access to DOE information, technologies or equipment, see DOE Order 143.A.
Finally, there may be cases where working with a student or postdoc might be considered a “foreign component,” if that student or postdoc is performing effort in a foreign country. NIH defines a foreign component as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”
- As “Other Support” because the externally funded individual is a “resource available in direct support of [your] research endeavors.” The NIH recently clarified that “all research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, … must be reported.”
- As a “Participant” in the progress report if the person worked on a project for more than a month in any given year (see 6.4 Section D – Participants). Additionally, the person’s “primary affiliation” is determined by where the work was done for the project: if the individual is affiliated with a foreign organization but worked on the award solely in the U.S., the “primary affiliation” is not foreign; if work was performed while outside of the U.S., the primary affiliation should be noted as foreign.
- As a “Foreign Component” if the individual performed part of the work while in your Northeastern lab, but also made a significant contribution to the project a from his/her home institution, or any other foreign location (e.g. collecting data at a foreign site, running samples on instrumentation there, and/or will be a co-author on publications arising from the grant).
Northeastern asks that all faculty notify their college dean should they wish to apply for or receive a talent award. The Dean’s office in coordination with Research Compliance will assess the risks and benefits of a specific faculty member’s participation in such a program.
As standard practice, NU-RES Administration will notify Research Compliance when these terms are included in a notice of award or contract. Research Compliance will reach out to the faculty to set up a discussion.
Ultimately, at this time, if the faculty member wishes to proceed, the University will be able to accommodate the DOE requirements, but coordination with the Office of Research Compliance will be required to document our assessments.
One or both of the following clauses will appear in your award notice from DOE (or via a subaward):
- Foreign National Access under DOE Order 142.3B, “Unclassified Foreign National Access Program”: states that DOE may request additional information on foreign nationals participating in the DOE project(s). Any foreign national that is from a country considered to be a State Sponsor of Terrorism is prohibited from participation until cleared by the DOE. It is not clear what information DOE may seek related to foreign national participants, but the University would be required to respond and provide the requested materials. Should you wish to include a foreign national on a project that includes this requirement, the Office of Research Compliance will reach out to you to develop a plan for compliance with this requirement.
- Export Control this clause defines export controls and reminds faculty that irrespective of the origin of any results or materials, if export control regulations require the institution to seek a license prior to export, then the recipient institution should do so. However, the clause also includes a section that states: “some of the results of the research conducted under this award may be restricted for proprietary reasons and not published or shared broadly within the scientific community”. Because this term implies that some of the results may be export-controlled, the Office of Research Compliance will reach out to you to develop a plan for compliance with this requirement.
Compliance Training
Responsible Conduct of Research (RCR) trainings are required for all PIs, PDs, Senior/Key Personnel, and Investigators whose research is funded by NSF or NIH awards, specifically T,F, and K series awards. Postdocs and students ( undergraduate and graduate) are also required to complete RCR training if they will be paid from the previously listed award types. There are five RCR disciplines: Physical Science, Biomedical, Humanities, Engineering, and Social and Behavioral. Those who are required to complete RCR trainings are only required to complete the training for the discipline that most aligns with his or her research.
Investigators may be subject to additional training based on the nature of their research, as required by federal regulation, university or sponsor policy.
Additionally, NU-Res hosts RCR workshops on the respective disciplines. Our department uses data available to us to reach out to those with the funding that requires these trainings so that we can provide proper notice of workshops available each semester along with registration information. We also provide a calendar on our website.
Last Updated on May 17, 2022