Administrative Considerations

PIs write letters of support sponsoring matriculation of foreign persons to UMassD. Before PIs send visiting scholar letters, the OIEC must approve them. If the letter involves a high-risk discipline or anyone from Country Groups D and E, the Dean and / or PI must forward the letter to OIEC for review and approval. In addition, regardless of the type of visa requested, PIs are required to submit a copy of all visiting scholar letters to the International Student and Scholar Center. The International Student and Scholar Center maintains copies of all visiting scholar letters, passports, and visas of all international visitors to UMassD. See also: ISSC Visiting Scholar Appointment Information, Policy on Honorific Appointment.

New students must report their nationality and visa status when applying for admission. A human resources employee requests that students present original documents evidencing their nationality and visa status. Human resources maintains copies of these documents in the students’ record. UMassD works under the presumption that Immigration and Customs Enforcement screens and clears students before issuing U.S. visas. The UMassD Graduate Admissions Office approves changes to accepted students’ majors. The Graduate Admissions Office screens for restricted persons requesting to change their major to high-risk disciplines. Prior to approving the change, the Graduate Admissions Office requests OIEC review and approval. At the time a research project is identified as restricted, the PI must request nationality information for all students he or she intends to involve in the project and determine whether a license is required for any student.

The UMassD accepts contributions of cash and property from donors globally. Regardless of the donor’s country of residence, acceptance of a gift of any kind must comply with all US laws and regulations, the laws of the country of origin, and UMassD institutional policies. In alignment with export control procedures and screening requirements for gifts and donations, the OIEC must review in-kind donations of equipment, technology, or materials that may be export controlled.

Any person with knowledge of an export-control violation, or noncompliance with TCP provisions, export control regulation, or UMassD export control guidelines and procedures shall immediately report the circumstances surrounding the activity to his/her supervisor. The reporting can also be accomplished by calling the Director of Institutional Ethics & Compliance (DIEC) via email at export.compliance@umassd.edu. Where required, UMassD shall disclose violations to the proper authorities in accordance with applicable regulations and laws.

Audits systematically review and monitor approved research activities to ensure that researchers follow all safeguards and conduct research as approved. OIEC conducts audits regularly and as necessary to ensure compliance with the UMassD guidelines, procedures, export licenses, and technology control plans.

Audit objectives include but are not limited to the following:

• Understanding and assessing the adequacy of management policies designed to comply with export control laws and regulations;
• Documenting and evaluating controls implemented to ensure compliance with policies;
• Through testing, determining the effectiveness of the controls in place and, if necessary, recommending revisions to improve effectiveness;
• Monitor compliance of research projects and departments with export license requirements, technology control plans and these compliance guidelines;
• Identifying possible violations.

OIEC audits include, but are not limited to, the following:

• Record keeping;
• Hiring policies and practices;
• Screening students and related guidelines;
• Foreign national procedures;
• Licensing practices;
• Training and education;
• Technology Control Plan reviews;
• Emergency stop & hold procedures;
• Updates to policies, procedures, and forms to reflect any regulatory changes;
• Review procedures for supervisory sign-offs, and task and information collaboration between departments.

Audit objectives include but are not limited to the following:

• Understanding and assessing the adequacy of management policies designed to comply with export control laws and regulations;
• Documenting and evaluating controls implemented to ensure compliance with policies;
• Through testing, determining the effectiveness of the controls in place and, if necessary, recommending revisions to improve effectiveness;
• Monitor compliance of research projects and departments with export license requirements, technology control plans and these compliance guidelines;
• Identifying possible violations.

OIEC audits include, but are not limited to, the following:

• Record keeping;
• Hiring policies and practices;
• Screening students and related guidelines;
• Foreign national procedures;
• Licensing practices;
• Training and education;
• Technology Control Plan reviews;
• Emergency stop & hold procedures;
• Updates to policies, procedures, and forms to reflect any regulatory changes;
• Review procedures for supervisory sign-offs, and task and information collaboration between departments.