Guidance and Policies

Federal Grant Rules and Requirements (Uniform Guidance)

The federal government created a set of rules called the Office of Management and Budget Uniform Guidance (2 CFR 200), to make grant management more consistent across all federal agencies. This is a government wide framework for grants management and a common set of rules governing most federal grant making. These rules explain how colleges, universities, and other organizations must manage federal grant funding, including budgeting, purchasing, reporting, and audits.

The rules also reduce administrative burden for universities and researchers, improve accountability and transparency on how federal funds are used and clarify expectations for budgeting, documentation, purchasing and audits.

Federal agencies such as the National Institutes of Health (NIH), National Science Foundation (NSF), and the United States Department of Energy develop their own grant policies based on these federal requirements.

Universities, including Saginaw Valley State University, must follow both the federal rules and any agency-specific requirements.

Click here to learn more about Uniform Guidance, its six subparts and appendices.

Export Controls

Any equipment, technology, or technical information subject to U.S. government control that is released to any foreign person in any location in any way is an export. The technical data, service, or commodity need not physically leave the U.S. to be considered to have been exported. Export includes face-to-face conversations or meetings, emails or faxes, or casual conversations in a hallway or at lunch or on an airplane. Exports involving both classified defense information and critical unclassified technical data are controlled by the federal government.

SVSU’s routine international business activities may be subject to U.S. export regulations.

All SVSU employees need to be aware of the existence of these laws, to know when a work situation poses export control concerns, and where to turn for guidance and assistance when questions arise and help you avoid the civil and criminal penalties imposed on individuals who violate these federal laws.

Training

All relevant SVSU personnel, including U.S. citizens, permanent residents, and foreign person, must receive initial training regarding export controls and compliance via CITI Modules at https://www.citiprogram.org/

Such personnel will also receive refresher briefing on export controls at least annually via CITI Modules.

Sponsored Programs is responsible for scheduling and conducting these training sessions. SVSU will document these training sessions, including a list of the participants. Timely information regarding export regulations and compliance issues shall be disseminated on an as needed basis to senior managers, supervisors, and employees. Changes to the regulations that have a direct impact on the conduct of SVSU’s export functions are transmitted to the appropriate offices immediately and included in updated training sessions. Following a voluntary disclosure, mandatory training is routinely conducted as part of the remedial measures.

Foreign Travel

Each employee traveling on SVSU business receives a written briefing from SVSU’s International and Advanced Studies Office including:

The most current Worldwide Caution Public Announcement
Counter Intelligence Awareness Briefing
Current State Department advisories for each country the employee will be visiting; and
Additional information i.e. other source information and anti-terrorism information when applicable

Laptop Letters - Each SVSU employee who takes abroad a laptop computer, or other electronic device allowing storage of data, is provided with a letter that identifies the description, make, model, and serial number of the device, the U.S. Department of Commerce ECCN number for the device, and outlines the license exceptions available for the temporary export of such electronic device. If controlled technical data is stored on the device, authority for such data is also required in separate documents; copies are maintained in Sponsored Programs.

An employee traveling overseas - whether for business or pleasure who intends to bring a laptop containing information about an SVSU project - must contact Sponsored Programs first. The data on the laptop may be subject to export controls, so carrying it out of the United State in electronic format qualifies as an export.

Control of Visiting Foreign Persons

Hosting a Foreign Visitor - Report all foreign visitors to International and Advanced Studies Office.

Controlled Areas - Foreign visitors are not allowed unrestricted access to SVSU facilities. The host shall ensure that the proper badge (provided by International and Advanced Studies Office) is worn at all times, and that the visitor does not enter areas unrelated to the visit, or where controlled data or hardware is unprotected. The rooms or offices selected for authorized disclosures shall be locations where technical discussion can occur without the possibility of releasing unauthorized information or inadvertent access of information due to physical proximity. The host will remove from the controlled area(s) any controlled technical data not authorized for access by the visitors. SVSU will then place any needed and releasable information in the controlled area(s). Technical discussion and all review of hardware, software, and documentation will occur only in the controlled area(s).

Uncontrolled Areas - Outside of the controlled area(s), all visitors who are foreign persons will be required to wear conspicuously a visitor identification badge. SVSU employee escorts must be familiar with the status of SVSU technical data as it pertains to export control. It is the responsibility of the escort to ensure that foreign persons do not have access to technical data unless access is permitted by a valid technical data license. In addition with respect to foreign person visitors, all relevant SVSU personnel will receive briefings on:

The technical data, if any, licensed for disclosure;
The requirements and limitations imposed by the license and any provisos; the areas and activities of the facilities to which the visitor will be given access; and
Visitor escort requirements and all other requirements of this website.

Foreign Persons Employees

Scope - Disclosure of technical data on the USML or controlled technical data on the CCL to foreign persons in the course of employment with U.S. contractors is considered an export and is subject to U.S. Government license. SVSU employs technical personnel possessing the highest caliber engineering and educational experience. Accordingly, SVSU may employ foreign persons, pursuant to the policy set forth below.

Foreign Person Policy - Foreign persons will not be involved on any work which involves the disclosure of technical data as defined in the ITAR or controlled technical data as defined in the EAR until a specific license has been granted. The following controls and procedures will assure physical access safeguards and adherence to DDTC and BIS authorized licenses.

Rules and Controls Governing Access to Technical Data

Members of the technical staff of SVSU who have supervisory responsibility for foreign persons must be briefed in those areas of export control and export licensing which are pertinent to their activities. Copies of this manual will be issued to all applicable supervisory personnel. All employees who work directly with foreign persons will also receive a copy of the manual and will be advised of their responsibility to ensure that only data authorized for export is transferred to the foreign person.

Technical data, subject to the provisions of the ITAR and controlled technical data subject to the provisions of the EAR, may be disclosed to a foreign person to the extent authorized under a DDTC or BIS export license, as applicable. Data authorized for access will be controlled by the supervisor to who the foreign person reports. The computer system databases and documents available to foreign persons will be strictly limited to technical data authorized for release.

Foreign Person Employment Agreement

New Employee Procedures - Foreign persons will be informed that an export license will be required from the U.S. Government before they can have access to hardware or technical data on the USML or controlled hardware and technical data on the CCL. Sponsored Programs will apply for this license. Foreign persons will be informed as to their responsibility to treat all technical information obtained during their employment at SVSU on a proprietary basis. Foreign persons will be provided a copy of this manual and will be made cognizant of, and responsible for, adherence to facility security rules, policies, and procedures relating on site regulations for personnel.

Non-Disclosure Statement - All foreign persons to whom technical data will be disclosed under license by DDTC or BIS will be required to sign a Non-Disclosure Statement.

Screening

Denied Party Screening - SVSU is prohibited from conducting export-related business with parties subject to denial orders (i.e., parties listed on the Department of Commerce Table of Denial Orders (TDO), parties specified on the Treasury Department Specially Designated Nationals List (SDNL), or parties subject to Department of State suspensions or debarments, without U.S. government licensing authorization. This prohibition covers intro-country transfers abroad of U.S.-origin goods and technology and the servicing of a denied party’s U.S. origin items. SVSU subscribes to an external service that combines all the published denied/debarred party lists from U.S. government agencies in searchable form. SVSU screens customers, supplies, consultants, and other business partners against this list. The database contains an internal record of searches performed.

SVSU IT Office screens email coming into SVSU through its website, looking for inappropriate or suspicious inquiries. These messages occasionally provide information identifying a specific transaction as suspect or intended for diversion. In those instances, proper U.S. Government authorities are notified immediately, following established reporting guidelines.

SVSU Policies

This page includes references to policies, practices and guidance commonly used for Sponsored Programs

Many of these policies can be found by visiting the University Policies and Procedures website and scrolling to the corresponding title.

Academic Research

Copyright Policy 1.0-6
Patent Policy 8.2-1
Reporting Misconduct in Science (8.3-1)
Sponsored Research & Consulting Relationships Policy 8.1-1
Animal Care and Use – See SVSU Institutional Animal Care and Use Committee webpage for processes, procedures and regulations.
Human Subject Research – See SVSU Institutional Review Board webpage for processes, procedures and regulations.

Administration

Operations Manuals Manual Policy Guide 1.0-1

Business & Financial Management

Facilities Use Policy 3.1-1
Financial Conflict of Interest 5.8-2
Insurance Policy 5.2-7
Outside Food Catering Policy 3.1-4
Purchasing Policy 5.2-1

Travel Meals and Expenses Policy 2.3-1
Indirect Cost Recovery & Distribution

Facilities and Property

Vehicle Policy 3.5-1

Human Resources

Vacation for Administrative Professional Staff 2.2-1
Administrative/Professional Employee Additional Earnings at SVSU 2.7-1

Contact Us

sponsoredprograms@svsu.edu
(989) 964-4295(989) 964-4295

Office

Wickes 314

Hours

8:00-4:30