Faculty & Staff

Columbia University has a policy entitled International Research and Service Projects: Risk Management Procedures in recognition that some projects involve special risks. The risk management procedures provide a mechanism for the University to inquire as to what risks should be considered and how they should be managed.

The procedures specify that there will be:

• Early identification of large, complex, or high-risk international projects
• Initial review of such projects, in the grant/contract application stage, to spot major issues (the review should not delay the submission of a grant/contract application)
• A more comprehensive review when it is certain that a project will be funded
• Ongoing, regular monitoring of certain projects

The following summarizes key procedures. PIs should be familiar with the entire policy found on the University’s Research Compliance & Training website.

Criteria

Generally, only those projects that meet one or more of the following criteria will be reviewed:

1. The direct costs of the project exceed $1 million per year, of which at least 50% will be expended outside the United States (either directly or through one or more subawards).
2. The project involves ongoing University operations in a non-U.S. country, such as the establishment of an office, leasing of space, or an on-the-ground presence for more than a nominal period.
3. The project is located in, is funded by, or involves a collaboration with persons in a country on the Treasury Department’s Office of Foreign Assets Controls (OFAC) list of embargoed countries at http://www.treas.gov/offices/enforcement/ofac/programs.
4. The project involves the use of high risk materials (e.g., radioactive materials or certain biologic materials).

Notification to Research Administration

The risk management procedures for the notification stage are as follows:

• The PI or Department Administrator notifies the appropriate RA Project Officer of his/her intent to submit the funding application, providing maximum time for pre-application review of the project proposal.
• The RA Project Officer asks the PI or Department Administrator the questions set forth in the Criteria Form.
• If a proposal is entered into RASCAL or InfoEd, the system asks whether the proposal involves international research or service. If it does, and the RA Project Officer has not already done so, he/she will call the PI or Department Administrator and ask the questions set forth in the Criteria Form.
• If an RA Project Officer, upon review of any proposal, ascertains that the project involves international research, he/she calls the PI or Departmental Administrator and, if not already done, asks the questions set forth in the Criteria Form.
• If the project is to be funded by a gift, the initial notification to Research Administration is coordinated through the Office of University Development and Alumni Relations.

International Research Questionnaire

If the project meets the above criteria, the PI should notify Research Administration as early as possible of the intention to apply for funds for the project. The RA Project Officer will ask the PI or Department Administrator to complete the questions set forth in the International Research Questionnaire found at http://www.cumc.columbia.edu/research/website/3/5/21/.

The Associate Vice President for Research Administration and the Director of the Office of Research Compliance and Training (ORCT) will determine on the basis of the International Research Questionnaire whether the questionnaire should be reviewed by the International Research (IR) Committee. If not, the Project Officer will notify the PI or Department Administrator. If so, the Project Officer will forward the International Research Questionnaire to the IR Committee and so notify the PI or Department Administrator. After its review of the proposal, the IR Committee will either notify the PI or Department Administrator that no further review is needed or work with the PI to resolve any questions.

If any issue needs further discussion, the proposal will be referred to the appropriate senior administrator for review. All issues will be addressed and resolved with the PI as expeditiously as possible.

Post-Award Steps

After a proposal is funded, the project will be reviewed for financial, legal, and operational risks by the IR Committee or an ad hoc committee appointed by the Chair of the IR Committee.

If appropriate, the Finance Division will work with the PI and the Mailman School Associate Dean for Finance to establish a set of financial controls and an ongoing monitoring plan for the project, and the appropriate structure for the project and a plan for mitigation of legal risks, as needed.