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  • 1.  Using Flags for Export Control Risk Management

    CAYUSE CHAMPION
    Posted 10-20-2021 10:32
    This issue, while pretty well-managed here, has taken over my week - just out-of-the-blue questions I've never come across before....    (My belief that PIs have secret meetings where they plan confusing issues to keep us on our toes remains firm! - just kidding- but it does feel like that...)

    So, I'm now looking for ways for the Sponsored Programs team to communicate a little better with the Export Controls "team" (it's one person....)  Here's my idea.  But it's just the idea I've had; I'm not at all tied to it if there's a better idea out there.

    I'm thinking of having the pre-award  GCOs utilize a flag called something like "Potential Dual Use" if they are concerned that there's a possibility that the work being proposed is going to include an export control issue.  I expect that they will over-use this flag - which is actually fine with me.  The Export Controls person will be able to see these flags - or maybe he'd get an email when the flag is set.  (Will Cayuse do that?)  Whatever.... a weekly search for flags would be good enough.  He will review and either remove the flag, with a note that he reviewed and there's no problem.  Or, he will remove the flag and set a new one that says something equivalent to "Post-Award Staff Take Heed"   Or maybe it will just say "Dual Use Expected."  I could go either way ;)

    And then the Post-Award GCO will know that there's an issue to be addressed.  But also, if we flag the issue at pre-award we would have more time to pursue a license assuming the work will move forward in some limited way even if the work isn't funded.

    So...what do ya'll do?  Feel free to shoot this idea down and tell me your vastly better one.  I'm good with that.

    Andrea

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    Andrea Buford
    Director, Office of Sponsored Programs
    Oakland University
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  • 2.  RE: Using Flags for Export Control Risk Management

    CAYUSE CHAMPION
    Posted 10-20-2021 11:22
    HI Andrea,
    While we don't specifically use Events regularly for Export control review we do have our SP folks assign a "Proposal Compliance Review" Event for any item that needs guidance or input from staff in Research Compliance. The event triggers an email. In Research Compliance we either close the event with notes for no further action or keep the event open for follow up. Within the SP proposal form we have an entire set of questions around export controls.  Let me know if you would like a copy of our questions. I am curious to see how others might respond in using flags.
    Hila


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    Hila Berger
    Director Research Compliance & Regulatory Programs
    Montclair State University
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  • 3.  RE: Using Flags for Export Control Risk Management

    CAYUSE CHAMPION
    Posted 10-20-2021 11:32

    We have questions in our SP module, but I hate them.  PIs don't know what they mean, and they answer sort of willy-nilly.  I think they're trying to guess the "right" answer.  Re-writing that section is on my never-ending to-do list.  Our best training on this happens one-on-one, and revolves around the novel concept of "let's figure out what's true here and check THOSE boxes."  So, in short, yes I'd love to see your questions.

    A



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    Andrea Buford
    Director, Office of Sponsored Programs
    Oakland University
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  • 4.  RE: Using Flags for Export Control Risk Management

    CAYUSE CHAMPION
    Posted 10-20-2021 12:12
    Andrea, I don't have anything really to contribute to this conversation, but I'll be watching out for how others respond.  Being able to flag things pre-award is the best approach in my opinion.  Below your post was a section called Related Content about flags and their use.  Sounds like a great feature designed to be used as you have described.  I've not really looked into the use of flags but will be keeping it in mind.  I think what you've proposed is workable and I plan to steal the idea and have our compliance person begin using it.  Keeping my eyes open to see what others have to say.

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    Audrey Wineglass Foster
    Assistant Dean for OSP + Research Svcs
    Gallaudet University
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  • 5.  RE: Using Flags for Export Control Risk Management

    CAYUSE CHAMPION
    Posted 10-21-2021 06:25
    Andrea,
    One of our tabs in the proposal setup is about export control. We have our pre-award folks highlight if there are export control items disclosed and post-award reviews the proposal record as well when we receive an award. So far we use emails to alert the person who should look at export control compliance. Separate email not using the Cayuse SP email notifications.

    Currently, flags do not initiate an automated email, that would be great though, as we also use flags for items to flag, data management, and open-source requirements that our Library would like to know about.

    Another idea is to use Events and alert the export control person this way. There is status in the event which could potentially be customized (if possible) to address the particular workflow you have set up for export control compliance. I might actually implement this idea myself :)




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    Vibeke Svensson
    Director, Office of Sponsored Programs
    American University
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