Notice of Account End Date

If your project is ending, the following steps should be taken in order to ensure an orderly closeout:

1. Submit requisitions in a timely manner so that all materials and supplies can be received
and used on the project by the end date. Auditors are likely to disallow post-term or retroactive cost transfers on expired accounts.

2. Check all encumbrances for validity. Invalid encumbrances should be cancelled.

3. Request LPL Payroll Representative to remove all payroll encumbrances by the term date.

4. Notify LPL Business Office to change/remove account numbers for long distant charges and copy cards

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Final Reporting Requirements

Final Technical Report - NASA, Department of Defense (Navy, Air Force, Army and DARP) and Space Telescope Science Institute have a requirement for Final Technical and Progress Reports. The PI is responsible for preparing and submitting all required technical reports and deliverables to the sponsor, per the agreement. Final Technical Reports must be completed and submitted to the sponsor AND also to the Office of Navel Research (ONR) within ninety (90) days of the term date. Failure to submit the reports can result in lost funding for your self and your colleagues in the Lunar and Planetary Laboratory as well as other University of Arizona departments. Delinquent reports can reflect negatively on the quality of your research and often lead to the involvement of the Head of the Lunar and Planetary Laboratory as well as the Vice President for Research and Graduate Studies.

If you are not able to complete the Final Technical Report within the 90 days you need to request a time extension from the sponsor and submit the request through the Lunar and Planetary Laboratory Business Office. Time extensions must be submitted prior to the term date of the award.

NASA and DoD have delegated to the Office of Naval Research (ONR) the administration of their award to you. A copy of your Final Technical Report is required to be submitted to the LPL Business Office, Doug Hilyard, Sponsored Projects Administrator and ONR. You must submit the report to:

Beth Swing
Contract Administrator
140 Sylvester Road
Bldg. 140, Rm 218
San Diego, CA 92106-3521

Phone:(619) 221-5489
Fax: (619) 221-5615 and 5616
e-mail: beth.swing@navy.mil

NASA Center for AeroSpace Information (CASI)
Attn: Document Processing Section
7121 Standard Drive
Hanover, MD 21076
email: eft_ftp@sti.nasa.gov

The Air Force Office of Scientific Research (AFOSR) shares administrative over site on AFSOR awards with the Office of Naval Research. Both the AFOSR and ONR must receive a copy of the Final Technical Report. You must submit the report to Renee Luna (see above) and to:

AFOSR/PK
4015 Wilson Blvd, Room 713
Arlington, VA 22203-1954

E-Mail Address: pkcontracting@afosr.af.mil
Phone Contact: Beverly Sivels (703) 696-9732
FAX: (703) 696-9733

The Space Telescope Science Institute (STSI) – Grantee shall submit the final report within ninety (90) days of the end of the grant period, to the Grants Administration Office via the electronic Grants Management System (GMS)

If you can not complete and submit the Final Technical/Progress Report to the sponsor and ONR within the 90 days closeout period, you need to request a time extension from the sponsor through the Lunar and Planetary Laboratory Business Office. Time Extensions must be requested before the end date.

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Invention Reports

NASA, Department of Defense (Navy, Air Force, Army and DARP) and Space Telescope Science Institute each require a final invention report. By e-mail, Sponsored Projects Services will send to the Principal Investigator and the Lunar and Planetary Laboratory Business Office the appropriate invention report form. The e-mail includes completion and return instructions. You need to complete and return the form to the LPL Business Office as soon as possible for processing. Sponsored Projects Services will obtain the signatures from the Office of Technology Transfer and mail the report to your sponsor and the Office of Technology Transfer.

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Requesting a No-Cost Extension

If a PI needs additional time to complete a project, a no-cost extension can be requested. Identify the project number PI name and the period of time you are requesting along with a brief description of what will be accomplished during the extension period (research related justification).

If the project is issued under the terms of the Federal Demonstration Partnership (FDP), the University of Arizona can approve a one-time no-cost extension up to twelve months automatically. One-time no cost extension should be submitted in writing through the LPL Business Office.

Sponsors may require the request for a no-cost extension be submitted on-line. Please check sponsor regulations prior to submitting a written request.

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Requesting a Grant Transfer to a New Institution

The requirements for transferring a grant to a new institution vary by sponsor. The PI should consult with the Business office well in advance of the anticipated transfer date to ensure a smooth transaction. Please check the individual sponsor’s policy manual for specific instructions.

All grant transfer requests must have the written approval of the Director or Department Head and then forwarded to Sponsored Project Services for institutional countersignature.

The written requests should include the name of the new institution and the effective date of the transfer, an estimate of the unexpended balance that will be relinquished as of the transfer date.

When leaving the University of Arizona, a PI may have pending proposals that have a chance of being funded. Some sponsors require that the UA relinquish their interest in the proposal, so that if it is funded, the new institution will receive the award. Contact Sponsored Projects Preaward if your sponsor requests a letter relinquishing your proposal to the new institution.

In addition, the University requires an internal form to be completed. This form can be found at http://www.sps.arizona.edu/forms.

Complete both the letter and the form. Bring it to the Business Office for signature and processing.

If equipment purchased on the grant will also be transferred a separate letter needs to be submitted. This letter needs to be addressed to the Sponsored Projects Property Administrator. Please contact the Business Office Property Coordinator prior to submitting a request. Equipment transfers require the approvals of the Director or Department Dead, Dean, SPS Property Administrator and the Vice President for Research before equipment may be transferred. See FRS Department Manual, Section 15.33.

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Export Control Compliance & Foreign Visitors

EXPORT CONTROL

Compliance of the export control regulations is necessary for the protection of national security interest. Penalties for violations of the regulations can be severe for the university, principal investigator and all other personnel working an export controlled project. Therefore, it is important that all University of Arizona personnel involved in research activities be aware of and comply with all export control laws.

All UA units that engage in research and other activities which involve controlled technologies are required to designate an individual who will be responsible for assisting faculty and other research personnel with the identification of export issues and managing export compliance at the department level. The Lunar and Planetary Laboratory Department Export Control Administrator (DECA) is trained to assist you with reviewing grants and contracts to identify export restrictions, screening of foreign nationals and assisting Principal Investigator’s with item classification, coordinating with the University Export Control Officer the submission of various export related forms and recordkeeping. The DECA for the Lunar and Planetary Laboratory is Rose Griffin located in the Kuiper Space Sciences Building, Rm. 345 (rose@lpl.arizona.edu).

What are Export Controls?

Export Controls are the regulations that require federal agency approval before the export of controlled items, commodities, technology, software or information to restricted foreign countries, persons and entities (including universities)

Who Controls the Regulations?

There are three main sets of regulations that require the need for concern with export controls. They are the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the regulations under the Office of Foreign Asset Controls (OFAC).

The ITAR falls under the Arms Export Control Act and controls defense services, defense articles and related technical data; items designed or developed for military use. The United States Munitions List (USML) contains the list of controlled items. These regulations are administered by the Department of State. The agency responsible is the Directorate of Defense Trade Controls (DDTC).

The EAR falls under the Export Administration Act and controls the export of “dual-use items (civilian or military uses). The Commerce Control List (CCL) contains a list of controlled items. These regulations are administered by the Department of Commerce’s Bureau of Industry and Security (BIS).

OFAC is part of the U.S. Department of Treasury and administers and enforces economic and trade sanctions. They control the list of sanctioned countries, Blocked Persons List, Specially Designated Nationals List, Denied Persons List, and the Debarred Parties List. The UA has a contract with a vendor that supplies a database to screen these lists. Contact Rose Griffin in the Business Office to conduct a screening.

Export Control Indicators (proposal stage):
Provide LPL DECA a copy of the RFP or AO prior to submitting the proposal

• Export Control Language
• Requirements for security plans
• References to DoD
• References to Prohibited Countries
• Sponsor is a foreign entity
• Clear military component to research
• References to “classified” information
• Key words and acronyms
• Publications restrictions
• Foreign National’s restrictions

What is an Export?

• Sending or taking defense articles or technical data outside the United States.
• Disclosing or transferring technical data to a foreign person whether in the United State or abroad
• The performance of a defense service on behalf of, or for the benefit of, a foreign person whether in the United States or abroad.

An export occurs whenever the release of technology or software (including source code) to a foreign national, even if the release takes place in the United States (deemed export). Examples of a deemed exports are: disclosure at lectures, meetings, conferences; lab access; release of source code.

What is Technical Data?

• Information, other than software, which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles. This includes information in the form of blueprints, drawings, photographs, plans, instructions, and documentation.
• Classified information relating to defense articles and defense services.
• Information covered by an Invention Secrecy Order.
• Software that is directly related to defense articles.

What is a Defense Service?

• The furnishing of assistance (including training) to foreign persons, whether in the United States or abroad, in the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of defense article.
• The furnishing to foreign persons of any technical data as defined in ITAR paragraph 120.10, whether in the United States or abroad.
• Military training of foreign units and forces, regular and irregular, including formal or informal instruction of foreign persons in the United States or abroad or by correspondence courses, technical, educational or information publications and media of all kinds, training aid, orientation, training exercise and military advice.

Export Administration Regulations (EAR)

Some exports may fall under the restrictions imposed by the EAR, which are administered by the Department of Commerce (DOC), Bureau of Industry and Security.

Items subject to the EAR are those items and technologies specifically identified under an Export Control Classification Number (ECCN) on the Commerce Control List. Items under the jurisdiction of the DOC and not described under ECCN are referred to as “EAR99” items. EAR99 items generally consist of low-technology consumer goods and do not require a license in many situations. If your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern or in support of a prohibited end-use, a license may be required.

If the item is “subject to the EAR” a license may be required to export the item or technology, either through a physical export of the item or a deemed export (a release of technology or source code to a foreign national in the United States) to a foreign national. No license or other authorization is required for any export transaction subject to the EAR unless the EAR affirmatively states a requirement. The circumstances under which a license must be obtained are consolidated into ten General Prohibitions. There are major factors that determine whether an export is subject to one of the ten General Prohibitions.

All UA ECCN determinations must be reviewed and approved the UA Export Control Officer.

Licensing Requirement (ITAR)

The export of a defense article or technical data that is identified on the United States Munitions List requires a DDTC approved license. There are several types of license application forms depending on the type of export or import and the nature of the export or import. If you require a license for controlled hardware or technical data the License Questionnaire for U.S. Government Export Application can be found at:

http://orcr.vpr.arizona.edu/export-control/processes

Export of Technical Data (Technical Assistance Agreement)

In addition to export licenses, the ITAR provides a mechanism whereby DDTC can authorize ongoing relationships between the U.S. and foreign nationals or companies for the exchange of “unclassified” technical data and the provisions of defense services. The most common agreement used by LPL is the Technical Assistance Agreement (TAA). A TAA is an agreement for the performance of a defense service(s) or the disclosure of technical data. Such arrangements must be described in an agreement submitted to DDTC for approval. Written approval must be received by the DDTC prior to the exchange of any technical data.

If a license or agreement is going to be submitted, begin the process at least 120 days in advance of the actual transfer to allow time for document submission, review and decision.

If you need to submit a TAA for review the Agreement Questionnaire for U.S. Government Export Applications can be found at:

http://orcr.vpr.arizona.edu/system/files/Questionnaire%20for%20TAA%20Rev2.pdf

Complete the form and submit it to the LPL DECA. The LPL DECA will work with the university Export Control Officer (ECO) to prepare DRAFT TAA. Or if you prefer, call the LPL DECA directly to arrange a meeting with the university Export Control Officer to discuss the project in detail and allow the ECO to gather the required information for drafting a TAA.

Export Control Indicators in Non-Disclosure Agreements (NDAs) and Proprietary Information Agreements (PIAs)

• Export control language
• Security requirements
• Required certifications about nationality
• Requests for information regarding nationality

The office of the Vice President for Research is required to review any agreement that contains export control language. The Checklist for Export Control Issues will assist the Export Control Officer to determine if research project will be subject to the export control regulations. The form can be found at:

http://orcr.vpr.arizona.edu/system/files/Export%20Checklist%20rev%207%20041410.pdf


Technology Control Plan

A Technology Control Plan (TCP) is a document that lays out the requirements for protecting export-controlled information and equipment for projects conducted on the UA campus. The UA has a TCP template for use on projects requiring this document. It can be found at:
http://orcr.vpr.arizona.edu/export-control/processes


International Travel

It is unlawful to hand-carry technical data or hardware outside the U.S. without appropriate authorization and documentation.

Transporting your laptop, PDA, flash drives, or other electronic devices to certain countries or the software on the electronic devices as well as any technology or technical data may require export authorization. Taking a laptop to certain restricted countries (N. Korea, Iran, Iraq, Cuba, Rwanda, Syria, and Sudan) or using it in connection with certain export-controlled activities, or taking a laptop that contains defense-related technical data will require an export license or an OFAC license and in some cases, may require both.

If the devices are not needed for the trip, DO NOT take them. If you must have them, remove any information that is not needed for the trip.

Laptop Travel Policy: UA faculty, students, or other employees traveling outside the U.S. intending to bring laptops or other data storage equipment, must ensure that there is no export-controlled information on the devices unless there is a specific license or other authorization in place for that information to that destination. International travelers should notify the DECA of their travel plans prior to making their travel plans.

Presentations and Publications: The PI is responsible for ensuring that no export-controlled data or technology is included in the presentations or publications by the project personnel.

Restricted Party Screening

University personnel must screen individuals who will involved in export controlled projects or transactions to ensure that we are not doing business with individuals or companies that may be identified on government “prohibited lists”. The University uses software called “eCustoms” that electronically goes through this process. Rose Griffin has access to “eCustoms” and has the ability to do the screening against multiple lists that will ensure that the individual, company or export is not prohibited. Individuals should also be screened before sending out letters of acceptance to students and new hires as well as visiting scholars.

Foreign National Visitors

A foreign national is an individual who is not 1) a U.S. citizen; or lawful permanent resident (Green Card) or 2) A protected individual (political asylum).

The LPL DECA should be advised of every foreign visitor regardless of the reason for visit or whether or not they will be paid or unpaid. LPL has several export controlled projects located in all three buildings. Prior to allowing a foreign visitor to participate or have possible access to Export Control Restricted areas requires prior approval. Some projects may be required to submit a Technology Control Plan to the ECO before access can be approved.

If you are expecting a foreign national visitor please complete the “Lunar and Planetary Laboratory Visitor Questionnaire prior to the visit so the LPL DECA can make certain that we are not violating any export control regulations. The LPL Visitor Questionnaire form is at: ttp://www.lpl.arizona.edu/resources/business/forms.php.

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