FAQs

Frequently Asked Questions

NU-RES Administration/Pre-Award

Can I see a sample R01 application and summary statement?
You can see a sample of a few different applications on the NIH website.

You can find the NU Facts sheet here.

How can companies apply for an EIN?
Companies can apply for an EIN on the IRS webpage.

How do I find an EIN number?
You can search multiple search engines such as EDGARMassachusetts Corporate SearchMelissa, or Google.

How do I submit a research proposal?
We are so excited that you are interested in applying for and managing research grants here at Northeastern University! Below is some basic information you will need to get you started on this exciting endeavor.

  1. 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.
  2. 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
  3. 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!
  4. Use either ePAWs and the sponsors submission portal, or our proposal submission application COEUS
  5. 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
  6. 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!

How do I write a research proposal?
There are several websites that offer basic proposal writing assistance, please visit here for a list of helpful sites.

How to Register in Grants.gov?
To apply for a grant opportunity using the Workspace, you need to be registered with Grants.gov. See the instructions on how to register. See the instructions on how to register here.

I will be collaborating with another institution. Do I need to submit to Northeastern’s IRB and the other institution?
If you are a member of the Northeastern’s faculty or staff, or a Northeastern University student, and you are the person responsible for the conduct of the study (PI), you must get Northeastern’s IRB approval to conduct your research regardless of where the research takes place. Investigators should contact the IRB office whenever collaborative research is occurring. Separate applications for each institution may be necessary; however, in order to avoid duplicate review, an IRB Authorization Agreement may be arranged with the other institution to establish one IRB as the designated IRB to review and approve the research.

Should I Contact a Program Officer Before I Apply for a NIH Grant?
Yes. Early in the planning stage of your project, we recommend you contact a program officer. You can find them by talking to colleagues or by checking out our websites. They are listed in section seven of our funding opportunity announcements (FOA). You can also search individual institute’s or center’s websites, or search for your area of science in RePORTER and see which program officers might be the right fit.

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.

What if I am conducting research with human subjects, such as clinical testing, surveys, human tissue studies, etc.?
If you are, be aware that Title 45 Code of Federal Regulations Part 46; defines a “human subject” as a living individual about whom an investigator obtains:

  1. data through intervention or interaction with the individual, (such as, interviews, surveys, clinical testing, or any other physical intervention or personal interaction), or,
  2. 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.

What if I don’t know the EIN? Will that delay the processing of my proposal or contract?
If you don’t know the EIN, the NU-RES Help Center will work with you/the other party to identify it. Your proposal or contract will not be delayed due to a missing EIN.

What if the external vendor is a foreign entity?
The IRS recommends for foreign entities complete the Form SS-4.

What is an Employer Identification Number (EIN)?
The IRS Employer Identification Number (EIN) is used to identify a business entity. It is also known as a Federal Tax Identification Number. Please see the video here to learn more about EIN.

What is Research.gov?
Users can prepare and submit full, research proposals in Research.gov.  Research.gov runs in parallel with existing FastLane proposal preparation and submission capabilities, so users can choose to prepare and submit full, research proposals in Research.gov or in FastLane. Click here for more details on how to register and add roles.

What is the Fly America Act?
The Fly America Act is a federal regulation that requires the use of U.S. carriers for travel that will be reimbursed from federal grants and contracts. Travelers who will be reimbursed from federal grants and contracts can also use foreign air carriers with code-sharing agreements with U.S. flag carriers.

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.

Where can I find the NSF Proposal and Award Policies and Procedures Guide (PAPPG)?

Where can I get the NU Facts sheet?
Visit our Policies & Guidelines webpage.

Where do I find Statistical information on the University so I can complete my application?

Who can help me apply for a grant or contract from a federal, state, or foundation sponsor?
Northeastern Research Development Office can assist you in getting started in applying for a grant. Below is some basic information you will need:

  1. First, are you eligible to be a Principal Investigator?
    • All NU faculty are automatically eligible, all others must request temporary PI status.
  2. Choose a funding opportunity
  3. 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.

Who can help me apply for funding or negotiate a sponsored research agreement from industry or corporation?
If you would like to apply for funding or negotiate a sponsored research agreement from industry or corporation please contact Eva Pasadas via email at Eva Pasadas or via telephone at 617-373-5316.

Who can help me negotiate a Material Transfer Agreement (MTA), Non-disclosure Agreement (NDA), Confidential Disclosure Agreement (CDA), or Data Rights Agreement?
If you would like to negotiate a CDA, NDA, MTA, or Data Rights Agreement please contact Eva Pasadas, or via telephone at 617-373-5316.

Why do I need to provide an EIN for the external vendor?
This is an internal control for NU-RES in verifying external parties, so we need it regardless of whether there is a dollar amount associated with the contract/agreement.

NU-RES Finance/Post-Award/Compliance

Allowable and Unallowable Expenses

Can alcoholic beverages be charged to a federal award under any circumstances?
No. There are no instances when alcoholic beverages would be either appropriate or allowable unless the awarding agency specifically provides approval in the award notice.

Do I need to get approval for foreign travel charged to a grant?
Before making travel arrangements please examine, in collaboration with the Northeastern University Research Enterprise Services (NU-RES), the terms of your contract or grant award regarding foreign travel for which you plan to claim reimbursement using funds from a sponsored award. NU-RES should be consulted well in advance of booking arrangements. For additional information please review the Northeastern University Travel Policy.

How can a PI delegate some administrative tasks in eRA Commons?
Did you know that the eRA Commons allows principal investigators the ability to grant permission to have others at their institution help with some grants administration tasks? You might want to consider whether delegating any or all of the following tasks is right for you.

How can I see a summary of the Award information (attachments, etc.)?
Coeus Awards Module in Coeus Lite is available for users to see a summary of the Award information, and to have access to attachments from all modules, including ePAWs. Users will now be able to search for department Awards, glance at a summary view of the entire Award, and view all related project documents. See the quick card for guidance on how to use My Awards.

Is there a special form for processing participant payments?
Yes, please use the attached D-PAY form, which includes a checklist to assist you in providing the necessary documentation.

Participant Costs Appendix

Should I issue a subcontract or a vendor agreement to an external institution?
Before requesting a subcontract, please determine if it is more appropriate to issue a subcontract or vendor agreement. For more information visit Subawards on your Proposal as well as Subawards under Manager Project.  If in doubt please contact via email NU-RES@northeastern.edu.

What are participant support costs?
Costs associated with individuals who participate in research and sponsored programs are known as participant support costs – these include incentive payments participants in human subjects research studies as well as participants in training programs and conference grants; costs include stipends, allowances and other related expenses. See the guidance documents for more information.

What Banner subcodes are used for participant support costs?
  • 78010 Study Subject Payments/Incentives
  • 74600 Participant Support Costs – Stipends
  • 74601 Participant Support Costs – Other

Where can I find guidance on determining the difference between an allowable/unallowable costs?
The NU-RES website has a guide for Costs for Sponsored Agreementsthat gives an overview and lists a matrix of commonly found allowable and unallowable costs.

Who can help me manage my grant or contract?
Your Grant Officer or Sponsored Account Analyst is always available to help you manage both non-financial and financial related aspects of your grant.

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.

How do I access my award in Banner?
SSB and E-print are the tools to view your award in Banner, information on interpreting both can be found on the Banner Finance Help page via your MyNEU Services and Links tab. In addition there is a Banner Finance for Research Tip Sheet available to assist you. In the event you are new to the University it’s important to note that Banner Finance access to view your awards isn’t automatically granted, it must be requested. The instructions and forms to request Banner Finance access can be found on the NU-RES Finance Resources page.

How do I get Banner or Cognos Access?
For Banner, in some cases, you may already have access based on your position and role within your department. Access to Cognos must be requested. In the event you that you do not have access to Banner Finance, you can request access through the Budget Office. The instructions and forms to request Banner Finance access can be found on the Budget Office website under Links, Forms and Lists. General information, including the Banner Access form and the Cognos Access form, can be found on the following links:

For Cognos training, visit the Cognos Training Calendar and sign up for a session.

What is the Daily Budget Statement-Inception to Date e-print report and how do I interpret it?
The Budget Statement-Inception to Date E-print report (FZRB090) is an ad hoc report that is run monthly and can be accessed through Banner e-print reports. This report contains information such as total budget, expenses, and available balance from the start of your award through the month selected. The following link displays a Budget Statement and provides information on how to interpret the report.

What tools are in place to help me manage my budget?
Self Service Banner (SSB), Banner e-print reports, and Cognos are the tools in place to help you manage your research budget. Information on interpreting both SSB and e-prints can be found on the Banner Finance Help page via your MyNEU Services and Links tab. In addition, there is a Banner Finance Research Tip Sheet and E-print Tip Sheet available to assist you.

Closeout Process

How do I close out my award?
Closing out your award is a multi-step process involving NU-RES, the PI, and the Department Administrator. For more information visit the Closeout Project page.

What do I need to do when closing out my grant?
Closing out your award is a multi-step process involving NU-RES, the PI, and the Department Administrator. The formal process is initiated by NU-RES once your award is within approximately 60 days of ending. A checklist of action items and an email notification is sent to the PI and Department Administrator. All final expenditures must be posted as an activity within the project period/ end date. Future commitments must be removed and/or adjusted to other Funds as appropriate. Sub-recipients will need to Final Invoice NU typically 60 days prior to the end date. Procurement cards must be canceled and cost-sharing must be expended within the project period.

Cost Sharing

What is cost sharing?
Research sponsors may require NEU to share the cost of research projects. Therefore, cost-sharing is that portion of a project or program cost that is not reimbursed by the sponsor. In some instances, in-kind contributions can qualify as cost-sharing. To ensure that NEU has fulfilled its cost-sharing commitment made as a condition of an award, cost-sharing expenditures are recorded in a separate Index /Fund. Some sponsors also require that NEU’s cost-sharing expenses be included on all invoices for reimbursement. All federal cost-sharing agreements are legally binding and subject to audits and failure to provide the level of the commitment could lead to the return of award funds and /or termination of the project. NEU funds the overhead cost associated with cost-sharing commitments.

Cost Transfers

How can I get expenses that were mistakenly charged to my award transferred to the correct Index?
Federal sponsors closely scrutinize cost transfers. Frequent or untimely transfers leave the principal investigator open to questions regarding lax oversight or inappropriate spending of award funds. Therefore, the principal investigator should frequently review the account activity and identify in a timely fashion any inappropriate charges to an award. However, mistakes happen. If you do identify errors on your account, you’ll need to complete a Journal Voucher. Use the form to describe and justify the need for any transfer of expenses – please refer to the Cost Transfer Policy for a detailed overview. It is not acceptable to request a transfer simply to use funds remaining on an award about to expire. Generic descriptions, such as “Due to administrative oversight,” are not acceptable. All cost transfers must be completed within 90 days of the original transaction. Exceptions must be discussed with Research Administration and Finance. Consideration of the issue will be given, but approval is not guaranteed. Repeated requests for transfers could require a written action plan detailing procedures to be implemented to ensure more accurate record-keeping.

Facilities and Administration Costs

What are F&A costs?
F&A stands for Facilities & Administrative costs (sometimes called IDC, Indirect Costs). These are actual costs incurred by the university in support of sponsored activities that cannot be identified readily and specifically to a project. The rate used by Northeastern is negotiated with the federal government. Among other expenses, it includes the cost of departmental and central administrative support, building and equipment use, and library services.

What is Northeastern’s current Indirect Cost Rate?
See the Northeastern University current FY Rate agreement on the Policies and Guidelines page for details.

General

Don’t all awards come with a check attached?
Most awards, in fact, are simply authorization for the faculty to begin incurring expenditures in furtherance of project goals. NU-RES is responsible for requesting funds in accordance with sponsor guidelines in order to receive reimbursement for expenses incurred by the project.

Progress Reporting

When is NIH RPPR required, and how do I calculate it?
In accordance with Section 8.1.1.1 of the NIH Grants Policy Statement, recipients of NIH grant awards under the SNAP mechanism are required to report, as part of the grant’s progress report, whether the estimated unobligated balance (including prior-year carryover) is expected to be greater than 25 percent of the current year’s total approved budget. Visit the NIH RPPR Estimated Unobligated Balance webpage to learn more.

When is NSF RPPR required?
NSF PIs must complete a support section as part of the RPPR. As a reminder, the section should only be completed if the funding support is provided from a source other than award being reported on. PIs should not list effort on other awards, this is not the same as other support. See RPPR Format For Interim Project Reporting. Note that these instructions should be followed until further notice.

Salary-Related

Can I charge clerical or professional administrative salaries to my federally funded research grant?
Federal regulations discourage the charging of salaries for administrative and clerical staff as a direct cost to a project. OMB Uniform Guidance states that administrative and clerical staff should normally be treated as Facilities and Administrative costs and not as a direct cost.

When is NSF RPPR required?
For grant and contract funded research, the Summer Salary is limited to 3.2 months or 40% of the faculty member’s academic year salary (Northeastern University’s academic year is generally 8 months). To calculate summer salary simply divide your academic year salary by 8 and then multiple it by 3.2 (or the portion of the summer available to you after teaching, other duties, and/or vacation time have been accounted for). Please note that certain external sponsors may have their own policies regarding summer salary payments to faculty and/or principal investigators.

What is a faculty buyout?
A faculty buyout occurs when an effort is conducted during the academic term (generally September 1st through April 30th) and charged to a research grant or contract. Consequently, academic term salaries shall not be augmented either in rate or in the total amount for research performed during the academic term. When part of a faculty member’s services are to be charged as project costs, it is expected that the faculty member will be relieved of an equal part or all of his or her regular teaching or other obligations.

What is Summer Salary?
Summer salary is compensation paid to faculty that perform research on a grant or contract during the summer months of May, June, July, and August.

Time and Effort Reporting

What is a time and effort report?
Federal regulations require that Institutions maintain an effort activity reporting system. OMB Uniform Guidance requires faculty and staff involved in federally sponsored research to report activities (e.g. sponsored projects, instruction, administration) for which they are compensated. Under this system, the distribution of salary and wages by the Institution will be supported by certification reports which are required to be signed by the Principal Investigator (PI) or responsible official.

Why does the Principal Investigator need to review and certify the report and return it to NU-RES?
The Principal Investigator (PI) is ultimately responsible to ensure that all salary charged to the externally funded project is commensurate with the employee’s effort on the project. The PI is required to sign the report and return it to NU-RES in a timely manner where it is kept on file for audit purposes.

Travel

What are the travel restrictions on my grant?
Travel is restricted to the personnel working on the Research Project, whether it is employees or non-employees. In general, travel should be done within the sponsor-approved budget and guidelines. Federal guidelines prohibit certain expenditures such as alcohol and entertainment.

Why do I need to get prior approval for foreign travel?
The federal government has increased oversight with regard to travel to foreign countries in connection with sponsored research. All foreign travel using federal funds must follow certain criteria such as the Fly America Act and other A-21 requirements. The following link will give you information pertaining to Northeastern University’s policy on Foreign Travel: Policy & Procedure on Foreign Travel in Connection with Sponsored Research.

Compliance

Export Control

What are export controls?
Export controls regulations are federal laws and regulations that prohibit and restrict the release of unlicensed export of certain commodities, controlled technologies, information, and services to foreign nationals foreign countries for reasons of foreign policy and national security. Export controlled items may include (but are not limited to) equipment, software code, chemical and biological materials, and technical data. These laws and regulations, which include international sanctions programs, also restrict activities within certain countries and with designated institutions, entities, and individuals, even if no controlled items are involved.

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.

What do export controls regulate?
The export control regimes collectively cover items, information, and software considered to be important to U.S. national security and foreign policy. “Items” include products, equipment, devices, organisms, components, materials, etc. Additionally, these regulations also control equipment, materials, information, and software necessary for producing, developing, and using controlled items. Further, restrictions are also placed on certain countries with comprehensive embargoes, entities, and individuals as recipients of exports.
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.

What don’t export controls regulate?
Research in economics, history, languages, linguistics, literature, mathematics, music, philosophy and political science is outside the purview of export control regulations. However, individuals working in these areas may still be using export-controlled items (e.g., computers with encryption software).

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
  • .

What kinds of activities potentially trigger the need for an export license?
  • 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

Is any prepublication review by a research sponsor permitted under the fundamental research exclusion?
An award requiring “review and approval” makes the fundamental research exclusion inapplicable, since this language contemplates the potential denial of approval to publish.

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.

How do I know if a foreign national would be subject to the “deemed export” rule?
Any foreign national is subject to the “deemed export” rule, including all persons in the U.S. as tourists, students, business people, scholars, researchers, technical experts, airline personnel, salespeople, military personnel, diplomats, etc.

The rule does not apply to a foreign national who is considered a “US Person” by virtue of:

  1. permanent resident status (i.e., a “green card” holder); or
  2. U.S. citizenship; or
  3. status as a “protected person” under U.S. law (i.e., refugees, asylees).

How is a foreign national citizen who has obtained permanent residence status or dual citizenship treated for export control purposes?
It depends on which regulations apply to the circumstances. Under Bureau of Industry and Security (BIS) guidance, only the latest citizenship or legal permanent residence is considered. The Directorate of Defense Trade Controls (DDTC), however, takes into account all of a person’s citizenships and country of birth and imposes the controls that correspond to the most restrictive citizenship.

Does a Northeastern professor planning to travel to a foreign country to work in a research laboratory need an export license?
Application abroad of personal knowledge or technical experience acquired in the U.S. constitutes an export of that knowledge and experience that is subject to export control regulations. Therefore, in certain technical areas, the professor may need to obtain an export license or otherwise qualify for a license exception, prior to working in the lab.

Do export controls apply even if there is no external funding sponsoring the activity?
Yes. Export control regulations apply regardless of the funding source.

I am planning an international research trip and plan to bring university equipment, including some supplies and a laptop. Do I need to worry about export controls?
Yes. Research Compliance will need to evaluate your itinerary (including any stop overs), the supplies and materials you plan to take, as well as any entities or persons you plan to collaborate with.

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.

I would like to explore the possibility of travelling to or collaborating with a researcher in a comprehensively embargoed country. What do I need to do?
Contact Research Compliance at researchcompliance@northeastern.edu well in advance of the planned research activities or travel. Research Compliance will perform a review of the activities and provide guidance and advice on next steps.

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.

What is the Fundamental Research Exclusion/Exemption (FRE) and how do I know if it applies?
National Security Decision Directive (NSDD) 189) defines fundamental research as “basic and applied research in science and engineering where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research, the results of which are restricted for proprietary reasons or specific US Government access and dissemination controls.”

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.

I am planning to explore a new research relationship with a non-US entity. What steps should I take to ensure I am not violating export control provisions?
Before you exchange technical information and explore specific research projects, please contact Research Compliance at researchcompliance@northeastern.edu. Research Compliance will help you screen the entity to ensure there are no restrictions placed on that entity by the U.S. government. In addition, Research Compliance will confirm if you should expect any technical information to be subject to export controls as the relationship progresses.

How do export controls relate research security?
Export controls are put in place to protect the U.S. economy and security. Often research security violations are associated with technology that would be controlled by either the EAR or ITAR regimes. Northeastern has several resources available on our Research Security & Transparency pages.

Where can I go to learn more about export controls?
The Export Control Compliance Manual and Decision Tree can be found on the Research Compliance website. If you have additional questions, please contact Research Compliance to set up a briefing based on your specific circumstances or concerns.

Whom should I contact about Customs Entry processing for equipment or supplies imported into the U.S. related to my research?
Please contact Dolliff & Co., Inc. for assistance with import/export issues. They hold a Customs Power of Attorney for Northeastern and can help with any of your shipments. Call Stuart Eldridge at 617-561-0900. To save time, when you are ordering internationally, instruct the shipper to do these three things: (1) consign the shipment to Northeastern University; (2) notify Doliff & Co.; and (3) fax copies of shipping documents to Doliff $ co. You will be subject to fees associate with Customs Entry processing, generally a $125 entry fee, local delivery charges, and airline terminal charges. In some cases, there will need to be a bond (if the item is valued >$2000). Stuart Eldridge can help with all of that. Note that you will need to use a Northeastern Purchase Order for your transaction. This process is only available for university-approved business.

International Engagement

Why has Northeastern implemented the new Policy on International Engagements?
This Policy has been implemented in response to concerns raised by the U.S. federal government related to national and research security. An overview of those concerns and the evolving disclosure requirements is located on the Research Security & Transparency page.

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.

What is considered an international engagement for the purpose of this policy?
All international engagements totaling 14 or more days will require approval. The only exception is any engagement undertaken directly on behalf of Northeastern in the scope of your employment with the university, such as teaching a class abroad as part of NU-In.

I am attending an international conference. Do I need to request approval?
No, you do not need to seek approval to attend an international conference. However, 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 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.

I have been invited to give a talk at an international university and will spend a day or two visiting some potential collaborators at the university. Do I need to request approval?
No, you will not need to see approval through this process for such a short-term visit. However, you will need to screen the entities 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).

I am engaged as a consultant, sitting on a Scientific Advisory Board for a global company. I have received approval under this process, but is there anything else I should do?
Yes, we recommend that you also provide the company with a copy of the University’s Consulting Agreement Addendum. It will make it clear to the company that your primary employment and obligations lie with Northeastern and explains how intellectual property rights may be assigned. Many universities offer a similar addendum to their faculty. Asking to include this addendum is consistent with industry practice and most companies will accept it without additional discussion.

How long will the approval process take?
Overall, the process should take between 3-10 business days if no translation is required for review of related documents. The timeline for review will be flexible depending on the type of proposed engagement, the risks associated with the engagement and the need to review any contract documents associated with the engagement, including time to translate the materials.

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.

What information will I need to provide?
Research Compliance is asking for enough information to help us efficiently assess each case. We will need to understand, at a minimum, the nature of the engagement, any remuneration proposed or received, the duration, the parties and locations involved, and any accompanying documentation.

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.”

Who is involved in the process?
The following offices are involved in the process (goes in order through the process):

  • 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.

What can I do to ensure my proposed engagement is processed quickly?
Please provide as much information as possible. We know that some information may not be available at the time you seek guidance, but do your best to answer the intake questions, as that will greatly expedite the process.

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.

My engagement was approved. What other actions will I need to take?
If you are a faculty member with active research proposals and/or active, externally funded research, you may need to update your biosketch, CV, current and pending or other documentation to support your compliance with applicable federal funding agency policies. Research Compliance will include information on this step in their recommendation and will follow up with you upon acceptance of the engagement to either help you with updating disclosure information, and/or connect you to NU-RES administration, who will help you in communicating to the agencies.

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.

Is there an appeal process?
Northeastern will request that a faculty member decline an external engagement in certain circumstances. Such circumstances include, but are not limited to: government-wide prohibitions or restrictions on doing business with the specific entity or individuals; government-wide sanctions related to a specific country (i.e., a proposal to do business in [sanctioned country such as North Korea]); or other circumstances that may pose a legal or reputational risk to Northeastern.

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.

What is the Consulting Agreement Addendum and when should I use it?
The Consulting Agreement Addendum is a tool recommended by the University when engaging in external consulting arrangements. It can be used any time you are engaging in an external activity, whether domestic or international. The intention is to make employment and reporting obligations clear to all parties. Several universities offer something similar.

What if I fail to request approval for an international engagement?
Faculty members who fail to report an international engagement put themselves and the institution at risk. As publicized in recent news coverage, inappropriate international engagements by faculty can result in law enforcement actions taken against individuals, and fines and/or sanctions imposed on universities.

How should the short-term (14-day) exception be calculated?
The calculation the university uses to confirm a short-term engagement is: 14 days x 8 hours a day = 112 hours a year during any 12-month period. Even if the pending international engagement is for less than 14 days you are welcome to submit inquiries through the Intake Form. We would be happy to provide feedback and guidance on any risks presented.

I have a proposed International External Engagement that involves committing a measurable amount of effort, but I will not be receiving any salary support. Do I need to report this to any federal funding agency from whom I receive support?
Federal funding agencies (i.e. NIH and NSF) require that all effort, regardless of salary support, be disclosed in your Other Support / Current & Pending documentation in the format of person months. In addition, if the outside institution has also provided a formal appointment, please list the appointment in your Biosketch. These requirements are not tied to salary support, it is the commitment of a measurable amount of time and effort that requires disclosure. We’ve developed a Disclosure Matrix that references federal requirements, as well updated resources, as they are available.

CUI

What is Controlled Unclassified Information (CUI)?
CUI is defined as federal non-classified information that the U.S. Government creates or possesses, or that a non-federal entity (.g. Northeastern) receives, possesses, or creates for, or on behalf of the U.S. Government, that requires certain information security controls to safeguard. CUI may include research data and other project information that a research team receives, possesses, or creates during the performance of a contract funded by the federal government.

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)

How do I know if I’m working with CUI?
Contract solicitations will outline expectations for contract recipients, including any technology standards. Most frequently, the solicitation will require a system security plan which demonstrates an implementation of NIST SP 800-171.

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.

Will Northeastern accept and manage CUI clauses?
Yes, Northeastern will accept and manage contracts containing CUI requirements. In order to manage the CUI process appropriately, all personnel working with CUI will require a special instance of Microsoft 365, called the Government Cloud Computing (GCC) instance. Research compliance and ITS will work together to facilitate setting up the accounts.

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.

Who can I go to for additional questions or assistance?
Name Contact
Amanda Humphrey Amanda Humphrey
Director of Research Integrity & Export Controls
Jeff Seo Jeff Seo
AVP for Research Compliance
Lissette Gilster 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

What is the basis for concerns regarding research security or “foreign influence” in the academic setting?
The FBI and other federal government agencies have expressed concern that some foreign actors, particularly foreign state adversaries, are seeking to acquire U.S. academic research and information illicitly or illegitimately.

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.

Do these issues apply only to NIH grants?
No. The Department of Defense, the National Science Foundation, and the Department of Energy have also issued statements regarding this issue. Given the current U.S. Government focus on this issue, we anticipate similar guidance, statements, or requirements will be forthcoming from other funding agencies.

What are “foreign talent recruitment programs” and why is there concern about them?
Foreign Talent Recruitment Programs are efforts directly or indirectly organized, managed, or funded by a foreign government to recruit science and technology professionals or students (regardless of citizenship or national origin, and whether having a full-time or part-time position).

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.

What is the federal government doing to address concerns about foreign talent recruitment programs?
At present, there is no generally applicable U.S. legal or regulatory prohibition on participation in a foreign recruitment program. However, the Department of Energy (DOE) recently issued an internal directive that prohibits DOE employees and contractor employees from participating in certain foreign talent recruitment programs to ensure the protection of U.S. competitive and national security interests as well as DOE program objectives. Similarly, NSF announced a policy prohibiting NSF personnel and Intergovernmental Personnel Act (IPA) details to NSF from participating in foreign government talent recruitment programs due to risk concerns.

What steps must I take in response to these concerns?
Refer to the University’s Agency Matrix for Disclosures summarizing disclosure requirements. Make your sponsors aware of your collaborations and interactions with foreign entities that support or contribute to your research program; federal agencies are expecting a thorough account of touchpoints between your research program and any foreign entity. For an explanation of the various requirements imposed by federal sponsors, please check the Research Security webpage maintained by NU-RES Research Compliance.

What do I need to update to prepare for future proposal and progress report submissions?
This area is rapidly evolving. NIH and NSF have a lot of information available on their websites and the Department of Energy and the Department of Defense has also alluded to forthcoming changes that will be necessitating changing some requirements in both proposals and progress reports.

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.

How does this affect my foreign collaborations and/or foreign students and visitors in my lab?
Northeastern University believes that global engagement, by continuing to expand our international campus network, bringing international scholars to any of our campuses, and encouraging our scholars to collaborate internationally, enriches the student experience and brings diverse knowledge and experiences that enhance our scholarship. However, consistent with federal agency guidance you should provide information to your federal funding agencies about all foreign collaborations and ensure that all foreign research visitors are screened through Research Compliance, confirming that there are no restrictions upon hosting such visitors. That said, there remains considerable concern regarding research security.

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.

Do I need to disclose the work of my graduate students if they are foreign nationals?
In most cases, there is no reason to disclose the participation of foreign students or postdocs on sponsored research, especially if all such work will be performed in the U.S. There are no foreign national restrictions on “Fundamental Research” projects.

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.”

I have a visitor in my lab who is supported by his/her home foreign institution. S/he is not funded by any of my federal grants. Do I need to account for this visitor in proposals or progress reports? If so, how?
We do not have specific guidance from all sponsors on this topic, however, per NIH guidelines, this person’s work on the project should be documented as follows:

  1. 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.”
  2. 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.
  3. 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).

I am interested in participating in a foreign talent program. Am I allowed to? Who should I talk to?
It is important to note that the federal government does not have a blanket prohibition in place with respect to extramurally-funded researchers participating in talent programs. However, many federal agencies are emphasizing the importance of clear disclosure. Depending on the program, faculty may be asked to limit or eliminate their participation in a specific 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.

I recently received an award notice from the Department of Energy (DOE) that includes export control terms and terms about foreign national participation. What do I do?
DOE recently began to include two provisions in their award notices and contracts that will require additional follow up with the Office of Research Compliance.
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):

  1. 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.
  2. 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

I am involved with research studies at Northeastern University (as an investigator, staff, or student). Which trainings are required of me?
Under university policy, Northeastern requires a few sets of trainings depending on the source of research funding. Public Health Service regulations require Financial Conflict of Interest (FCOI) training for PIs, PDs, Senior/Key Personnel, and Investigators. FCOI training is only required of postdocs and students (undergraduate and graduate) if the designated investigator is subject to PHS regulations.

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.

How do I go about completing the trainings that are required of me?
Northeastern University has partnered with The Collaborative Institutional Training Initiative (CITI Training) to host required courses. This program includes the FCOI trainings, RCR trainings, and the Social and Behavioral Research Stage 1 course. The associated course numbers are listed on the CITI training page, in addition to instructions on how to register with CITI to begin your courses.

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.

Who is responsible for record retention surrounding required trainings?
Foreign Talent Recruitment Programs are efforts directly or indirectly organized, managed, or funded by a foreign government to recruit science and technology We ask that any faculty, staff, or student who has completed training please save their Certificate of Completion. We also advise that it is best practice for the College or the PI to keep a copy of the certification for any staff or students paid from the respective grants.

How often do I need to complete required trainings?
Training cadence will vary based on a variety of factors, including federal regulation, university or sponsor policy. Please contact researchcompliance@northeastern.edu if you have questions about research-related trainings.

Last Updated on September 28, 2021