Closer Look: Frequently Asked Questions Regarding CUI

So, you have controlled unclassified information (CUI) or are assessing your project for CUI compliance.  We've put together some frequently asked questions to help our research community navigate this compliance initiative that centers on the protection of data.

The Revised Common Rule for Human Subjects Research Takes Effect January 21, 2019

The U.S. Department of Health and Human Services and 15 other federal departments and agencies have issued revisions to the “Federal Policy for the Protection of Human Subjects” (also known as the Common Rule). These changes take effect on January 21, 2019.

CUI Training Tools

Does your research project involve controlled unclassified information (CUI)? Compliance requirements in accordance with DFARS/NIST 800-171 include training requirements. (See our previous article on "What is Controlled Unclassified Information?")

The U.S. National Archives website includes a section with CUI Training Tools, including links to training modules by topic, videos, powerpoints and more.

NSF: Notification Requirements Regarding Findings of Sexual Harassment, Other Forms of Harassment, or Sexual Assault

The final version of NSF’s award term and condition entitled, “Notification Requirements Regarding Findings of Sexual Harassment, Other Forms of Harassment, or Sexual Assault” was published on September 21, 2018, in the Federal Register. A link to this Federal Register notice, as well as other important information regarding this important topic (including Frequently Asked Questions regarding the term and condition), is available at:


NIH Foreign Influence Memo from Dr. Francis Collins

On September 17, 2018, a memo was released by Rafael Bras, Provost and Executive Vice President for Academic Affairs, and Chaouki T. Abdallah, Executive Vice President for Research, titled "NIH Foreign Influence Memo from Dr. Francis Collins."

Use of eRouting Required Effective January 1, 2019

The Office of Sponsored Programs began the implementation of eRouting, an online system for proposal submission, in July 2017. To date all schools, centers, IRIs and colleges should have  their individual workflows implemented so that they are using eRouting to route proposals through appropriate internal approvers prior to it being received in OSP. Effective January 1, 2019, OSP will no longer accept paper proposal routing forms.

New NASA Statements on Discrimination and Harassment Policies

NASA Policy Statement on Anti Discrimination in NASA Conducted or Funded Programs, Activities and Institutions

NASA Administrator Jim Bridenstine issued a policy statement on September 11, 2018, reaffirming NASA's commitment to equal opportunity among the many education and research institutions nationwide that receive NASA grant funding or that participate in agency-conducted programs.

NSF: Next Steps Against Harassment

For more information, see NSF's press release.

What NSF is doing:

The National Science Foundation (NSF) will release a term and condition requiring awardee organizations to report findings of sexual harassment. It will be posted in the Federal Register Sept. 21, 2018 and go into effect Oct. 21, 2018.

Why NSF is doing this:

RCR Status Reports Now Available in GTCrossroads

A set of five Responsible Conduct of Research (RCR) Status Reports is now available for use through GTCrossroads (via Cognos Reports). The reports provide timely RCR training status information for employees funded by NSF, NIH, and USDA-NIFA projects that have RCR requirements, as well as RCR training status information for any individual with a GTID.

(Extension!) New Common Rule: Federal Policy for the Protection of Human Subjects

IMPORTANT:  This article was updated on April 30, 2018, to reflect an update on Common Rule implementation. 

On April 19, 2018, HHS released an NPRM proposing to delay the general compliance date for the revised Common Rule until January 21, 2019. A 30-day comment period will be open until May 21, 2018.

In addition to delaying the general compliance date, the NPRM proposes to allow institutions to implement three "burden-reducing provisions" of the revised rule during the delay period:


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