Forms, Policies and Procedures

 

Here you will find a repository of forms, policies and procedures related to research at the University of Delaware. This repository draws on sources throughout campus to provide quick and easy access to these resources in a variety of formats, such as html, MSWord and Adobe PDF. We encourage you to explore and use the tools provided to narrow your search by word, resource type or category in order to learn more about the content that governs research at UD.

Forms, Policies and Procedures (36 Procedures Entries)
Procedure: Conflict of Interest
Conflict of Interest Disclosure Procedure
Procedure

Conflict of Interest Disclosure Procedure

PROCEDURE STATEMENT:

Log in to the Conflict of Interest (COI) Disclosure webform

  • The form describes the different categories of significant financial interest (SFIs) that are required to be disclosed. A table of examples below is provided as a reference. Please know this is not an all inclusive reference, rather, just few examples for illustrative purposes.
  • If answering ‘Yes’ to any of the listed questions, a pull down menu of information required will show. Please provide enough detail to facilitate its assessment.
  • COI web forms will be automatically routed to the chair or direct supervisor and the dean for review and approval.

Faculty and professional staff must complete a new COI disclosure every year, even when they do not have any SFI to disclose. COI disclosures must be submitted, via web form, on an annual basis or within 30 days of any change to previous disclosures. Please click on the link below, and login using your UDNet ID and password. If the link does not take you directly to the form, look for “Conflict of Interest Disclosure Form” under the tab “Blanks.”

Significant Financial Interest (SFI) Must Be Disclosed Does NOT Need To Be Disclosed
Publicly traded entity(ies) Any remuneration from the entity during the previous 12 months that, when aggregated, exceeds $5,000; and/or any equity interest that represents more than 5 percent ownership in a single entity Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles
Non-publicly traded entity(ies) Any remuneration during the previous 12 months received from the entity that, when aggregated, exceeds $5,000; and/or any equity interest  
Intellectual property(ies) Royalties, inventions, discoveries and patents under NOT assigned to UD Royalties, inventions, discoveries and patents under assigned to UD through Policy 6-6, and/or Policy 6-7
Consulting activity(ies) Any arrangements that involve a consulting agreement, or other outside professional activities Seminars, lectures, teaching engagements or income from service on advisory committees or review panels sponsored by a federal, state or local government agency, or an institution of higher education
Entity(ies) related to employee’s institutional responsibilities Participation in, or personal sponsorship from, any entity that invests in, or provides financial support for, activities related to the employee’s University areas of responsibility.  
Commercial enterprise(s) An appointment as an officer, director or any other managerial position in a commercial enterprise; participation in the day-to-day operations, including serving on the scientific advisory board, of a commercial enterprise.  
Potential conflict(s) of interest Situations where students are directed into research areas or other activities from which the employee intends to realize personal financial gain.  
Reimbursed or sponsored travel   Travel reimbursed or sponsored by a federal, state or local government agency, or an institution of higher education

 

Related Links

 

Procedure Details:

OWNER: Research Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Conflict of Interest
Conflict of Interest Management Procedure
Procedure

Conflict of Interest Management Procedure

PROCEDURE STATEMENT:

  • If a COI is determined to exist, a COI management plan is to be developed by the chair and/or dean in agreement with the employee.
  • Please use the template for the COI management plan.
  • Examples of conditions or restrictions that might be imposed to manage a COI include, but are not limited to:
    1. Public disclosure of the conflict (e.g., when presenting or publishing affected research);
    2. Appointment of an independent monitor capable of taking measures to protect against bias resulting from COI;
    3. Change of personnel or personnel responsibilities, and/or modification of the research plan;
    4. Reduction or elimination of a financial interest;
    5. Severance of relationships that create the conflict(s).
  • In addition, please see a detailed guidance for the development of COI management plans in the context of SBIR/STTR awards.
  • Additional information on UD’s COI disclosure and management procedures can be found in the UD COI training module.
  • Further details on reporting requirements specific to PHS-funded research can be found in the Financial Conflict of Interest (FCOI) tutorial provided by NIH.
  • Inquiries concerning Institutional Conflict of Interest should be directed to udresearch@udel.edu

Related Links

NIH Conflict of Interest Tutorial

 

Procedure Details:

OWNER: Research Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Contracts and Grant Management
Grant Transfers Procedure
Procedure

Grant Transfers Procedure

PROCEDURE STATEMENT:

When a Principal Investigator (PI) of an externally-funded grant changes institutions, a decision is made about whether the grant stays at the current institution or is transferred to the new institution. UD will determine on a case-by-case basis whether it will retain or transfer a grant. Because the grant award is made to the institution and not to the PI, there must be agreement between the institutions and the sponsor as to where the grant will ultimately reside.

If the decision is to change the grantee organization to the PI’s new institution, the request must be made prior to the PI’s anticipated start date at the new organization, preferably several months in advance. Failure to provide timely notification may result in disapproval of the request or a delay in processing.

If the decision is to leave the grant award at the current organization, the sponsoring agency must be notified immediately with a request for change in responsible PI. This correspondence may also include a request to re-budget part of the award as a sub-grant to the former PI’s new organization for continued work and collaboration on the project. In either case, Office of Sponsored Programs will assist in facilitating this process.

Some sponsors have specific guidelines and forms to be used when requesting a transfer. It is the PI’s responsibility to follow the guidelines of the sponsor. Please see Exhibit A, which identifies sponsors and links to their websites and guidelines.

Transferring a Grant FROM UD to Another Institution

Facilitating the transfer of an agreement from the University of Delaware requires significant amount of coordination and close attention to the award terms and conditions. Specific areas to review include cost sharing commitments, equipment procured on the agreement, unexpended direct and F&A cost balances. The responsibilities matrix – worksheet will assist in initiating and completing the transfer of awards from UD to another institution.

Forms:

Transferring a Grant TO UD from Another Institution

Facilitating the transfer of an agreement to the University of Delaware requires significant amount of coordination among the PI, the department administrator, OSP and the sponsor. The responsibilities matrix will assist in initiating and completing the transfer of awards from another institution to UD.

Other Documentation that may be applicable during transfer:

  • Letter/Communication from Transferring Institution Indicating Intent to Transfer Award to UD
  • Provider Determination Worksheet
  • Consultant Agreement form
  • Agency specific forms

 

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

ORIGINATION DATE: September 25, 2012

Procedure Source Open Procedure



Procedure: Contracts and Grant Management
Procedure for Requesting Letters of Support and Cost Share Commitments from the Research Office
Procedure

Procedure for Requesting Letters of Support and Cost Share Commitments from the Research Office

PROCEDURE STATEMENT:

Principal investigators (PIs) are encouraged to review UD’s Cost Sharing Policy. Cost share letters and or commitments require sufficient preparation and often a long lead time. PIs should start this conversation with their respective department chairs or college research office/deans as early as possible. All proposals that require cost share commitments and/or letters of support from UD leadership (president, provost, VP for research, scholarship and innovation) should follow the steps outlined herein.

Please route all requests for cost shares and letters of support requiring UD leadership support through the associate vice president for research development. Encourage the PI’s and research deans to engage with the Research Office (RO) as early as possible through the Research Development Office. Use email researchdev@udel.edu for communication to the RO.

The timeline, specified below, depends on the complexity of the cost shares/commitments and level of letters of support.

Cost Sharing and F&A Modifications:

  1. Standard equipment match requests should follow the Equipment Cost Share policy and be communicated to the RO at least one week in advance of the submission date.
  2. RO should be notified at least two weeks from the submission date for proposals with substantial match, such as non‐equipment match. Large/complex proposals, such as major research instrumentation grants or proposals involving more than one college, generally require very substantial university cost share commitments and therefore need even more lead time.
  3. Unless F&A is limited by the sponsor, any reductions of F&A, including its use as cost share, need to be communicated to the RO at least two weeks in advance.

Letters of Support:

  1. Letters of support that involve language for cost shares need to follow the cost share schedule noted above. See also #3 below.
  2. Please plan at least five business days before proposal submission date for letters of support that need president or provost signature; three business days for letters of support that need VP for research, scholarship and innovation support.
  3. The PI and/or respective research dean must provide a draft summary for such letters and key points that must be emphasized in the LOS, paying careful attention to the solicitation’s guidelines.

 

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

Procedure Source Open Procedure



Procedure: Contracts and Grant Management
Research Office Collection Procedure
Procedure

Research Office Collection Procedure

PROCEDURE STATEMENT:

This procedure applies to all sponsored projects and programs as of January 1, 2016. It must be understood and followed by principal investigators (PIs), department/college managers and staff, department chairs, deans and the Research Office. All University faculty, staff and students who are responsible for administering federal, state and privately sponsored grants/contracts should be familiar with this collection procedure.

This section describes the procedures to follow during the collection process. Throughout the process, it is critical that communication between the Research Office, principal investigator (PI) and department administrators (deans, chairs and departmental/college administrators) be both timely and consistent. The steps are designed to obtain uniform results of high collection rates and maintain a working relationship with the sponsor.

The Research Office should continue to use prudent judgment in collection efforts until all avenues of resolution have been exhausted. These methods may include phone calls to the sponsor, continued notifications and legal letters, legal action or other means to continue contact and collect past due invoices. The following procedures should be followed based upon the aged date of the receivable.

At any time, the associate deputy provost, research administration (ADP), in coordination with the appropriate parties to include the PI, dean or research dean and VP for research, scholarship and innovation may order the work stopped or to proceed at risk. If the decision is to continue the project, the PI and his/her department will become wholly responsible for all additional deficits that occur after the date of the stop work order. For state or federally funded awards, ceasing work will be evaluated on a case-by-case basis. This information will be relayed to the associate director, post awards administration (ADPA), and the ADP.

A. 30 Days Outstanding: Receivables 30 days or less are considered current.

B. 31 to 60 Days Outstanding: Receivables 31 to 60 days outstanding will be reviewed by the assigned billing coordinator. The following initial steps should be taken by the assigned billing coordinator:

  • Contact the sponsor to confirm receipt of the invoice and verify accuracy of email and/or physical address
  • Determine if there may be problems with the invoice that prevent payment
  • Determine if a revised invoice or second notice is necessary
  • Alert the department administrator and PI if the sponsor is “Industry”
  • Document the initial steps taken in the award file using the Aging Report/Accounts Receivable Collection Efforts Log

Notes: If the sponsor is non-responsive, the assigned billing coordinator should follow the steps for 61 to 90 Days Outstanding.

If the sponsor refuses to pay due to work performance (deliverables, reports and other technical functions) the assistant director, billing and receivables (ADBR) should be notified. These sponsor’s comments regarding work performance will be relayed to the PI, department/college administrator and ADPA via email or memorandum. If either party feels the situation warrants it, a meeting will be scheduled to discuss the account status before any decision regarding further collection is made. All accounts receivables will continue to age and be subject to all other collection procedures at 61 to 90; 91 to 120, and >120 as stated below, even if collection efforts with the sponsor have been temporarily suspended. The assigned billing coordinator will be notified when collection efforts with the sponsor can resume.

If, at any time during the collection process, a sponsor notifies either the Research Office or the PI that they do not believe the receivable is their obligation, notification will be sent by the ADBR to the ADPA and the ADP, for their assistance and opinion in considering the validity of the claim. Until Research Office and/or the PI resolve the issue, all other collections procedures may cease. As part of the review process, the ADP may engage the appropriate parties, depending on risk factors, to determine if work should continue.

C. 61 to 90 Days Outstanding: When a receivable has been outstanding for 61 to 90 days, the following steps should be taken by the assigned billing coordinator:

  • Email or mail correspondence to the sponsor informing them of the outstanding invoice
  • Send a copy of the email/mailed correspondence to the PI and department/college administrator depending on risk factors
  • Place a phone call to sponsor to ensure contact information is valid
  • Contact the Research Office contract and grant specialist to identify any other sponsor contacts if necessary
  • Document the steps taken in the award file using the Aging Report/Accounts Receivable Collection Efforts Log

Keep ADBR informed so that needed information can be provided to the ADPA and ADP. ADP may engage appropriate parties regarding continuation of work based on risk factors.

D. 91 to 120 Days Outstanding: When a receivable has been outstanding for 91 to 120 days, the ADBR will notify the ADPA in a monthly report. The report will identify those awards which have not been settled due to the fault of the University and those that are not the fault of the University.

When a receivable has been outstanding for 91 to 120 days, the following steps should be taken by the assigned billing coordinator:

  • Email or mail a letter to the sponsor informing them of the outstanding invoice
  • Send a copy of the email/mailed correspondence to the PI and department/college administrator
  • Inform the ADBR that the invoice is 90 days past due and provide background/corresponding information
  • Contact the department/college administrator and inform him/her of the outstanding payment
  • Document the steps taken in the award file using the Aging Report/Accounts Receivable Collection Efforts Log

ADP may engage appropriate parties regarding continuation of work based on risk factors. Upon review by ADPA and ADP items deemed uncollectible may be submitted for write-off.

E. After 120 Days: When a receivable has been outstanding for more than 120 days (121 to 180 days), The ADPA will notify the ADPA and the ADP in a monthly report. The report will identify those awards which have not been settled due to the fault of the University and those that are not fault of the University.

When a receivable has been outstanding for 121 to 180 days, the following steps should be taken by the assigned billing coordinator/ADBR:

  • Email or mail correspondence to the sponsor informing them of the outstanding invoice
  • Contact the department/college administrator and inform of the outstanding payment
  • Document the steps taken in the award file using the Aging Report/Accounts Receivable Collection Efforts Log

ADP will engage appropriate parties regarding continuation of work. Upon review by ADPA and ADP items deemed uncollectible may be submitted for write-off.

F. After 180 Days:

After 180 days, the ADBR and assistant director post award administration will submit a report to the ADPA and the ADP for possible referral to UD’s General Counsel for legal recourse. UD’s General Counsel will review existing information as provided by the ADP and determine if legal action is necessary. The ADP shall be kept informed accordingly.

When a receivable has been outstanding for 181 to 365 days, the following steps should be taken by the assigned billing coordinator/ADBR:

  • Email or mail correspondence to the sponsor informing them of the outstanding invoice
  • Contact the department administrator and inform him/her of the outstanding payment
  • Document the steps taken in the award file using the Aging Report/Accounts Receivable Collection Efforts Log

Upon review by ADPA and ADP items deemed uncollectible may be submitted for write-off.

G. After 365 Days:

If after 365 days, all collection efforts fail, including examination of legal recourse, the Research Office will notify the PI and dean of the status of the receivable. The Research Office will provide information to University Finance to determine the best course of action on an award by award basis. If a privately held company has defaulted on a debt, ADP will engage DPRS to determine if further contract assignments should be accepted by the University of Delaware. For federal or state funded projects that have defaulted on a debt, further contract assignments will be evaluated on a case-by-case basis by the Research Office. Upon review by ADPA and ADP items deemed uncollectible may be submitted for write-off.

H. After two years:

If after two years, a receivable is deemed uncollectible by the ADPA and ADP, regardless of the actions taken by the sponsoring agency, it will be written off. If payment is received after it has been written off, the ADP will review and issue credit for payment to the appropriate parties.

The University of Delaware receives sponsored project awards from various governmental and private entities. As a recipient of federal, state and privately sponsored grants and contracts, the University is required to comply with all policies and regulations set forth by the federal and state government and private sponsors, including compliance with the Office of Management and Budget (OMB) Uniform Guidance. Sponsors generally require an invoice or cash drawdown request before paying the University for an award. Invoices/Cash drawdowns are generated in accordance with the requirements set forth by the sponsor in the agreements. The Research Office billing team manages the billing and collections activities for all sponsored projects while working closely with the principal investigator (PI), department, and the Office of Sponsored Programs Pre- and Post-Award administration teams.

While most sponsors pay invoices reliably, occasionally a sponsor is unable/unwilling to pay the award they made to the University. This procedure provides guidelines in collecting accounts receivables and writing off uncollectible balances.

DEFINITIONS:

Grants Receivable — Refers to any amounts billed for a sponsored project by means of an invoice/cash drawdown. Receivables include billings for expenditures on a reimbursement basis, payment schedule or a fixed-price contract. Invoices are generated via the University’s financial system in accordance with the award agreements. Once an invoice has been emailed, mailed or a cash drawdown has been completed, a billing coordinator in the Research Office tracks the invoice to confirm payment. The assigned billing coordinator is responsible for updating receivable comments within the University’s financial system when a payment is past due.

Aging report — This is a list of outstanding receivables grouped or summed by category in the University of Delaware’s financial system. Categories are based on the invoice due dates. These categories include: 731 days. For this accounting process, aging is determined by the due date of the invoice. Using the Research Office Aging Report, collections efforts and comments are logged on a daily basis by the Research Office billing team.

Write-off of Uncollectible Balances— After a thorough collection process is followed by the University and it is determined that an invoice will not be paid in a reasonable time, the balance is no longer considered collectable and revenue should be adjusted accordingly. The process of removing the balance from the accounts receivable balance on the financials is called a write-off.

Related Links

Appendix

Responsible Parties

The financial management of sponsored projects resides with the principal investigator(s) and their respective department(s)/college. It is incumbent on the faculty and/or staff who manage projects to:

  1. Understand the budget as awarded and planned
  2. Monitor the financial activities on a timely basis
  3. Know the costing/budget policies associated with their programs
  4. Review billing & collection information in UDATAGLANCE

Closeouts

There are a number of scenarios under which costs may not be reimbursed. This situation may come to be known at any time throughout the life of a project. In order to assess the reasons and potential resolution of any outstanding invoices or deficit in a timely fashion, it is critical that the financial closeout activity occur within the timeframe documented in the Automated Closeout Report (ACR) escalation process, and prior to the closeout period, as defined by the sponsoring agency for the project in question.

Aging Report Schedules

  • An aging report is generated monthly and managed by the Research Office billing team. Collections efforts are logged and comments are added for each invoice that is past due
  • An aging report is generated quarterly and is shared with the DPRS and Office of the Vice President for Finance and Administration documenting outstanding invoices by sponsor type (federal, state and other)
  • A Sponsored Programs Receivable Report is prepared semi-annually for the Board of Trustees Finance Committee meeting. This aging report reflects aging as of February and August month end

Exceptions to Write Offs

  • In the event of a No-Cost Extension, the ADBR and the ADPA will review and take the appropriate internal actions to update the receivables
  • If an invoice is outstanding due to an unfinished task or un-met deliverable(s), the ADBR and the ADPA will review and take the appropriate internal actions to update the receivables within the University’s financial system

Institutional Responsibility Issue

If the costs are allowable and the payment is delayed due to a late technical report submission or other resolvable situation, the billing coordinator will:

  • Send an email notice to the PI and department administrator requesting resolution within two weeks (completing the report/deliverable or providing and update of when the task will be completed)
  • A reminder email will be sent to the PI and department/college administrator after the two weeks
  • If a path-forward (resolution) is not provided to the billing coordinator after a month, a follow up email will be sent to the PI with copies to the PI’s chair/dean, departmental administrator, college business officers, ADBR and ADPA
  • If the problem is not resolved the issue will be escalated to ADPA

 

Procedure Details:

OWNER: UD Research Office

RESPONSIBLE OFFICE: UD Research Office

Procedure Source Open Procedure



Procedure: Effort Certification
Effort Certification Procedures
Procedure

Effort Certification Procedures

Each department assigns an effort administrator who has the procedural responsibility to oversee the reports for that department.

PROCEDURE STATEMENT:

A. Each department assigns an effort administrator who has the procedural responsibility to oversee the reports for that department.

B. Reports are required from every employee whose salary is either directly charged to a sponsored project or used as match/cost sharing for a sponsored project during a particular effort reporting period.

C. For faculty on academic contracts, there are three effort reporting periods. Period 1 includes effort provided during the fall semester of the academic year. Period 2 includes effort provided during the spring semester, and Period 3 includes summer research activity performed during the months of June through August. The following chart describes the three periods for academic faculty: Click to view the sample chart.

D. Following each reporting period, a web based electronic application will produce web views for review. This application will allow interaction (via web journal) to modify transactions through cost transfer submissions. Every certification must be reviewed by a designated Effort Administrator (each unit has one assigned staff member for this role) and the employee personally (unless that employee has terminated or retired from employment with the University in which case an employee with suitable means of verification evaluates effort in lieu of the particular employee). If an employee has an active HR status but is not capable of certifying their own report, the report may be completed by providing certifications (with suitable means of verification) from both the Effort Administrator and the Effort Manager or another Research Office

designee.

E. To facilitate accuracy in initial payroll allocations, the Labor Allocation Module (LAM) allows for timely changes made to an employee’s payroll distribution plan. A LAM calculator exists to assist in the accuracy of percentages to distribute.

F. It is expected that all certifications will be in “completed” status within 90 days of the end of the reporting period. Electronic copies are retained in the Research Office for the retention period required by the sponsored agreement, usually three years after the closeout or final payment of the project.

G. Email notification will be sent to effort administrators listing reports 40 days old in an effort to remind administrators of this responsibility. Notification of delinquent reports still outstanding beyond the 90 day certification period and again at 120 days past the last day of the effort certification period will escalate to the Department Chair, Assistant Dean and Dean. If any reports remain incomplete 150 days past the end of a reporting period, notification will be sent to the Associate Deputy Provost for Research Administration for review and action as necessary. If any reports remain incomplete 180 days past the end of a reporting period, notification will be sent to the Deputy Provost for Research & Scholarship for review and action as necessary. The effort administrator is responsible for completing these reports. Cost disallowances on sponsored projects resulting from the failure to complete an effort report will be removed from the sponsored project to a non-sponsored project.

H. In the event that an error was made during the routing process, the research office has the authority to create revised effort reports which must be completed within 30 days of release. These will be stamped with ‘[REVISION]’ so as to identify the report as such. In order to request a revision the effort administrator must have an adequate justification. Any changes must comply with all other UD policies and federal regulations.

University of Delaware Effort Certification Procedures

I. Routing is as follows:

a. Research Office creates the report (in batch three times annually, or one at a time as needed) (report is now in ‘UNSENT’ status)

b. Effort Administrator reviews and ‘forwards’ to employee (report is now in ‘IN PROGRESS’ status

c. Employee reviews and either clicks yes, I agree (‘review and certify’), or no I do not agree (‘forward’), and the system will require a comment stating what is wrong with the report. Either way it is routed back to the effort administrator.

d. Effort administrator selects ‘review and certify’ (if approved by employee in c.) or takes necessary action to correct the errors identified by the employee (if not approved in c.).

e. If approved in c and ‘review and certify’ in d., the system will set the certification report to ‘COMPLETE’status.

f. Once action is taken in step ‘d’, effort administrator will ‘forward’ back to the employee until the employee is satisfied that this report reflects the effort expended during that effort reporting period.

Revised July 2013

*If employee is terminated or otherwise incapable, someone with suitable means of verification may act as a substitute.Employee will REVIEW AND CERTIFYProxy* will REVIEW AND CERTIFY for otherwise incapable employeesEmployee supervisor * will REVIEW AND CERTIFY for Terminated employeesEA FORWARDS to Effort ManagerWith request for exceptionEffort Manager REVIEWS & CERTIFIES

 

Procedure Details:

OWNER: Research Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Export Regulations (ITAR/EAR/OFAC)
Export Compliance Program Manual
Procedure

Export Compliance Program Manual

Given the complicated nature of exportation, this procedure has been created to assist in ensuring that any exportations of your research are in compliance with the standards of the United States and any other nations involved. Please review the material carefully and if there are any questions, please refer to the Regulatory Affairs page.

PROCEDURE STATEMENT:

The U.S. export control system generally requires export licensing for defense items, for items that have both commercial and military applications, and for exports to sanctioned persons and destinations. U.S. national security, economic interests and foreign policy shape the U.S.export control regime. The export laws and regulations aim at achieving various objectives, such as preventing the proliferation of weapons of mass destruction, advancing the U.S. economic interests at home and abroad, aiding regional stability, implementing anti-terrorism and crime controls, and protecting human rights.

These controls generally restrict the export of products and services based on the type of product and the destination of the export. In both the defense and high-technology sectors, the U.S. government tightly regulates the export not only of equipment and components, but also of technology. Technology includes technical data, such as blueprints and manuals, as well as design services (including the transfer of “knowledge”) and training. U.S. laws assert jurisdiction over U.S.-origin equipment and technology even after it is exported (i.e., restricting the re-export or retransfer to third parties). In addition to general export licensing, the United States maintains economic embargoes against a number of countries whose governments consistently violate human rights or act in support of global terrorism. Such embargoes bar most transactions by U.S. persons with these countries. Finally, the U.S. government maintains lists of Specially Designated Nationals or persons and entities that are barred from conducting export business because of previous activities.

Three principal agencies regulate exports from the United States: the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) administers export control of defense exports; the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) administers export control of so-called “dual-use” technology exports; and the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) administers exports to embargoed countries and specially designated entities.

DEFINITIONS:

APRRA– Associate Provost for Research & Regulatory Affairs
BIS– Department of Commerce Bureau of Industry and Security
CCL– Commerce Control List
CJ– Commodity Jurisdiction
DDTC– Department of State Directorate of Defense Trade Controls
EAR– Export Administration Regulations
ECCN– Export Control Classification Number
EO– Empowered Official
URC– University Research Counsel
ITAR– International Traffic in Arms Regulations
OFAC– Department of the Treasury Office of Foreign Assets Control
RO– Research Office
PI– Principal Investigator
SDN– List Specially Designated Nationals and Blocked Persons List
TCP– Technology Control Plan
USML– United States Munitions List
UD– University of Delaware

 

Procedure Details:

OWNER: Research Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Export Regulations (ITAR/EAR/OFAC)
Is your UD project in Compliance with Export Controls
Procedure

Is your UD project in Compliance with Export Controls

Given the complicated nature of exportation, this procedure has been created to assist in ensuring that any exportations of your research are in compliance with the standards of the United States and any other nations involved. Please review the material carefully and if there are any questions, please refer to the Regulatory Affairs page.

The attached PDF is a flowchart determining whether or not a project needs to be advised upon in terms of its compliance.

 

Procedure Details:

OWNER: Research Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Export Regulations (ITAR/EAR/OFAC)
Office of Foreign Asset Control
Procedure

Office of Foreign Asset Control

Given the complicated nature of exportation, this procedure has been created to assist in ensuring that any exportations of your research are in compliance with the standards of the United States and any other nations involved. Please review the material carefully and if there are any questions, please refer to the Regulatory Affairs page.

PROCEDURE STATEMENT:

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope and involve close cooperation with allied governments.

 

Procedure Details:

OWNER: US Treasury Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



Procedure: Export Regulations (ITAR/EAR/OFAC)
Specially Designated Nationals And Blocked Persons List (SDN)
Procedure

Specially Designated Nationals And Blocked Persons List (SDN)

Given the complicated nature of exportation, this procedure has been created to assist in ensuring that any exportations of your research are in compliance with the standards of the United States and any other nations involved. Please review the material carefully and if there are any questions, please refer to the Regulatory Affairs page.

PROCEDURE STATEMENT:

​As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” Their assets are blocked and U.S. persons are generally prohibited from dealing with them. Click here for more information on Treasury’s Sanctions Programs.

 

Procedure Details:

OWNER: US Treasury Office

RESPONSIBLE OFFICE: Research Office

Procedure Source Open Procedure



FILTER BY
Animal Subjects in Research

For Forms, Policies and Procedures pertaining to Animal Subjects in Research and other resources

Click Here

Conflict of Interest
Contracts and Grant Management
Effort Certification
Export Regulations (ITAR/EAR/OFAC)
Human Subjects in Research
Intellectual Property
Internal Funding
Material Transfer
Reporting Misconduct
Research Agreement Templates
ASSISTANCE

Compliance Hotline
Phone: (302) 831-2792

UD Research Office
Phone: (302) 831-2136
Fax: (302) 831-2828

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