UMass Boston

It is the Policy of the University of Massachusetts to comply with NSF, NIH, DoD, DoE and any other agencies’ or federal departments’ MFTRP requirements. Therefore, in accordance with federal research sponsor requirements (Section 10638(4)(a)(i-ix) of the CHIPS and Science Act of 2022), Covered Individuals who engage in federally funded research are prohibited from participating in MFTRPs.

The U.S. Government and federal sponsors have raised significant concerns with foreign talent recruitment programs and malign foreign talent recruitment programs. These programs can lead to conflicts of interest or commitment, the inappropriate transfer of federally-funded research to foreign governments, violation of export control laws, and theft of intellectual property. Any country can sponsor a foreign talent recruitment program, the U.S. Government is particularly concerned with programs affiliated with China, North Korea, Russia, and Iran

Read University of Massachusetts Policy Statement on Malign Foreign Government Talent Recruitment Programs

Foreign Country of Concern. A “Foreign Country of Concern” means the People's
Republic of China, the Democratic People's Republic of Korea, the Russian Federation,
the Islamic Republic of Iran, or any other country deemed to be a country of concern as
determined by the Secretary of State.

Faculty and key personnel must disclose their Outside Activities and/or Significant Financial Interests in outside organizations that relate to their University responsibilities on an annual basis by submitting the Kuali Disclosure Form. In addition, an updated Disclosure Form must be submitted within 30 days of any significant change in outside interests or Significant Financial Interests. 

Complete and accurate disclosures of all outside activities (paid and unpaid), in-kind and other support, and foreign travel are of the utmost importance.

Log into the Kuali System to complete disclosures

Required Training
All investigators are required to complete COI training. The training must be completed: prior to engaging in research related to any funded research, and at least every four years thereafter; when an Investigator is new to the University; and when an Investigator is not in compliance with the COI Policy. UMass Boston Investigators should complete the CITI COI Training to comply with this requirement.

UMASS Boston now uses single sign-on (SSO) for all CITI training. Please log in and associate your CITI training with UMASS Boston. 

University Travel Approval 

Most University Travel requires prior approval, also known as pre-travel authorization.  University Travelers must submit a request to travel in Concur for all overnight, out-of-state, and international University Travel. Approval must must be obtained by the Traveler prior to booking travel.

All international travel will require Export Control review.  Any travel to High-Risk Destinations will be subject to High Risk Review by the High Risk Travel Review Committee.  All approvals are facilitated through Concur.

A High-Risk Destination is any domestic or international country, region, province or city designated by the Systemwide Travel Risk Management Advisory Committee (TARMAC) or a campus as posing substantive health, safety, security risk to a University Traveler and/or the University.  High-Risk Destinations are inclusive of comprehensively sanctioned countries.  For the most up-to-date list of High-Risk Destinations, visit the Pre-Travel Authorization page under the "Requirements for Travel to High-Risk or Elevated Cybersecurity Risk Destinations" section. A copy of the list is also available here.

Export Controls
Export controls and trade sanctions are the United States laws and regulations that control and restrict the release of critical technologies, software, equipment, chemical, biological materials, and other materials, and services to foreign nationals and foreign countries for reasons of foreign policy and national security.

These laws apply to virtually all fields of science and engineering. They restrict the shipment, transmission, or transfer of certain commodities, software, technology, and services from the U.S. to foreign countries. Deemed exports, i.e. the release of controlled information to foreign nationals located in the U.S., are also restricted under these laws and regulations. Export control laws apply to all activities—not just sponsored research projects.

The Principal Investigator has the Following Responsibilities Related to Export Controls
Prior to commencing any research, the PI (Principal Investigator) must review and cooperate with ORSP to determine whether any technical information or technology involved in the research is subject to the export control law or regulations and, if so, whether any exclusion is available under the export control regulations.

The PI must in cooperation with the ORSP re-evaluate that determination before changing the scope or adding new staff to the project to determine if such changes alter the initial determination. The PI must ensure that export determinations are made far enough in advance to obtain an export license from appropriate agencies when required and if available. The PI must ensure that foreign nationals are excluded from access to restricted data or technology until the availability of an exclusion has been determined, or an export license has been obtained.

Data Security for Research Collected Abroad
When research is being conducted outside of the United States, special care should be taken with the methods being used to collect, transmit, and/or store that data. The following guidelines will help reduce the risk to that data:

Make sure any devices being used are fully patched and up to date.
Data should be transmitted and stored in University approved services hosted in the United States, such as OneDrive.

If data must be stored locally, make sure it is done so on an encrypted device (unless otherwise prohibited).

Keep devices that are being used for research collection, transmittal, or storage physically secure and, ideally, in your possession at all times.

Working with citizens of Cuba, Iran, Syria or North Korea?
These countries are designated by the U.S. Department of State as “State Sponsors of Terrorism.“ You may need special permission from the U.S. government before working with their citizens. 

Collaborating with companies located or primarily owned by China, Russia, Venezuela?
An export declaration is required when shipping most items to these countries.

Shipping Materials Outside the U.S.?
Contact ORSP - They are there to ensure your research endeavors are protected, and to help prevent unintended breaches of U.S. export laws that could result in fines and other punitive actions.

Questions?
Contact Tracey Poston, PhD, Associate Director of Research Compliance & Integrity

See: Global Programs at UMASS Boston University

Mandatory Cybersecurity Awareness Training for All Staff and Faculty

IT Research Computing

The Information Technology Research Computing group provides and brokers specialized resources in support of research activities.

Services include high performance computing, storage, and analytical applications. Consultation is available for any IT related research needs, including data security, risk mitigation, and equipment specification. 

IT Research Computing
Healey Library, Lower Level
UMass Boston
100 Morrissey Blvd.
Boston, MA 02125
Book a Consultation
 617.287.5399
 It-rc@umb.edu

Numerous new federal mandates for training are covered by CITI and the Office of Research and Sponsored Programs. 

All faculty and key personnel involved in federally funded research are required to complete the Research Security Training.

Additional Links to Resources:

Training on new NSF disclosure requirements: https://nsfpolicyoutreach.com/resources/nsf-implementation-of-the-common-forms-for-the-biographical-sketch-and-current-and-pending-other-support/

Department of Defense, Academic Research Security: 
https://basicresearch.defense.gov/Programs/Academic-Research-Security/

Office of Director of National Intelligence, Research Security
https://www.dni.gov/index.php/safeguarding-science/research-security

NSF Research Security:
https://new.nsf.gov/research-security#mftrp

NIH Foreign Interference:
https://grants.nih.gov/policy/foreign-interference.htm

NIH Foreign Interference Case Studies:
https://grants.nih.gov/policy/foreign-interference/case-studies

NIH Foreign Disclosure and Risk Management for SBIT and STTR, pursuant to the SBIR and STTR Extension Act of 2022:
https://seed.nih.gov/small-business-funding/small-business-program-basics/foreign-disclosure-and-risk-management#collapseOne