Export Controls and IT Security Ancillary Reviews Procedural Change
Effectively immediately Export Control and IT Security Ancillary Reviews will no longer be requested at proposal stage.
Since the launch of CERES, when a proposal contained language that was not aligned with Northwestern polices or procedures (e.g., restrictions on the participation of foreign nationals, strict cybersecurity regulations, FISMA), Sponsored Research (SR) would ask the department to submit an ancillary review to Export Controls or IT Security. We found that this was not the most practical approach in these time-sensitive situations and have decided to change the process.
Going forward when a proposal contains language that is not aligned with Northwestern polices or procedures:
- At proposal stage, SR will document in the Funding Proposal (FP) record that there are problematic terms that would need to be negotiated at award stage. The PI will be alerted if there are terms that may prohibit the university from accepting an award, to confirm they accept this risk.
- If awarded, SR will route an ancillary review request to Export Controls and/or IT Security for a full review prior to award acceptance.
As a reminder, this change applies only to Export Control and IT Security reviews at proposal stage. Other Ancillary Reviews required at proposal stage, including PI Eligibility Waivers, F&A Waivers, or Organizational COI clearance, should continue to be routed as needed.
Visit the Northwestern Knowledge Base to read more about Ancillary Reviews in CERES.