Forms, Policies & Procedures

Subaward Management Policy

1. SCOPE OF POLICY
   This policy sets forth requirements for issuance and administration of outgoing subawards and applies to all departments, faculty, and staff involved in externally sponsored research at the University of Delaware (UD).
2. DEFINITIONS
   1. Sponsor or Sponsoring Agency or Prime Sponsor – An external entity responsible for providing project funding to UD under a formal award agreement. Also known as Prime Sponsor.
   2. Sponsored Award or Prime Award – A formal award agreement issuing funding from an external sponsoring agency to UD to achieve specified project goals. Also known as Prime Sponsored Award.
   3. Pass Through Funds – Funds originally issued to UD which are subsequently transferred to a subrecipient to implement sponsored award activities.
   4. Subrecipient – An external entity that receives pass-through funds via a subaward from UD to implement a specified portion of sponsored award activities. Also known as subawardee, subgrantee, or subcontractee.
   5. Contractor – An external entity that receives funding from UD via a procurement contract to provide goods or services related to the sponsored award. Examples of external contractors include a Consultant, Vendor, or Service Provider relationship.
   6. Subaward – A formal award agreement issuing pass through funds from UD to a subrecipient to implement a specified portion of sponsored award activities. Also known as a subagreement, subgrant, or subcontract.
   7. Procurement Contract – A formal contract agreement issued from UD to a contractor to provide specified goods or services under the prime sponsored award.
   8. Single Audit – A compliance and financial audit required of any institution receiving over $750,000 in federal funds to assure effective management and use of funds. Also known as the “A-133” audit.
   9. Authorized Institutional Official – An individual officially designated with institutional authority to legally bind UD in grants administration matters.
   10. Federal Funding Accounting and Transparency Act (FFATA) – A 2006 act of Congress that requires information on federal awards to be made available to the public via www.USASpending.gov
3. POLICY STATEMENT
   The objective of this policy is to provide guidance to Principal Investigators (PIs), Department/College Administrators, Research Office Administrators, and other responsible UD parties for issuing and administering outgoing subawards.

   Key administrative activities related to subaward management include:

   • Accurate determination of external collaborators as subrecipients or contractors.
   • Inclusion of subawards during UD proposal submissions.
   • Assessment of subrecipient risk level prior to subaward issuance or modification.
   • Incorporation of applicable monitoring requirements into subaward terms and conditions based on risk level.
   • Issuance or modification of subaward agreements in coordination with subrecipients.
   • Monitoring of programmatic and financial activities associated with the subaward.
   • Termination of a subaward via normal closeout activities or extenuating circumstances
4. POLICY STANDARDS AND PROCEDURES
   1. General Considerations
      1. UD may issue an outgoing subaward to a subrecipient to conduct a specified portion of the work performed under a sponsored award. As the prime recipient of the sponsored award, UD is obligated to undertake certain stewardship activities to ensure the subrecipient:
         1. Possesses adequate technical expertise and potential ability to successfully perform their scope of work in alignment with the prime sponsored award objectives.
         2. Proposes an appropriate budget for their applicable scope of work.
         3. Manages funds and meets performance goals stipulated by the prime sponsored award.
         4. Complies with governing laws, regulations, and special terms and conditions associated with the prime award; this includes compliance with federal regulations set forth per Uniform Guidance including 2 CFR 200.330 as applicable for federal and federal flow-through awards.
      2. UD PIs are responsible for initiating the request for UD engagement with a subrecipient. This request typically occurs during proposal submission, but may also occur during the course of the award:
         1. Upon funding of a proposal, the prime sponsored award issued to UD typically includes specific authorization and an explicit budget for any proposed subawards.
         2. Occasionally, the need for a subaward develops after a sponsored award has already been issued to UD. These instances may require UD to obtain prior written approval from the sponsor to issue a subaward; please confirm prior approval requirements with the Research Office.
   2. Subrecipient v. Contractor Determination
      1. The appropriate classification of a subaward or other procurement action at the time a sponsored award is proposed and funded is essential for ensuring:
         1. Proper budgeting and accounting for related costs.
         2. Adherence to applicable compliance requirements for subrecipients versus contractors.
      2. UD utilizes a standard “Provider Category Determination Worksheet” (PCDW) to correctly classify UD’s substantive relationship with an external collaborator as that of a subrecipient or contractor.

          

         Subrecipient Characteristics:	Contractor Characteristics:
         Performs substantive programmatic work related to the sponsored award Bears responsibility for programmatic decision making Is accountable for measurable performance requirements Must adhere to compliance requirements specified by the sponsored award	Provides goods or services which are ancillary to the sponsored award operations Normally operates in a competitive environment Provides similar goods or services to many different purchasers Is not subject to compliance requirements of the sponsored award
         Use of Judgement: All characteristics listed above may not be present in all cases. UD will use its judgment in correctly classifying the relationship between UD and an external entity.

      3. Key considerations utilized for subrecipient versus contractor determination are outlined below:
      4. In determining whether an agreement between UD and an external entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. As such, UD must use judgment in classifying each agreement as a subaward or a procurement contract, as certain characteristics outlined above may not be present in all cases.
   3. Subaward Issuance and Modifications
      1. The Research Office prepares, issues and administers subawards jointly with the UD PI and his/her unit administration to ensure subrecipient compliance with the prime sponsored award.
      2. Subawards may only be issued, modified and executed on behalf of the University by an authorized institutional official with delegated signature authority.
         1. A UD PI or other unauthorized individual may not approve a subrecipient to begin working without a fully-executed subaward from UD. Subrecipients that prematurely commence work do so at their own risk, and have no assurance of payment from UD.
         2. UD is a member of the Federal Demonstration Partnership (FDP) and requires utilization of standard FDP templates to expedite subaward execution when possible.
         3. Subaward modifications are executed by UD in accordance with any modifications to the prime sponsored award (e.g. incremental funding or renewal), or as a result of actions required due to subrecipient monitoring (e.g. changes to a subaward’s terms and conditions). Subaward modifications are normally issued annually to coincide with routine monitoring activities
      3. Components below must be completed prior to UD issuance or modification of a subaward:
         1. Establishment of the prime sponsored award in UD’s financial system.
         2. Establishment of the subaward purchase order requisition or amendment.
         3. Confirmation that subrecipients receiving federal or federal flow through funds have a DUNS# and an active SAM registration.
         4. Completion of subrecipient risk assessment or monitoring activities per subsequent sections of this policy. UD reserves the right not to enter into a subaward or terminate an existing relationship wherein the risk of engagement is deemed too high or excessive.
      4. Key items outlined in the subaward agreement issued by UD should include:
         1. Payment Terms
            1. Subawards are typically issued on a cost-reimbursement basis by UD.
            2. UD will issue a fixed price subaward with a predetermined payment schedule under limited circumstances. Fixed price awards typically:
               1. Require prior written approval (or waiver thereof) by the sponsor.
               2. Require a specific project scope in alignment with prime sponsored award objectives, wherein subrecipient accountability is based on performance and results.
               3. May not exceed $150,000 funds wherein:
                  1. The fixed funding amount is based on adequate cost, historical, or unit pricing data used to reasonably estimate actual costs.
                  2. Payments are based on meeting requirements of the sponsored award.
                  3. Mandatory cost sharing or match is not required by the sponsored award.
                  4. The subrecipient will realize no increment above actual costs.
               4. Must specify and utilize one of the following payment methods:
                  1. Payments made for a set of specific milestones agreed upon prior to work performed and set forth in the prime sponsored award.
                  2. Payments made on a per-unit basis at defined prices agreed upon prior to work performed and set forth in the prime sponsored award.
                  3. Lump sum payment made at time of award completion.
         2. Authorized Funding Amount and Period of Performance
            1. Subawards will be issued and modified in alignment with their allotted budget amount and timeline authorized per UD’s prime sponsored award.
            2. Subawards are normally issued annually to coincide with routine monitoring activities. Only in unique situations will a subaward be issued in increments greater than one year.
         3. Facilities and Administrative Costs (F&A)
            1. UD personnel may not require/suggest subrecipients forego their entitled F&A.
            2. UD will issue a subaward using the subrecipient’s federally negotiated F&A rate except under circumstances specified below:
               1. UD and subrecipients are required to limit total F&A to a cap specified per written sponsor policy or the funding opportunity.
               2. If the subrecipient does not have a federally negotiated F&A rate, a de miniumus 10% F&A rate will be used on the subaward’s Modified Total Direct Costs (MTDC) per Uniform Guidance 2 CFR 200.414. Subrecipients which have had a federally negotiated F&A rate in the past are not eligible for the de minimus 10% F&A rate.
   4. Subrecipient Risk Assessment and Monitoring
      1. It is UD’s policy to complete a risk assessment prior to issuing a subaward/amendment, no less than annually. This ensures that the most appropriate subrecipient monitoring plan is:
         1. Developed based on a standardized process,
         2. Communicated to the subrecipient, and
         3. Documented in the terms of the subaward
      2. UD’s risk assessment categorizes a subrecipient as “Low”, “Moderate” or “High” risk based on a predetermined set of risk factors. Typical implications for subrecipient monitoring based on their assigned risk level are outlined below:

          

         Risk Level	Subrecipient Monitoring Guidelines
         Low Risk	Check all subrecipient invoices to confirm they: Adhere to the required format as specified in the subaward agreement which requires inclusion of the following: UD Purchase Order Number UD Award Number Invoice line items per the approved subaward budget Current and Cumulative Totals by budget category (including Cost Share) A signed certification statement as to the accuracy and appropriateness of the charges from an authorized Subrecipient Institutional Official Are within the allowable subaward project period start and end dates Contain F&A charges calculated in accordance with the subrecipient’s federally negotiated F&A rate agreement Contain billed amounts which appear reasonable based on technical progress towards project goals Do not contain any unallowable charges such as alcohol, meals, postage, office supplies or other unallowable items except where specifically authorized as per the subaward agreement For Final Invoices, invoices are clearly marked “FINAL” and accompanied by the Subaward Closeout Form. Note: A subrecipient invoice will not be approved for payment until all errors, discrepancies, or questionable items have been adequately and fully resolved.
         Moderate Risk	Incorporate additional requirements dependent on UD management decision: Required copies of supporting/backup documentation for subaward invoice charges such as: Payroll records to support invoice personnel charges Copies of receipts for specific charges (travel, supplies, equipment, etc.) Copies of consultant hourly rates and time charged Transactional detail from the subrecipient’s accounting system of record More frequent submission of subrecipient invoices and technical reports Requirement to align subrecipient invoice payments to technical progress
         High Risk	Incorporate additional requirements dependent on UD management decision: Mandated regularly scheduled conference calls with the UD PI and subrecipient institutional representative Financial Desk Audits Site visits, both technical and financial

      3. It is UD’s responsibility to ensure that all agreed-upon monitoring activities occur and that the results of the risk assessment are updated accordingly.
         1. UD may adjust a subrecipient’s assigned risk level and applicable monitoring activities throughout the course of a sponsored award.
            1. The PI is responsible for monitoring the technical progress of the subrecipient to ensure their performance is aligned with objectives outlined in the subaward and the prime sponsored award, including:
               1. Advancing toward the completion of programmatic goals.
               2. Submitting accurate and timely invoices and technical reports as required.
         2. One or more of the following actions may be taken by UD for subrecipients deemed noncompliant as a result of subaward monitoring activities:
            1. Temporarily withholding cash payments pending correction of the deficiency,
            2. Denying both use of funds and any applicable matching credit for all or part of the cost of the activity or action,
            3. Wholly or partly suspending or terminating the subaward, and/or
            4. Taking other remedies that may be legally available.
            5. Note: In most cases, noncompliance must be documented to support above actions.
   5. Subaward Closeout and Termination
      1. Normal closeout and termination of a subaward occurs upon expiration of the subaward period of performance. Action should be taken to complete key activities in a timely manner, including:
         1. Confirmation by the UD PI that all subaward deliverables have been met.
         2. UD receipt of a final subaward invoice and associated closeout documents:
            1. The final subaward invoice must be clearly marked “FINAL” with certification statements signed by the Subrecipient Institutional Official
            2. UD requires the subrecipient’s final invoice be accompanied by a completed “Subaward Closeout Form” signed by the Subrecipient Institutional Official and the Subrecipient PI prior to releasing payment. This form contains:
               1. Confirmation that the subrecipient sent a final invoice to UD
               2. Confirmation of the final subaward expenditures.
               3. Amount of required cost share.
               4. Completion of all final technical/patent/equipment reports and deliverables.
            3. UD typically incorporates a 60-day grace period from the subaward end date for the receipt of the subrecipient’s final invoice.
            4. If UD does not obtain the subrecipient’s final invoice in a timely manner, UD reserves the right to treat the last invoice received from the subrecipient as the final invoice.
         3. Closeout of the subaward purchase order via a Purchase Order Amendment Webform after the final subaward invoice is paid.
      2. Early closeout and termination of a subaward occurs when the subaward is terminated prior to the original subaward end date specified in the subaward agreement.
         1. An agreement may need to be terminated early at the request of the sponsor, UD, or by mutual agreement between UD and the subrecipient.
            1. The UD PI may consider termination due to factors related to suboptimal subrecipient performance towards project milestones, services, or objectives specified in the subaward agreement. Any UD PI contemplating early termination of a subaward should immediately contact the Subaward Team within Research Office for appropriate action.
         2. Sponsor regulations and subaward specific terms and conditions detail the steps needed to process an early termination of a fully-executed subaward agreement.
            1. UD typically incorporates a clause into the subaward agreement outlining UD’s right to terminate a subaward within 30-days of official written notice to the subrecipient.
               1. A “Stop Work Order” is a formal notification to the subrecipient to discontinue all work on a subaward. UD will issue a “Stop Work Order” to a subrecipient in the rare instance when all other remediation means have been unsuccessful.
            2. The Research Office will work with the PI and their unit administration to ensure all required termination actions and documentation is completed.
   6. Roles and Responsibilities
      1. Successful administration of subawards relies heavily on the involvement and coordination of multiple parties across campus including the UD PI, unit administration, the Research Office, and others. The table below provides an overview of applicable roles and responsibilities for subawards:

          

Travel and Business Hosting Policy

1. SCOPE OF POLICY
   This policy relates to expenses incurred for traveling and entertaining on behalf of the University, regardless of the funding source, and including state, federal, basic budget, and reserves.

   It applies to all travel and business hosting events for all individuals including University administrators, faculty, staff, students, and non-employees. …

The complete policy and more can be found on the General Counsel’s web site.

Travel with or Transportation of Research-Related Materials and Data

The purpose of this memo isto remind and inform all University of Delaware employees of the laws, policies and procedures that may impact the transportation of University of Delaware property, including research-related materials,software, data,biological materials and equipment. These laws,policies and procedures apply whether the materials, software or data are hand-carried during travel or shipped commercially. The laws,policies and procedures apply to our international visitors as well. Please help them to be aware of the following regulations.

Although the University of Delaware is working to keep compliance on this matter from becoming onerous, candid assessment of the current situation must acknowledge that scholars are increasingly subject to external constraints that can be both unfamiliar and frustrating. As our policies and procedures evolve in light of external constraints and faculty and staff needs, we will work to keep you apprised of changes as quickly as possible. Listed below are some key concepts with which every University of Delaware employee should be aware and in full compliance.

1. Not all research material may be shipped or hand-carried by air. The Transportation Security Administration (TSA) has rules that limit what airline passengers can place into their checked and carry-on luggage. These rules may prevent research materials and equipment from being brought onto airplanes. Please review the list of permitted and prohibited items posted on the TSA web page found at (https://www.tsa.gov). This list issubject to change and should be checked on a regular basis.
2. A Material Transfer Agreement (MTA) should be used when University of Delaware research materials,software,biological materials or data sets are received from an outside party or transferred off campus. Similarly an MTA should be used when transferring such materials from the University of Delaware to outside parties.
   • When the University of Delaware is the recipient of the materials, the MTA triggers appropriate health and safety alerts to the Occupational Health and Safety Office concerning the materials received.
   • When the University of Delaware issending materials off campus,the MTA permits review of applicable shipping regulations.
   • An MTA permits review of intellectual property rights to protect the interests of the University of Delaware and individual University of Delaware researchers.

     Appropriate MTA forms are available on the University of Delaware Research Office website (https://research.udel.edu/forms-policies-procedures/).

3. All transfers of research materials,software or data must comply with export control and trade sanction regulations. Export controls are federal laws that regulate the export of sensitive technologies, equipment, software, biological agents and related data and services. These laws require the use of licenses for the export of these items unless an exemption exists. Trade sanctions are imposed by the Department of State, which may prohibit travel, payment or providing anything of value to sanctioned entities, including countries, businesses, and individuals, regardless of exemptions.Information and guidance on export control and trade sanction compliance is available at https://research.udel.edu/regulatory-affairs/#3. If you have questions about your activity, please contact the Associate Deputy Provost for Research & Regulatory Affairs, Dr. Cordell Overby, at overbyc@udel.edu.
4. Commercial shipment of hazardous materials must comply with U.S.Department of Transportation regulations. For specific requirements, please contact Occupational Health and Safety.
5. Federal law and regulation by the USDA,FDA,or EPA can severely limit the interstate shipment of certain biological,recombinant,or toxic materials.
6. The U.S.Foreign trade Regulations require that all exports (temporary or permanent) with a dollar value greater than $2,500 as well as any licensed export be registered in the AES export system prior to shipment. The AES (Automated Export System) filing includesinformation about the date, method and destination of the export and licensing exception or authority if applicable. The U.S. Census Bureau uses the data to compile export trade statistics. Additionally the information is shared with Customs and Border Patrol, export licensing enforcement and other law enforcement agencies.
7. The University of Delaware provides compliance assistance to facilitate your transfer and transport of research materials,software and data.
   • Information on export controls and trade sanctions, including international travel: Dr. Cordell Overby (overbyc@udel.edu or 302-831-2383)
   • MTAs for research related transfers: Dr. Cordell Overby (overbyc@udel.edu or 302-831-2383)
   • Shipping and receiving of hazardous materials: OccupationalHealth and Safety Office {302-831-8475)
   • Biological Materials: Krista Murray (klmurray@udel.edu )
   • Chemical Materials: Jane Frank (janejf@udel.edu or 302-831-8288 )
   • Radioactive Materials: Bill Fendt (B_Fendt@facilities.udel.edu )

We welcome your comments regarding clarifications or improvements to the University of Delaware policies and procedures regarding the transfer or transport of University of Delaware research materials, software, data, biological materials, or equipment. Please feel free to contact any of the following individuals:

Dr. Cordell Overby at overbyc@udel.edu

It is important that all University of Delaware employees are aware of these laws, policies and procedures. Please distribute this message to your colleagues across campus.

The complete policy and more can be found on the UD Research Office’s web site.

UD Credit Card

1. SCOPE OF POLICY
   This policy sets forth guidelines and procedures for the University of Delaware Credit Card Program (the Program) which encompass the UD Credit Card and the UD Declining Balance Card.

   These policies are applicable to all UD Credit Card holders and articulate the overall Card Administration including requirements for receiving a credit card, appropriate card usage, and responsibilities and roles pertaining to approval as well as allocation of usage, fraud, cash advances, and reimbursement. …

The complete policy and more can be found on the ’s web site.

UD Individual Development Plan (IDP)

University of Delaware IDP policy
The University of Delaware requires Individual Development Plans (IDPs) to be completed for graduate students and postdocs funded by NIH (regardless of funding mechanism) each year. The use of IDPs for all graduate students and postdocs is encouraged as a means for professional development and career planning. Additionally, other funding agencies are beginning to request IDPs.

Reporting
PIs of NIH grants must report on the use of IDPs in their annual Research Progress Performance Report (RPPR) in Section B. Accomplishments, Question B.4. PIs do not need to include actual IDPs; they need to document that graduate students and postdocs funded by the award use IDPs and discuss them with their mentors on an annual basis. Below is suggested wording for inclusion in the RPPR. PIs should modify the text as needed to accurately reflect their activities in encouraging their trainees to develop and utilize IDPs.

Related Links

AAAS “myIDP” Individual Development Planning Tool
UD IDP Assessment Form

Underground Storage Tank Management

1. SCOPE OF PURPOSE
   To ensure the management of Underground Storage Tanks (USTs) at the University is conducted in compliance with Federal and State Underground Storage Tank Regulations (7 Del. Code Chapter 74, 40CFR280), NFPA, BOCA, City of Newark and other applicable codes.

   This policy applies to all University underground storage tanks and underground storage tank systems containing motor fuels, heating oils, waste products, and other regulated products. …

The complete policy and more can be found on the ’s web site.

Uniform Guidance Procurement Standards Update

MEMO

July 9, 2018

Re: Uniform Guidance Procurement Standards Update

Dear Colleagues,
We would like to update you of Policy changes regarding procurement of goods and services in accordance with the federal government’s Office of Management and Budget (OMB) Uniform Guidance. OMB has recently issued a memorandum that raises the threshold for micro-purchase under Federal financial assistance awards to $10,000, and raises the threshold for simplified acquisitions (large purchases) to $250,000. The University has revised the Procurement Policy 5-01, effective July 1, 2018, accordingly and as follows:

4. The following quotation/bid thresholds apply:
   1. Federal Contracts and Grants including Mandatory/Voluntary Committed Cost Share and University Service Centers:
      1. Less than $10,000 – Departments should perform due diligence on pricing options to ensure that products or services are obtained at reasonable prices.
      2. $10,000 to $250,000 – Quotes must be obtained from an adequate number of qualified sources (minimum of three sources if available). If there is only one qualified source, a UD Sole Source Justification form must be completed and submitted to Procurement for review and approval.
         http://www1.udel.edu/procurement/forms/Sole-Source-Form-UD.docx
      3. $250,000 and greater – Sealed bids are required with formal advertising by Procurement Services unless there is only one qualified source. A UD Sole Source Justification form must be completed and submitted to Procurement for review and approval.
         http://www1.udel.edu/procurement/forms/Sole-Source-Form-UD.docx
   2. All Other purchases:
      1. Up to $50,000, solicitation of quotations/bids will be at the discretion of Procurement Services. Buyers in Procurement Services are accountable for exercising professional due diligence by soliciting written or telephone quotations (documented) when appropriate.
      2. Purchases over $50,000 require price quotations or sealed bids to be obtained from at least three qualified vendors (if available), solicited by Procurement Services.
      3. In the event that only a single source can be located for a particular purchase exceeding $50,000, Procurement Services will make that determination and the buyer will so document in the purchasing system.

Thank you for your cooperation and effort in this regard. Please contact Procurement Services with any questions.

The complete policy and more can be found on the UD Research Office’s web site.

University of Delaware Research Foundation Program

1. PURPOSE
   To outline the administration, type of research supported, and application procedures for grants awarded by the University of Delaware Research Foundation.
2. POLICY
   1. University of Delaware Research Foundation ProgramThe University of Delaware Research Foundation, Inc. is a nonprofit, tax-exempt organization for the support of fundamental research in all fields of science. An independent corporation, it is chartered primarily to support the University’s scientific research programs.

      University of Delaware Research Foundation (UDRF) grants are administered by the Senior Vice Provost for Research, who represents the University on the UDRF Research Committee and is secretary of the UDRF Board of Trustees.

      The Senior Vice Provost for Research disseminates the updated information on UDRF grants to the faculty annually by letter. This letter includes the deadline for applications for grants.

      The appropriate deans and chairs provide the Senior Vice Provost for Research with preliminary evaluations of applications for grants. The Senior Vice Provost combines these evaluations into a University recommendation. The final evaluation and award decision is made by the UDRF Research Committee. Grants are made primarily in the fields of the natural and physical sciences, but any proposal that uses scientific methods and promises quantitative results is eligible for a grant.

   2. GrantsUDRF grants support high quality scientific and engineering projects by early-career, untenured, tenure-track faculty. Costs covered are stipends, graduate student or technical assistance, equipment, supplies, travel, etc. Grants are awarded on the basis of individual merit and specific need.

      The awards are made in April and become effective on the following June 1.

      These grants are not to be used for the support of advanced-degree theses nor for their publication.

      Understandings concerning the research grant programs and patents, copyright, and publishing considerations are stated in the Faculty Handbook and in this Policies and Procedures Manual.

      Patent, copyright, and publication policies are as stated in the University of Delaware Faculty Handbook and in sections 6-6 and 6-7 of this Policies and Procedures Manual.

   3. Understandings and Procedures for Submitting Proposals are found in the UDRF Proposal Guidelines which are updated annually by the committee.

The complete policy and more can be found on the ’s web site.

University Procedure for International Travel with Electronic Devices

The purpose of this memorandum is to remind and inform University of Delaware (UD) employees of the states-of-nature and UD expectations that exist when traveling internationally with mobile devices, laptop computers, personal-digital assistants (PDAs) and other electronic devices.

Consistent with the guidelines offered by the Office of the Director of National Intelligence, U.S. National Counterintelligence & Security Center (NC&SC) (https://www.dni.gov/index.php/ncsc-home), University personnel who are traveling internationally should be aware that:

1. In most countries, travelers should have no expectation of privacy in internet cafes, hotels, offices or public places. Hotel business centers and telephone networks are regularly monitored in many countries. In some countries, hotel rooms are often searched.
2. All information that you send electronically by FAX machine, PDA, computer or telephone can be intercepted. Wireless devices are especially vulnerable.
3. Your movements can be tracked using your mobile telephone or PDA, and the microphone in your device can be turned on even when you think that it is turned off. To prevent this, remove the battery.
4. Malicious software can be inserted into your electronic device through connections you use. This can also be done if your device is enabled for wireless. When you connect to your home server, the malware can migrate to your home system and/or the University, can inventory your system, and can send information back to the individuals who inserted the software.
5. Malware can be transferred to your device through thumb drives (Universal-Serial Bus (USB) sticks), computer disks … some of which you may have been given as “gifts”.
6. Transmitting sensitive information from abroad is risky
7. While corporate or government officials may be most at risk, it incorrect to assume that you will not be targeted.
8. Intruders are skilled at posing as someone you trust in order to obtain personal or sensitive information (i.e., phishing).
9. If customs officials demand to examine your device, or if your hotel room is searched while your device is unattended in the room, you should assume your device has been compromised.

To mitigate these threats, again consistent with NC&SC guidelines, when traveling internationally, University personnel should:

1. Take only necessary devices.
2. Take only needed information, including sensitive contact information. Consider the consequences if your information were stolen or otherwise compromised.
3. Back up all information you take, and leave the backed-up information at home.
4. If feasible, use a different mobile telephone or PDA from your usual one, and remove the battery when not in use. Have your device examined by your UD information technology (IT) support-personnel when you return.
5. Monitor official cyber security alerts from https://www.consumer.ftc.gov/features/feature-0038-onguardonline.
   1. Creating a strong password (numbers, upper and lower case letters, special characters – at least eight characters long). Never storing passwords, telephone numbers, or sign-on sequences on any device or in its case.
   2. Changing passwords at regular intervals, and as soon as you return.
   3. Downloading current, up-to-date antivirus protection, spyware protection, operating system security patches, and a personal firewall.
   4. Encrypting all sensitive information on a device. (Note that in some countries, customs officials may not permit you to enter with encrypted information.)
   5. Updating your web browser with strict security settings.
   6. Disabling infrared ports and features you don’t need.

While travelling internationally, you should:

1. 1. Avoid transporting devices in checked baggage.
   2. Use a digital signature and encryption when possible.
   3. Don’t leave your electronic devices unattended. If you stow a device, remove the battery and subscriber-identity module (SIM) card, and keep them with you.
   4. Don’t use thumb drives given to you – they may be compromised. Similarly, don’t use your own thumb drive in a foreign computer. If you must do either, assume your device has been compromised, and have it cleaned as soon as possible.
   5. Shield passwords from view. Don’t use the “remember me” feature that is found on many websites … retype the password every time.
   6. Be aware of who is looking at your screen, especially in public places.
   7. Terminate connections when you are not using them.
   8. Clear your browser after each use, delete history files, caches, cookies, URL and temporary internet file.
   9. Do not open emails or attachments from unknown sources. Don’t click on links in emails. Empty your “trash” and “recent” folders after every use.
   10. Avoid Wi-Fi networks. They are insecure, and maybe controlled.
   11. If your device or information is stolen, report it immediately to UD and the local US embassy or consulate.

Upon your return from international travel, you should:

1. 1. 1. Change your password.
      2. Have your UD IT support-personnel examine your device for the presence of malicious software, if you suspect that it may have been compromised.

If you have questions, contact the Research Office at UDResearch@udel.edu or (302) 831- 2383. Additional information regarding “Travel Best Practices for Both Domestic & Abroad” is provided by UD Information Technologies at https://www.udel.edu/it/security/bestpractices/travel.html.

The complete policy and more can be found on the ’s web site.

USCIS I-129 Export Control Certification Requirement

Recent changes to the United States Citizenship and Immigration Services (USCIS) regulations require the use of the new I‐129 petition form. The University of Delaware must certify whether or not the foreign person will be performing work that is subject to the U.S. Department of State (ITAR) or U.S. Department of Commerce (EAR) export regulations and if export licensing will be required for the work. It is important to note that the release of controlled technology or technical data to aforeign person in the United States is a “deemed export” and subject to the relevant export regulations. While most of the research conducted by foreign nationals at the University of Delaware qualifies as “fundamental research” (is performed without restrictions on publication or on who may participate), it is important to understand the specific terms of the contract or grant on which foreign national employees are working, as well as the nature of the research in order to correctly complete the new I‐129 form. The Office for International Students and Scholars will continue to manage the filing of I‐ 129 forms at the University of Delaware. A new “Export Control for Certification on I‐129 Form” has been instituted. This form must be submitted with other supporting documentation in order for the Office of International Students and Scholars to complete the I‐129 for potential employees. Additionally, if a foreign national employee’s source of funding changes, a new certification form is required so that the University of Delaware may appropriately amend the I‐129 filing.

The Research Office is available to answer questions and provide training on the U.S. export control regulations. Please contact the Associate Vice President for Research, Dr. Cordell Overby at overbyc@udel.edu.

The Office for International Students and Scholars is available to assist with questions about hiring foreign nationals. Please contact Younes Haboussi, Coordinator of Immigration Services at younesh@udel.edu.

The complete policy and more can be found on the ’s web site.

Use of Pipettes

1. PURPOSE
   To establish a policy for use of pipettes.
2. POLICY
   A variety of hazardous material are used in University laboratories, both for teaching and for research, and student, faculty, and staff exposure to such material should be kept at a minimum. Oral pipetting — suction by mouth or blowing through pipettes — is one of the most common means of exposure to hazardous materials. Oral pipetting, including oral pipetting for the purpose of starting siphons, is strictly prohibited at the University. Pipetting shall be done with a mechanical pipetting or siphoning device.

   Requests for exemption shall be submitted in writing to the Department of Environmental Health and Safety for Review.

The complete policy and more can be found on the ’s web site.

Volunteer Fire Service

1. SCOPE OF POLICY
   This policy addresses volunteer firefighter service during working hours.
2. POLICY STATEMENT
   To assist with the protection and safety of the Newark, Wilmington, Lewes and other campus communities, the University may release designated employees, who are volunteer fire fighters, to assist local fire companies in fighting fires during normal working hours without loss of pay.
3. POLICY STANDARDS AND PROCEDURES
   To qualify for release time under this policy, an employee must secure the written approval of the fire chief of the department for which the employee volunteers and the employee’s supervisor.  The written approval of the fire chief is to be updated annually.  The employee’s supervisor at his/her discretion may restrict an employee’s response to fires as business needs require.  Once the response is initiated, it is understood that the employee represents the fire department and must abide and comply with direction given by the fire chief in command of the incident. The University assumes no liability for any injury or activity arising from volunteer fire service.

The complete policy and more can be found on the ’s web site.