How do I determine if my project should be classified as either “research”, subject to the Organized Research rate, or “testing”, subject to the Other Sponsored Activities rate?

A research project typically has the following attributes:

  • The work involves original, creative research and is expected to produce new science or technology;
  • There is substantial involvement of the Principal Investigator in defining the statement of work;
  • University owns the results of the work.

A testing project typically has the following attributes:

When is the “Off-Campus” F&A rate applicable?

Off-campus is defined as activities performed at sites not owned or centrally leased by the university, or activities occurring in sites for which those site costs are directly allocated and charged to the project. Centrally leased by the university means the lease costs are paid by the Office of the Chancellor (including the Provost Office and the Vice Chancellor for Research) or the System Office.

Criteria for using the Off-Campus designation for the project are as follows:

What Are Export Controls?

Export controls are federal laws and regulations that govern exports of certain commodities, technologies, services, and money to foreign countries. Export controls also regulate disclosures of certain kinds of information—including research data—to non-U.S. persons. Some exports and disclosures require special permissions (usually in the form of a license) from a federal agency.

There are three primary sources of regulations that govern exports of different kinds of commodities and information:

What Is an Export?

Exports include shipments of tangible items, including carrying items in luggage, and transmissions of information to a destination outside the United States. The United States includes the 50 states, the District of Columbia, and other US territories (like Puerto Rico and Guam). The United States does not include US military bases or embassies in other countries: shipments or transmissions to these destinations are exports.

What Is a Deemed Export?

Transmissions or releases of information or software to anyone who is not a United States citizen or permanent resident are “deemed” to be exports of that information to that person’s country of citizenship. A deemed export can occur anywhere in the world, including inside the United States, and can occur in any format.

What Is a Technology Control Plan?

A technology control plan documents procedures for securing and managing access to controlled items or spaces where sensitive work is being conducted. Technology control plans may sometimes overlap and work in conjunction with other security plans, like biosafety or chemical safety protocols.

A template technology control plan is available. Please contact the Export Compliance Officer for assistance in determining whether your research requires a technology control plan, or for implementing an appropriate plan for your lab.

What Should I Consider When Traveling Internationally?

This depends on the purpose of your trip and your destination. When planning a trip, you should carefully consider the equipment and data you'll be taking with you. Keep in mind that customs officials may confiscate or impose duties on anything you attempt to bring into the country, so you should avoid traveling with anything you can't afford to lose. If you're traveling to conduct research, consider the kinds of equipment you will need, and whether they might require an export license based on the nature of the equipment and the country you're traveling to.