Obligations Associated with External Funding

    November 30, 2020

    Dear Faculty:
    I would like to take this opportunity to remind researchers of some important responsibilities related to being trusted with funding from external sponsors, highlight new policies and guidance from our federal sponsors, and describe some additional resources available. This communication includes updates on:

    • International Research Collaborations and Disclosure Requirements
    • Progress Reports
    • Publications
    • Equipment
    • Prohibited Vendors for Technology

    If you have any questions, please contact Lisa Mosley, Executive Director, Office of Sponsored Projects at lisa.mosley@yale.edu or 203-785-3680.

    International Research Collaborations and Disclosure Requirements

    The Office of Research Administration recently published a new website which provides information to the Yale community on safeguarding international research collaboration. This website also includes FAQs relating to disclosure requirements of external activities to federal sponsors and new guidance on external activities.

    Two federal agencies have published additional guidance on required disclosures:

    • The NIH has recently issued updated guidance on Protecting U.S. Biomedical Intellectual Innovation.
    • The NSF has issued FAQ’s for Current and Pending Support.

    These links are also included on the newly published website.

    Progress Reports

    For federal grants, ensure that the Federal Research Performance Progress Report (commonly referred to as, RPPR) includes:

    • All individuals who worked on the sponsored project for one month or more, even if they were not paid directly from the grant
    • All international travel for those working on the award
    • All publications, journals/juried conference papers, conference presentations/papers resulting directly from the award

    Content of progress reports describing the impact of COVID-19 related issues should align with information that has been previously relayed to the program officer.

    NSF Updates to the Research Performance Progress Report (RPPR) - Effective 10/5/20

    • New Question for Project Reports with Active Other Support Changes
      • Has there been a change in the active other support of the PI/PD(s) since the last reporting period?
    • Additional New Questions from the Revised RPPR
      • What was the impact on teaching and educational experiences? (Impact tab);
      • What percentage of the award’s budget was spent in a foreign country? (Impact tab);and
      • Has there been a change in primary performance site location from that originally proposed? (Changes/Problems tab).

    Publications

    Sponsors normally require acknowledgement of their support in all related publications. Often, the sponsor has specific requirements on how the acknowledgement must read. Please refer to the notice of award or the sponsor guidelines at the time a publication is submitted to ensure compliance with any requirements.

    Publication costs should be allocated across all active Yale awards that are cited in the publication.

    It is very important that only those grants or contracts that directly contributed to the research reported in the publication be cited.

    Equipment

    Equipment should not be purchased in the last few months of an award without strong justification. Allocation of cost methodology for split-use must be documented and included at time of requisition/purchase.

    Other Policies

    The National Defense Authorization Act (FY19 NDAA) places limits on the use of certain telecommunications equipment or services produced or provided by Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, and any subsidiary or affiliate of these entities. Accordingly, the university generally prohibits use of IT Systems produced by, or incorporating any technology, equipment, or services from, one of these entities for university business unless approval is obtained from Yale’s Director for Export Controls. This general prohibition extends to IT Systems not owned by Yale. If Users become aware of telecommunications equipment or services covered by this section being used or potentially used to conduct Yale business, please contact the Director for Export Controls.

    The FY19 NDAA also included a related prohibition on the use of loan and grant funds. OMB’s final guidance on 2 CFR Part 200 (Uniform Guidance) was published on August 13, 2020 and covers financial assistance (grants/cooperative agreements). Under this guidance, subrecipients are now prohibited from obligating or expending loan or grant funds to procure or obtain, equipment, services, or systems that use covered telecommunications equipment or services as a substantial or essential component of any system, or as a critical technology as part of any system.

    In essence, the purchase or use of prohibited equipment or services provided by Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, and any subsidiary or affiliate of these entities, is generally not allowable, regardless of the source of funds used to purchase them.

    Thank you,
    Pam Caudill

    Distribution:
    -Faculty named as personnel on active funding
    -Lead Administrators

    Pamela S. Caudill
    Senior Associate Provost for Research Administration
    Office of Research Administration
    Yale University
    25 Science Park, 150 Munson St, Room 322
    PO Box 208327
    New Haven, CT 06520-8327
    203-785-3012 (Office)
    www.yale.edu/researchadministration

    Preferred gender pronouns: she, her, hers.