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COVID-19: Information from SPA/OSP/CGA

Regulatory Requirements

Conflict of Interest

All Investigators who submit proposals to NSF, PHS or DOE agencies must certify an Annual Disclosure prior to their proposal being submitted by the Office of Sponsored Programs.  Visit the Federal Conflict of Interest Business Procedure FAQs webpage for a list of FAQs related to PHS and NSF COI compliance, as well as a link explaining how to complete an annual disclosure.

Investigators who have received awards from PHS agencies are also required to complete COI Training. Visit the MSU COI webpage for information on COI Training requirements as well as instructions on how to complete the training.

Export Control and Trade Sanctions

Review for compliance with export controls and trade sanctions is typically performed at the award stage rather than at the proposal stage.  There are a few circumstances that require an Export Control and Open Research Review Worksheet (ECORRW) to be completed prior to proposal submission.  For additional information on export control review visit the Export Control Procedures webpage.

Debarred Parties and Entities

U.S. export control laws prohibit Michigan State University (MSU) from doing business with an individual or company debarred by the Federal Government.  Anyone found working with a debarred individual or company could be prosecuted to the fullest extent of the law.  To assist in compliance with these laws, MSU uses a cross-campus license for the web-based tool called Visual Compliance to identify debarred individuals or companies.  The software performs denied party screening, Office of Foreign Assets Control (OFAC) Sanctions screening, FBI watch list screening, and can identify issues when traveling to sanctioned and embargoed countries. When identifying a subcontractor or consultant to work with, it is recommended that you check the list early in the planning stage. You can do this by either providing the subcontractor or consultant's name to your OSP proposal team or you can contact ECTS for information on obtaining an ID for access to the Visual Compliance system if appropriate. For additional information on export control review visit the When and How to Check for Debarment/Suspension Procedures webpage.

Human Subjects

The MSU Human Research Protection Program (HRPP) oversees the review and conduct of any research using human subjects. This is accomplished via the MSU Institutional Review Board (IRB).

At the proposal stage the use of humans should be disclosed within the application and on the Proposal Development document.  

Any Principal Investigator who anticipates the use of human subjects in his/her research must complete a protocol for review and receive approval by the IRB prior to award.  The protocol must be approved by the IRB prior to the start of any research activities involving human subjects. CGA cannot issue a project account number without this approval.  If MSU is relying on an external IRB, OSP/BC must receive the MSU IRB acknowledgement letter before a project account number can be setup.  For additional information on reliance, please see the FAQ page on the HRPP website.

Animal Use

The Institutional Animal Care and Use Committee (IACUC) oversees the review and conduct of any research, teaching, or testing using live vertebrate animals.

At the proposal stage the use of animals should be disclosed within the application and on the Proposal Development document.

Any principal investigator, who anticipates the use of animal subjects in his/her research, must complete a protocol for Animal Use and Care for review and approval by the IACUC prior to award.  The protocol must be approved by the IACUC prior to the start of any research activities involving animal subjects. CGA cannot issue a project account number without this approval.

Non-Domestic Influence and Global Activities eDisclosure

Undisclosed working relationships between scholars in U.S. institutions and non-domestic entities (e.g., universities, companies, and governments) have increasingly been of concern to American science agencies.  To support faculty in the required federal funding agency disclosures and to assist faculty in addressing any potential conflicts, the Office of Research and Innovation has developed the Global Activities e-Disclosure (GAED) web-based form to supplement other required disclosures.  The GAED FAQs are intended to address some of the common questions that faculty may have while completing their disclosure.  Step-by-step instructions on completing and editing the GAED form are provided in the Global Activities e-Disclosure job aid.  For more information on the MSU’s implementation of the form, please see the Provost and VPRI letter.  For general information related to issues of non-domestic influence, please see our Non-Domestic Influence FAQs webpage.  Disclosure requirements by agency, including examples of what must be included, can be found on the Current and Pending/Other Support Requirements by Sponsor webpage.  Additional information and resources related to emerging federal guidelines can be found on MSU's Emerging Federal Guidance on Outside Influence webpage.

Academic Freedom- Essential Sharing of Research Findings and Creative Works

Some sponsors, including the Federal government, may request MSU to accept varying restrictions relating to publication or data use for the research projects they are funding.  These requests usually are not in-line with MSU’s policy allowing faculty essential academic freedoms and for MSU and faculty to be responsible to publish or present research findings and creative works for public benefit. MSU’s basic purpose is the advancement, dissemination, and application of new knowledge (https://trustees.msu.edu/about/statement-free-speech.html).

Any publication restrictions beyond a brief review and comment period or the assignment of ownership of results to the sponsor would require special MSU review and approvals to ensure that such projects are necessary.  Potential factors for justifying the acceptance of a restriction include:

  • use of previously developed Intellectual Property (i.e. background IP) by another institution
  • project is not research
  • national security or export-control issues

If the project is approved with publication or data use restriction, it will usually need to be supervised under the auspices of the University Research Organization (URO).  The URO was established in 2011 to enable faculty to pursue research in areas of national importance that are challenging or impossible under current policies, particularly when review or restrictions on publication or considerations of citizenship status are involved.

If the project publication or data use restrictions are not approved, then the language must be removed from the agreement, or the PI must withdraw the proposal from consideration by the sponsor.

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