Frequent FAQs

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 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 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 Regina Minichello – 617-373-2157 . 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).Regina Minichello 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 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 . 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.

Controlled Unclassified Information (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?

Amanda Humphrey

Director of Research Integrity & Export Controls

Jeff Seo

Chief Compliance Officer

Lisette Gilster

Export Control Officer

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?

Principal Investigators are responsible for ensuring that all personnel are appropriately trained, and are responsible for maintaining records of IBC, IRB, and Export Control trainings for all lab members as appropriate. IACUC training records are maintained by DLAM. Individuals are encouraged to retain copies of all training certificates.

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 if you have questions about research-related trainings.