EXPORT CONTROLS

Generally Rutgers is not subject to export controls because we engage in basic research and publish the results of our research in the public domain.  Thus, most of our activity falls under a "fundamental research exception."  We will lose the protection of the fundamental research exception if Rutgers accepts work which allows restrictions on publication other than for prepublication reviews for patentability or to prevent inadvertent divulging of proprietary information provided to the researcher by the sponsor.  If the research is on "covered technology" as defined in the law and we allow publication restrictions, we would be subject to export controls.  The export controls required to insure we aren't exporting technology are quite onerous and the Rutgers policy is to stay under the fundamental research exception.  If Rutgers starts work on a project as either Pre-Award Spending or as a Hold Account, that could be construed as accepting the terms and conditions of the ultimate award without knowing what those terms and conditions might be.  If the award as finally issued has publication restrictions, we could be backed into export controls inadvertently.  To avoid that possibility we want the positive assurance of the signers that the award announcement and expected terms and conditions do not require export controls.  Or if they do require export controls that a plan for export controls has been approved by the Office of Research and Sponsored Programs and is in place and that a copy of that plan is attached to the IPAS form.  Please contact your grant specialist for further clarification.

OTHER CHANGES

• The descriptions for Pre-Award Spending, Hold Account and Continuation have been modified slightly. 
• In the first box on page two the instructions have been modified and rearranged better and the Department Risk has been highlighted and expanded. 
• The Justification has been allotted more space.
• The restrictions on Back Up Account have been eliminated.
• Under Approval: Chair or Director signature line a clarification has been added.
  
  FORM

Ronald S. Thompson, CPA, MBA, Assistant Controller  
Rutgers, The State University of New Jersey         732-932-0165 ext 2218
Division of Grant and Contract Accounting                     Fax 732-932-0182
3 Rutgers Plaza                                E-mail     rst@rci.rutgers.edu
New Brunswick, NJ 08901-8559     Web site http://postaward.rutgers.edu

BACK TO TOP

For questions or comments about this site, contact email address
Last updated: 07/28/2006

© 2003 Rutgers, The State University of New Jersey. All rights reserved.