Two Important Federal Legal Requirements

Dear Members of the Research Community,

We write to remind you of two important federal legal requirements related to sponsored projects:

  1. Certification of current and pending/other support (per Section 223 of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021)

Federal law requires principal investigators and senior/key persons to:

  • disclose the amount, type, and source of all current and pending research support received by, or expected to be received by, the individual as of the time of the disclosure;
  • certify that the disclosure is current, accurate, and complete; and
  • update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award.

Currently, funding agencies vary in their implementation of the certification requirement.  Information related to specific funding agency requirements is available on the Funding Applications and Progress Reports Disclosure page of the University’s Science and Security website.  If you are uncertain whether to make a disclosure, we recommend that you err on the side of transparency.  Please contact your Sponsored Projects Administration project officer with questions.

  1. Prohibition against use of certain telecom or video surveillance equipment (per Section 889 of the National Defense Authorization Act for Fiscal Year 2019)

The U.S. Government prohibits Columbia from using certain telecommunications or video surveillance equipment, produced by certain companies, as a substantial or essential component or as critical technology for any system.  These rules, which apply to all recipients of federal funding, also prohibit the use of federal funds to procure or obtain covered telecommunications equipment or services.  These restrictions apply to all purchases completed through a University Purchase Order, P-Card, AP Voucher or reimbursement of a personal charge through Concur.

“Covered telecommunications equipment or services” are:

Telecommunications equipment or services produced by Huawei Technologies Company, ZTE Corporation, or any subsidiary or affiliate of these entities; and

Video surveillance technology and equipment or services used for certain public safety, physical surveillance, or national security purposes and produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, or any subsidiary or affiliate of these entities.

For more information about this prohibition and to access lists of the prohibited companies and their subsidiaries and affiliates, please visit Research Compliance and Training’s Economic Sanctions and Restricted Parties webpage. 

For Procurement-related questions, please contact Hugh Horowitz, Procurement Services, at [email protected].  For questions about this restriction more generally, please contact Michelle Avallone, Director of Export Controls and International Engagement, at [email protected].

Thank you for your attention to these important requirements.


William Berger
AVP for Sponsored Projects Administration

Hugh Horowitz
AVP for Procurement

Naomi Schrag
VP for Research Compliance, Training and Policy

December 14, 2022