It is possible for a billing agreement to be issued from a non-sponsored source of funds under similar circumstances as sponsored billing agreements but with variations in the process based on the specific circumstances. Contact the SPA SRA assigned to your department for more information on non-sponsored billing agreements.
Export controls have the potential to apply to any exchange – physical or intellectual – with a foreign national or foreign country. And, if not for exclusions set out in the Export Control Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) (see...
Whether external funds allow for or prohibit overhead does not affect the determination of whether those funds represent a gift or a sponsored award. All sponsored awards that prohibit overhead (and all gifts whose terms prohibit payment of the gift assessment) must meet the approval of the cognizant School before the University can accept them.
Moreover, the classification of funds as gifts or sponsored awards is dependent on the terms and conditions accompanying the funding. The amount of overhead or the amount to be set aside for gift assessment does not have any bearing on...
Reporting is an important aspect of all award types. Donors are entitled to know that their donation was spent for the intended purpose. The more detailed the reporting is, both in terms of specificity and frequency, the more likely the award is not a gift, and is instead a sponsored award. However, it is important to remember that reporting requirements alone are not determinative of the classification of external funds as a gift or sponsored award.
If it is determined that your activity requires an export license, yourExport Control Administrator will work with you to submit a license request to the appropriate regulatory body on your behalf. It is important to note that obtaining an export license from the Commerce Department usually takes 30 days; a license from the State Department can take several months; and a license from the Treasury Department can take 3-6 months. Although there is no guarantee that a license will be granted, all three regulatory licenses have granted licenses... Read more about How do I apply for an export license?
Work with your Export Control Administrator to make this determination. Determining whether an export is subject to a licensing requirement is a complicated process that necessarily involves a full understanding of the item. Whether something is controlled for export is not intuitive. License requirements are dependent upon an item’s technical characteristics, the destination, the end use, and the end user.