International Research and Service Projects: Risk Management Procedures
If a sponsored project proposal involves international research or service, the principal investigator or departmental administrator responsible for the proposal should notify the appropriate project officer in Sponsored Projects Administration (“SPA”) as early as possible. Through a series of questions, the project officer will determine whether the project requires further review. The goal is to identify only those types of international projects that might need special assistance (e.g., a project requiring a long-term formal presence in another country or one operating within a country that is subject to sanctions). The questions are listed on the Criteria Questionnaire (Annex A of the Procedures). If the answer to one or more of the Criteria Questions is “yes,” the project officer will seek additional information about the project (Annex B of the Procedures). If warranted, the project may then be referred to the International Research Committee for further review.
For international research and service projects that do not route through SPA (e.g., projects using start up funds, internal awards, or gift funds), principal investigators and departmental administrators can access Annex A and B as a fillable PDF or Microsoft document. Completed Annex A and B forms should be submitted to Columbia’s Office of Research Compliance and Training ([email protected]) as early in the project lifecycle as possible and prior to the start of the project. The Procedures are not designed to second guess the scholarship of a project or to hinder the grant application process. The process is not intended to delay the review and submission of grant applications and, if necessary, can be completed after an application has been submitted. However, the process runs most efficiently when information is provided in a timely manner, as significant lead time is often required—for example, to file necessary registrations or obtain sanctions and export licenses.
After the project has been funded, a more extensive post-award review may occur. Some of the questions considered at that point are detailed in the Post-Award Review (Annex D of the Procedures). Highly complex projects may require further post-award review by an ad hoc committee.
Resources such as the Office of the General Counsel, the Office of Research Compliance and Training, and other offices within the University are available to provide legal, financial and other support to assist international project teams in finding solutions for implementing their service and research goals.
