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Announcements Compliance, Integrity & Safety

The Human Research Protection Program professionals provide guidance and support for students and staff developing submissions for IRB review. They can provide guidance on: completing online submission forms; drafting recruitment materials and describing recruitment processes; drafting consent materials; describing data management processes; and collaborations with other entities. Make an appointment using the Support Appointment Form

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Announcements Compliance, Integrity & Safety

A new Office of Research Security and Export Controls (ORSEC) is on the horizon within the Office of Research. Under the Office of Research Integrity and Safety umbrella, ORSEC will continue its export controls and economic sanctions compliance mandate while responding to new and evolving federal guidelines related to research security requirements for federally funded research.

ORSEC also will further shepherd compliance with heightened security and safeguarding requirements when the institution performs certain restricted research projects. As UGA steps up its sponsored research activity with federal “mission agencies” such as the Department of Defense, ORSEC’s responsibilities will become even more important.

The establishment of ORSEC is driven mainly by the research security requirements as outlined in National Security Presidential Memorandum-33 and associated agency implementation guidance. These new federal mandates will require the development of a formal research security program, applicable across research funded by all federal agencies. The research security program will include elements of cybersecurity, foreign travel security, research security training, and, where appropriate, export control training. Additionally, ORSEC will work to ensure that research requiring heightened safeguarding meets federal requirements for safeguarding controlled unclassified and classified information. Marty Bink serves as the facility security officer and the director of defense and secure collaborations in the Office of Research. In his facility security role, Bink will work closely with the ORSEC director as facility security responsibility transitions into that office.

ORSEC will also work closely with Gene Pope and the Office of Conflicts of Interest Review and Management regarding disclosure and reporting obligations mandated in NSPM-33 related to conflicts of interest, conflicts of commitment, and outside activities and affiliations.

More information, including an updated website, an outreach and education effort, and new policy or process, will be communicated to the research and university community over the coming months.

Starting May 23, Dan Runge will serve as the director of ORSEC. Dan has worked in research compliance at UGA since 2014. He is a member of the Association of University Export Control Officers and earned a bachelor of science from Kansas State University, a law degree from the University of Kansas, and a master of laws in international law from the University of San Diego. Runge was a prosecutor when he practiced law in Kansas.

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Announcements Compliance, Integrity & Safety

Attention human research investigators: We recognize and value UGA investigators’ experience and expertise in conducting research projects. Further, we understand the demands on researchers’ time, and we strive to create systems and infrastructure that provide a high level of research project management support. However, the PI is ultimately accountable for ensuring that individual research projects meet all reporting and approval requirements. While the IRB portal is programmed to send courtesy reminders at 90, 60 and 30 days prior to a study’s expiration date, this system does not replace the responsibility of PIs to be aware of the approval period for research studies.

We strongly urge investigators to have multiple tools and safeguards to ensure that they meet regulatory and institutional requirements pertaining to continuing review and maintaining approval of human research projects. Setting up calendar reminders for 30 days prior to study expiration is one possible method.

Please remember that all human research procedures related to the approved project must stop when approval expires until a new approval period is granted. When research activities are complete, the PI is responsible for closing the project in the IRB portal, even if the project was for a student’s thesis or dissertation.

Please contact the Human Subject Office at IRB@uga.edu or 706-542-3199 if you have any questions about continuing review and expiration of IRB approval. More information is available in our Policies and Procedures and on the Human Research Protection Program website.

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Announcements Compliance, Integrity & Safety

The U.S. government imposes comprehensive economic sanctions and trade embargoes on Cuba, Iran, North Korea, Syria and the Crimea, Donetsk, and Luhansk regions of Ukraine. These restrictions limit nearly all imports and exports of technology, goods and services involving those countries. Services are very broadly defined and include prohibitions on participating in academic conferences in Iran and tourist travel to Cuba, for example. Travel to North Korea by U.S. citizens is, for all intents and purposes, prohibited.

Additionally, the U.S. has recently subjected Belarus and Russia to significantly expanded export controls and economic sanctions. While not comprehensively sanctioned, both countries are subject to significant controls on the import and export of technology, goods,and services. 

China and Venezuela are also subject to heighted controls on end-users in those countries. 

It is particularly important that activities involving these high-risk countries receive export control review. UGA personnel may contact Dan Runge, in the Office of Export Control, at drunge@uga.edu or 2-4188 to discuss travel, shipping and activities involving these countries.

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Announcements Compliance, Integrity & Safety

The Office of Export Control can provide in-person or video conference training for international shippers on compliance with export controls and economic sanctions. Details about export control training are available here. University personnel that engage in international shipping are strongly encouraged to complete the “Export Compliance for International Shipping” CITI module available via the Professional Education Portal (PEP). The CITI modules are available by searching for Export Compliance in the PEP search bar. 

All university personnel engaging in international shipping on behalf of UGA should request review of international shipments by the Office of Export Control prior to shipment. Anything you ship abroad is considered an export. Export shipments of equipment, tools or research materials, for example, may be submitted for review via the “International Shipping Export Control Review” form. Further details about international shipping are available here

Please contact Dan Runge, in the Office of Export Control, at drunge@uga.edu or 2-4188 if you have questions or concerns. 

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Announcements Compliance, Integrity & Safety

In response to the change in UGA RIF requirements, the Office of Postdoctoral Affairs has revised its policy and guidelines for postdoc appointments and terminations.

In addition to no longer requiring an RIF for grant-funded postdocs, units now have two distinct options for postdoc appointments: defined term and open term. Faculty/units can choose which best suits their needs based on the nature of the funding available. The defined-term option requires an up-front defined end date and formal continuation letters, and has less notice requirement at the time of separation, while the open-term option does not require a defined end date or formal continuation letters, but requires additional notice at termination (and may be subject to RIF if the position is state funded). 

Details of these changes can be found on pages 3 and 4 of the updated UGA Policy for Postdoctoral Appointments, found here. Updated templates for both defined-term and open-term offer letters can be found here and must be used for all new postdoctoral appointments effective April 11, 2022.  

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Announcements Compliance, Integrity & Safety

The U.S. Department of Commerce has recently added multiple foreign universities and affiliated labs and other research centers to either the Unverified List or the Entity List. Multiple foreign universities have been previously listed and remain listed. These designations restrict, and may prohibit, certain interactions the University of Georgia and its employees may have with the designated institutions and individuals affiliated with those institutions.

The Office of Export Control, and others on campus, engage in “restricted party screening” related to many institutional interactions and agreements, such as in Sponsored Projects, and International Initiatives and Immigration Services in the Office of Global Engagement. UGA employees engaging internationally should be aware of these lists and contact the Office of Export Control prior to engaging in formal or informal relationships or collaborations, or providing services to ensure the foreign institution is not restricted.

The Office of Export Control maintains a list of restricted foreign universities on its website, but this list is not as up-to-date as utilizing the university’s “restricted party screening tool,” Visual Compliance. In addition to universities and research institutes, these lists contain individuals and entities, including multinational corporations such as Huawei and Gazprom. Please contact Dan Runge at drunge@uga.edu with questions or to set up a Visual Compliance account. 

Feb. 8, 2022, additions to the Unverified List

Hunan University, State Key Lab of Chemo/Biosensing & Chemometrics

Southern University of Science and Technology, Department of Mechanical and Energy Engineering

Dec. 17, 2021, additions to the Entity List: 

Academy of Military Medical Sciences and multiple affiliated research institutes

Nov. 26, 2021, additions to the Entity List: 

Hefei National Laboratory for Physical Sciences at Microscale, a.k.a., the following two aliases: National Research Center for Microscale: and Microscale National Research Center

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Announcements Compliance, Integrity & Safety

Before agreeing to provide an international sale or service, product, or international shipment, UGA personnel should contact the Office of Export Control to request review of the transaction. This review will ensure an export license is not needed for the provision of the service or international shipment and include a due diligence review of the end-use and end-user at the foreign destination. 

The Department of Commerce has taken export enforcement actions, including imposing monetary settlements, against U.S. academic institutions for unlicensed export of strains and recombinants of animal pathogens to non-U.S. research institutions as well as for shipments of basic research equipment to embargoed non-U.S. research institutions. 

Detailed information about International Shipping is available here and a list of export controlled items, software, and technology is available here. UGA employees also have access to the university’s “restricted party screening tool,” Visual Compliance.

Please contact Dan Runge at drunge@uga.edu to begin due diligence.  

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Announcements Compliance, Integrity & Safety

The National Science Foundation (NSF) released an updated Proposal and Award Policies and Procedures Guide (PAPPG) on June 22, 2021. The new PAPPG is effective on October 4, 2021. NSF requires the use of an NSF-approved format to prepare Current and Pending Support.

Current and pending support information must be separately provided through use of an NSF-approved format, for each individual designated as senior personnel on the proposal.  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 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 that have associated time commitments also must be reported.

Current and pending support information must be provided for the proposed project, for ongoing projects, and for any proposals currently under consideration from whatever source irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.  This includes, for example, Federal, State, local, foreign, public, or private foundations, non-profit organizations, industrial or other commercial organizations, or internal funds allocated toward specific projects.

NSF updated Proposal and Award Policies and Procedures Guide

FAQs on Current & Pending Support (nsf.gov)

https://www.nsf.gov/bfa/dias/policy/disclosures_table/jan2022.pdf

NSF-Approved Formats for Current and Pending Support

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Announcements Compliance, Integrity & Safety

On Dec. 20, 2021, the Department of Energy issued an interim conflict of interest (COI) policy that addresses both financial and organizational conflicts of interest, which will be incorporated in and made enforceable through the Special Terms and Conditions for DOE financial assistance awards. The interim COI policy establishes standards that provide a reasonable expectation that the design, conduct, and reporting of projects wholly or in part funded under DOE financial assistance awards (e.g., a grant, cooperative agreement, or technology investment agreement) will be free from bias resulting from financial conflicts of interest or organizational conflicts of interest. As used in this announcement, reference to DOE includes both DOE and the National Nuclear Security Administration (NNSA).

The interim policy requires each Investigator who is planning to participate in the DOE award to disclose the Investigator’s significant financial interests (and those of the Investigator’s spouse and dependent children) to UGA no later than the time of proposal for the DOE award.  Disclosures must be made at least annually, thereafter, and within 30 days of acquiring a new significant financial interest.  Disclosures of significant financial interests should be made to UGA via the Grants Portal.  In addition, an Investigator may need to disclose the significant financial interest on UGA’s Compensated Outside Activities Approval Form.  See UGA’s Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy.

Finally, the DOE interim policy requires Investigator complete COI training prior to engaging in projects related to any DOE financial assistance award and at least every four years.  Investigators can complete the CITI COI training module through UGA’s Professional Educational Portal (PEP).

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