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Compliance Notice

This compliance notice is to ensure that the Northern Illinois University community is aware of the restrictions imposed by Section 889 of 2019 National Defense Authorization Act (NDAA) - Prohibition on Certain Telecommunications and Video Surveillance Services or Equipment. The university's ability to continue to receive grants and contracts from the Federal government – our largest source of sponsored research – is dependent on compliance with this federal regulation. Therefore, it is important that you read this notice in its entirety.

General Compliance Responsibilities

General compliance responsibilities for the Northern Illinois University community include:

  • Do not procure covered telecommunications equipment or services, as defined below.
  • Do not provide covered telecommunications equipment or services to the U.S. Government.
  • Do not use or operate covered telecommunications equipment or services.
  • Notify the Ethics and Compliance Office ( immediately if you become aware of any covered telecommunications equipment or services being used by or procured for the University, and/or prior to making any representation to the U.S. Government in connection with Section 889 of the 2019 NDAA.
    • If you are using any covered telecommunications equipment or services for externally funded research, you must also immediately notify the Office of Research Compliance and Integrity (
  • General questions can be submitted to

Covered Telecommunications Equipment or Services

"Covered telecommunications equipment or services" is defined to mean, telecommunications equipment produced by:

  • Huawei Technologies Company or ZTE Corporation
  • Any subsidiary or affiliate of Huawei or ZTE (view list)
  • For the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure and other national security purposes, video surveillance and telecommunications equipment produced by:
    • Hytera Communication Corporation
    • Hangzhou Hikvision Digital Technology
    • Dahua Technology Company (or any subsidiary or affiliate of such entities)


Section 889 of the 2019 NDAA contains prohibitions on the use and procurement of "covered telecommunications equipment or services". Absent a specific waiver provided by a federal agency, Northern Illinois University may not procure covered telecommunications to perform work for a federal grant or contract or use "covered telecommunications and surveillance equipment or services" anywhere in its operations or processes, even if unrelated to a federal grant or contract. Because the university has received federal contracts that include the NDAA prohibitions, this use restriction is applicable immediately.


Section 889 of the 2019 NDAA is implemented through the Federal Acquisition Regulations (FAR) (52.204-24; 52.204-25; 52.204-26) for federal contracts and Uniform Guidance (2 CFR 200.216) for federal grants.

  • The prohibition on using federal loan or grant funds to procure or obtain covered telecommunications equipment or services became effective August 13, 2020 (2 CFR 200.216).
  • The prohibition on federal contractors providing covered telecommunications equipment or services to the U.S. Government became effective August 13, 2019 (FAR clause 52.204- 24 contains the representation: Offeror..." will" or " will not" not provide covered telecommunications equipment or services to the government...)
  • The prohibition on federal contractors using covered telecommunications equipment became effective Aug. 13, 2020 and applies " regardless of whether that usage is in performance of work under a Federal contract." As a result, the University must provide a representation to the U.S. Government whether or not it is using covered telecommunications equipment or services (FAR clause 52.204-24) as part of normal university operations. And, there is a one business day reporting requirement upon identification of covered telecommunications equipment or services during contract performance (FAR clause 52.204-25).

Next Steps

Several university units including the Office of General Counsel, Office of Ethics and Compliance, Divisions of Research and Innovation Partnerships, and Administration and Finance are developing an institutional policy and procedures to assist campus and Principal Investigators with managing this restriction. Additional information is forthcoming.

Frequently Asked Questions

My department, office or lab is not funded by the U.S. Government. Do the prohibitions against using covered telecommunications equipment or services apply to my work at Northern Illinois University?

Yes, the prohibition on using covered telecommunications equipment or services applies regardless of whether the use is in performance of work under a federal contract.

If I have a personal cell phone that is covered telecommunications equipment (e.g. a Huawei phone), may I continue to use it?

Do not use the cell phone for university work. However, you may use the cell phone for personal use.

Does it matter if the equipment or service being used was purchased prior to the effective date of these laws/regulations?

No, the prohibition on use of covered telecommunication equipment or services applies regardless of when the equipment was purchased or when the services were initiated.

My department or the university has identified covered telecommunications equipment that was purchased for our departmental use. Are we responsible for replacing this equipment immediately?

No, contact the Ethics and Compliance Office as noted above. NIU will assess the action that needs to occur, and next steps will be determined and communicated.

Northern Illinois University (“NIU” or “university”) is committed to addressing harassment and promoting safety, accountability, equal access, and ethical behavior in the university's educational and workplace environment. All applicable university policies, including the University’s Nondiscrimination, Harassment, and Retaliation Policy and Complaint Procedures (“Nondiscrimination Policy”) and Sexual Misconduct Policy and Complaint Procedures (“Sexual Misconduct Policy”), apply to all staff, faculty and students whether on-campus, off-campus or engaging in scholarly activities or study at an off-site location affiliated with the university.

In addition, it is NSF policy to “foster safe and harassment-free environments whenever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. NSF’s policy recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific environments where individuals can learn, grow, and thrive. Accordingly, for each proposal to conduct research off-campus or off-site, NIU, through Sponsored Programs Administration, must certify that the university has a plan in place for that proposal that describes how the following types of behavior will be addressed:

  1. Abuse of any person, including, but not limited to, harassment, stalking, bullying, or hazing of any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; or
  2. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.

The plan must also: 

  • Identify steps that NIU will take to nurture inclusive off-campus and off-site work environments; and 
  • Include a process for making incident reports and how any such reports will be resolved. This includes procedures for communications within the team and to the organization that addresses limited communication pathways or other special circumstances that may impede reporting of suspected non-compliant behavior. 


Dara Little
Associate Vice President for Research

Sarah Garner
Ethics and Compliance Officer

The underlying premise is that all participants need to know how to recognize and report inappropriate behavior and receive guidance in advance about how to feel safe and protected, even when they are away from campus. 

To comply with the NSF requirement (as well as applicable university expectations), Principal Investigators will need to:

  1. Determine whether any “off-campus or off-site research” will occur on their NSF-funded award that will require a plan. Plans are only required for NSF-funded awards containing research that is conducted off-site or off-campus. NSF defines off-campus or off-site research as data/information/samples being collected off-site, such as fieldwork and research activities on vessels and aircraft.
  2. Certify their determination and that a plan is in place as part of the InfoEd proposal routing process. Use the template and guidance provided on this page to determine the need for, and development of, the plan.
  3. Distribute the plan to everyone who will participate in the off-campus or off-site research activity prior to departure.
  4. Retain documents related to any individual who received the plan (e.g., email or signup sheet) and the plan itself in their departmental NSF files.
  5. Make plans available to SPA or NSF upon request. (PIs should assume that plans will be requested.)

If individuals are subjected to the conduct described in this guidance, as defined by NSF and/or applicable university policy, during off-campus or off-site research, the following resources are available: 

  • File Title IX Report/Complaint: Individuals can file a sexual misconduct report or complaint with the university. There are important differences between what happens when a report or a complaint is filed.
    • Title IX Complaint: An individual who has been subjected to sexual misconduct has the right to file a formal complaint with the university. A complaint triggers the university’s formal grievance process. You may file a sexual misconduct complaint online at File a Sexual Misconduct Report or Complaint - NIU - Ethics and Compliance Office, or by contacting the Title IX coordinator in-person, over the phone or via email or mail to discuss what happened.

      NIU Title IX Coordinator
      Sarah Garner
      Health Services Building 230

    • Title IX Report: Any third party who witnesses or learns of actual or suspected sexual misconduct may submit a report. A report informs the harmed party of their rights and options to address what they have experienced. You may file a sexual misconduct report online at File a Sexual Misconduct Report or Complaint - NIU - Ethics and Compliance Office, or by contacting the Title IX coordinator in-person, over the phone or via email or mail to discuss what happened.
      • Responsible employees: All employees of the university, unless deemed confidential, are considered responsible employees and are required to report actual or suspected sexual misconduct to the Title IX coordinator. Responsible employees are required to submit reports.
  • File Discrimination/Harassment Complaint: Any individual who experiences or witnesses possible acts of discrimination or harassment by an NIU employee as defined by the university’s Nondiscrimination Policy has the right to report the activity. You may file a complaint online at Discrimination/Harassment - NIU - Ethics and Compliance Office, or by contacting the ECO, over the phone or via email or mail to discuss what happened.

  • Confidential: An individual may request to remain completely anonymous or that their name or details surrounding the incident not be disclosed during the investigation process, which is called a request for confidentiality. If requested, the Title IX coordinator will determine if confidentiality can be afforded. An NIU confidential advisor can also provide assistance with accessing and navigating campus and local health and mental health services, counseling and advocacy services. To speak with a confidential advisor, contact the Center for Student Assistance, at 815-753-8300 and ask to speak to Andrea Drott. Questions may also be referred to the U.S. Department of Education, Office for Civil Rights, by contacting

  • External Agencies: Filing a report or complaint with the university does not constitute filing a police report. To file an official police report for incidents occurring off-site, please contact the appropriate local police department where the prohibited conduct occurred.

Research at Northern Illinois University has traditionally and routinely been performed at a high level of quality and scholarly integrity. In order to continue this tradition, it is necessary faculty, staff and students participate in continuous Responsible Conduct of Research (RCR) training and compliance with NIU’s RCR Policy.  
RCR is composed of the following topics:

  • Research Misconduct
  • Data Acquisition and Management
  • Responsible Authorship and Publication
  • Peer Review
  • Mentoring
  • Conflicts of Interest
  • Collaborative Research
  • Animal Care and Use
  • Laboratory Safety
  • Human Subjects Research

The research community has recognized personal and professional rewards from training in the Responsible Conduct of Research. All National Science Foundation,  National Institute of Health Training, and United States Department of Agriculture (NIFA) grants require RCR training for certain types of personnel receiving salaries or stipend support on these awards. Even researchers who do not have the requirement will benefit from the training, which strengthens and broadens the ethical awareness surrounding research. While online training is always available, NIU also offers in-person training from the RCR Forum Series to better serve the community and meet the increased demand for training.
Principal Investigators receiving a new NSF award on or after July 1, 2023, will need to ensure that all undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel supported by the proposed research project receive RCR training. Principal Investigators and key personnel have three months from the start date of their award to complete the training. Personnel in all other positions must complete the training within a year.
Responsible authorship is necessary to academic integrity. NIU faculty, staff, and students are asked to follow the guidelines in our Authorship Policy when writing articles or publications.

Authorship disputes can arise. See Guidelines for Avoiding and Resolving Authorship Disputes.


What is SciENcv?

Science Experts Network Curriculum Vitae (SciENcv) is an electronic system that allows researchers to prepare key personnel documents required for federal grant proposals. SciENcv helps faculty gather and compile information on expertise, employment, education, and professional accomplishments to be incorporated in biographical sketches and documents outlining research support. The system allows researchers to enter and select relevant information and produce documents that meet the requirements of the funding agencies to which they are applying.

Why should I know about SciENcv?

The National Science Foundation (NSF) will require the use SciENcv to prepare biographical sketches and current & pending (other) support for proposals submitted on or after October 23, 2023. Use of SciENcv will also be required for any key personnel documents submitted after this date related to post-award requests (e.g., if adding a new Co-PI).  

While other sponsors are not requiring the use of SciENcv at this time, many are requiring that individuals certify that the information on their biographical sketch and/or current and pending support information is accurate in order to comply with National Security Policy Memo -33. SciENcv allows key personnel to easily comply with these requirements.

Why should I be excited about SciENcv?

Once the system is populated with your information, the process of creating or updating key personnel documents is streamlined. SciENcv ensures that your biographical sketch and current and pending support information meets sponsor requirements and takes the guesswork out of formatting.  

What sponsors are participating?

The SciENcv project is led by the National Institutes of Health (NIH) and is heavily supported by the National Science Foundation (NSF).

The system can create:

  • NSF Biographical Sketches
  • NSF Current & Pending (Other) Support
  • NIH Biographical Sketches for Research & Fellowship projects
  • Institute for Education Sciences (IES) Biographical Sketches

Some programs within other sponsors, like the Department of Energy, have aligned requirements for biographical sketches and current and pending support with NSF requirements and encourage users to create these documents using SciENcv.

How long will it take to set up my account?

We recommend allowing 1-2 hours for the initial setup of your SciENcv account. The actual amount of time needed will depend on the information that is available in your current accounts that can be imported into SciENcv.  Researchers can delegate access to other users to enter information.

What else should I consider when setting up my account?

We highly recommend setting up your ORCID before beginning the SciENcv registration process.  ORCID will allow you to import publications and current grant funding into SciENcv. ORCID allows you to claim publications from a variety of journals and manually enter other publications and funded grant activities.

You may also import publications from NIH’s MyBibliography and PubMed Central. If you have a MyBibliography account, any publications tied to that account will be available automatically in SciENcv.

Publications can also be uploaded from Reference Management software like EndNote or RefWorks.

If your work is available in any of these systems, the initial setup process can be completed quickly. If your publications are not available in these systems, they can be entered manually. You can also enter information about your current projects manually. All proposal information will need to be entered manually. Once you enter the information during the initial setup, it will be saved in your profile, and you can easily select items when preparing future documents.

What accounts can link into SciENcv?

  • NCBI MyBibliography
  • eRA Commons

How do delegates work?

Researchers can assign a delegate, who will then have access to prepare documents in their account. Delegates can prepare or edit documents, but if individual certification is required, the delegate cannot download files until the individual has certified it. Delegates should be someone familiar with the work being proposed, like a graduate student or a post-doc. Please do not add SPA or research development staff as delegates.

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Indirect Cost Rates Introduction and Pre-Award


Contact Us

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DeKalb, IL 60115-2828

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