At the request of the provost, a vice provost, or a vice president, this policy has been posted in the interim between scheduled posting dates by University Policy Manuals Group because it has significant and urgent importance for the university community. This policy will be included in the publication process by the next feasible posting for online policies and procedures.
RSP 004: Definitions
Terms used in this manual are defined as follows:
Determined by the federal Office of Management and Budget (OMB), the sponsor’s requirements, and/or university policy. OMB defines allowable costs as those that are:
2. allocable to the project
3. given consistent treatment by the use of generally accepted accounting procedures
4. conform to any limitation or exclusions set forth by the sponsored agreement or OMB authoritative references (see RSP 101, “General Research Policy”).
Funds provided from an external sponsor for support of a project at ASU. This term is used for both original awards and supplements; it can mean monies or equipment.
The spending plan for a proposal or award, submitted to and/or approved by the sponsor. Categories include salary, fringe benefits, materials and supplies, travel, student support, equipment, subawards, publication costs, facilities & administrative (F&A) costs, and other miscellaneous costs.
Documents or materials that have been designated as classified by an authorized government official.
Responsible for the negotiation, execution, and administration of user agency contracts involving classified material; each member of the Classified Material Management Group shall have an appropriate security clearance. MG shall be designated to review classified materials on behalf of Arizona Board of Regents (ABOR).
A collaboration exists when key personnel from different institutions have substantive involvement in the development and performance of the scientific aspects of a project and the sponsor chooses to make only one award, thereby requiring the lead institution to issue subawards to the other collaborating institutions.
Advantage uses specific state and local agency/organizations referred to as companion accounts to account for university funded direct cost project expenditures. The exclusive use of companion accounts for these expenditures permits the university to meet federal accounting requirements regarding sponsored project accounting.
The person who submits a written allegation of misconduct to the senior vice president for the Office of Knowledge Enterprise Development (OKED).
A specific clause in a contract that provides for protection of confidential proprietary information as allowed by Arizona Revised Statutes § 15–1640.
Additional funding increments for projects beyond the original grant period. See specific sponsor guidelines for submission requirements
An agreement to acquire, purchase, lease, or barter property or services. For an award to be considered a contract, it normally must contain all of the following elements:
1. detailed financial and legal requirements must be included with a specific statement of work to be performed
2. a specific set of deliverables and/or reports to the sponsor is required
3. separate accounting procedures are required
4. legally binding contract clauses must be included
5. benefits of the project accrue to the sponsor and to the university, then to the nation.
A complete and in-depth review and evaluation by the U.S. government of ASU’s purchasing system. This evaluation, currently performed by the Office of Naval Research (ONR), includes the Purchasing and Business Services system and the system established by the Office for Research and Sponsored Projects Administration (ORSPA) for procurements issued under sponsored projects.
Effort expended on a sponsored project that the sponsor does not compensate; a form of cost-sharing.
The portion of project or program costs not borne by the sponsor. Cost sharing should not be confused with other applications of internal university resources in support of non-project- or non-program-specific activities. Acceptable cost-sharing contributions must meet the following criteria:
1. are not paid by the federal government directly or indirectly under any other award, except where authorized by federal statute to be used for cost sharing or matching
2. are not included as contributions for any other project or program
3. are necessary and reasonable for proper and efficient accomplishment of specific project or program objectives
4. are directly identifiable with the sponsored project as outlined in the proposal budget and/or budget justification, and thus incorporated in the award notice
5. are verifiable by ASU records.
There are three types of cost sharing:
1. mandatory committed cost sharing is cost sharing required by the sponsor in the application request. It must be quantified in the sponsor award notice, budget, or accompanying narratives. Mandatory cost sharing binds the university to provide and account for resources used in completing the award.
2. voluntary committed cost sharing is NOT required by the sponsor but is included in the proposal budget, budget narrative, and/or quantified in the proposal narrative. Like mandatory cost sharing, voluntary committed cost sharing binds the university to provide and account for resources used in completing the award.
3. voluntary uncommitted cost sharing represents effort above and beyond commitments made in the proposal. It is not required by the sponsor and is not included in the proposal budget or budget justification. There is no contractual commitment by the university, nor is it tracked by the university.
A release of technology and/or software subject to export control regulations to a foreign national inside the United States. A deemed export is considered an export to the home country of the foreign national.
Those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
For the purpose of the Effort Reporting system, effort is all the work performed for compensation by the university. It does not include work done for supplemental pay. The total effort is always equal to 100 percent even if the employee is part-time or worked only part of the reporting period. If the employee is salaried and works more than 40 hours per week, total effort is still 100 percent.
Generally, an article of nonexpendable tangible personal property having a useful life of one year or more and an acquisition cost of $5,000 or more per unit. Equipment is not a replacement part or component returning a piece of equipment to its original condition. If a component increases the capability of the original equipment and has an acquisition cost of $5,000 or more, it is considered a capital item.
The (1) actual shipment or transmission of any goods or items subject to export control regulations out of the United States; and (2) release of any covered technology, software (including source code), or technical data to any foreign national whether in the U.S. or abroad.
The EAR, codified at 22 CFR Parts 730-774, govern the export of items or technologies that are commercial or “dual use” in nature (i.e., they have both military and commercial applications) and are identified on the Commerce Control List (CCL). The EAR are administered by the U.S. Department of Commerce, Bureau of Industry and Security, which is responsible for licensing exports of items on the CCL.
Governs the shipment, transmission, or transfer of certain sensitive items, information, or software to foreign persons or entities. Where applicable, authorization from the U.S. government in the form of an export license may be required. The sources of export control regulations include: the U.S. Department of Commerce (Export Administration Regulations or EAR); the U.S. Department of State (International Traffic in Arms Regulations or ITAR); and the U. S. Department of the Treasury (Office of Foreign Assets Control or OFAC).
Facilities and administrative costs.
Equipment that is constructed by combining or assembling modular components and/or materials into one identifiable unit. Procurement of the components and/or materials may preclude open competition and will require the cooperation of the principal investigator, Office for Research and Sponsored Projects Administration (ORSPA) personnel, and Purchasing and Business Services.
The rates used to recover the facilities & administrative costs of a sponsored project. Negotiated, approved rates are to be used for all agreements with the federal government and for most non-federal projects, as allowable. Information on current facilities and administrative cost rates is available from the Office for Research and Sponsored Projects Administration (ORSPA).
Those costs incurred for common or joint objectives that therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity.
Facilities & administrative costs are real, auditable costs incurred by the university each time it accepts an award for a sponsored project. If the university does not collect full reimbursement for these costs, other university resources must be used to subsidize them.
The position designated by the Arizona Board of Regents responsible for the oversight and handling of classified materials and obtaining, maintaining, and adequately controlling security clearances held by the university. The director of the Office of Research Integrity and Assurance (ORIA) currently serves in this capacity.
All rank of professors; visiting, clinical, and adjunct faculty; lecturers; and faculty associates.
A contract with the federal government stipulating responsibilities of institutional officials, Office of Human Research Administration, the Institutional Review Board, and principal investigators for the conduct of research involving human subjects.
In a “fixed price” award, the principal investigator/ASU agrees to accomplish project objectives within a specific timeframe for a set dollar amount. If the deliverables are not completed within the award period, the PI must continue the project until the deliverables are met. Although this may result in an extension of the project period of performance, an amendment to the agreement is not necessary. The award amount also remains constant, even if actual costs for the project are above or below the amount received from the sponsor.
A “foreign national” is anyone who is not a U.S. citizen, a lawful permanent resident of the U.S. (i.e., a “green card” holder) or a “protected individual” as defined in 8 U.S.C. §1324b(a)(3) (e.g., refugees or persons seeking asylum in the U.S.). A foreign national also means any foreign corporation, business association, partnership, or any other entity or group that is not incorporated or organized in the U.S., including international organizations, foreign governments and agencies, and subdivisions of foreign governments. Where a foreign national is a citizen of more than one foreign country, or has citizenship in one foreign country and permanent residence in another, the general rule is that the last permanent resident status or citizenship obtained governs.
Enacted in 1966, the Freedom of Information Act (FOIA) is a federal law that established the public’s right to obtain information from federal government agencies. The FOIA is codified at 5 United States Code §552. “Any person” can file a FOIA request, including U.S. citizens, foreign nationals, organizations, associations, and universities. In 1974, after the Watergate scandal, the Act was amended to force greater agency compliance. It was also amended in 1996 to allow for greater access to electronic information.
The solicitation of bids that is used to assure that all responsible bidders are permitted to compete for the procurement.
ASU’s proposed federal F&A rate without the 26 percent administrative cap imposed by federal requirements and final rate negotiations. In addition, this rate includes actual costs for the president’s office, general counsel, cost overruns, etc.
Basic or applied research in science and engineering performed or conducted at an accredited institution of higher learning in the United States where the resulting information is ordinarily published and shared broadly in the scientific community. Fundamental research is distinguished from research that results in information that is restricted for proprietary reasons or national security reasons (EAR) or pursuant to specific U.S. government access and dissemination controls (ITAR).
University research will not be deemed to qualify as fundamental research if:
1. the university or its researchers accept any restrictions on publication of the scientific and technical information resulting from the project or activity, other than limited prepublication reviews by research sponsors to prevent inadvertent disclosure of proprietary information provided to the researcher by the sponsor or to insure that publication will not compromise patent rights of the sponsor
2. the research is funded by the U.S. government and specific access and dissemination controls protecting information resulting from the research have been accepted by the university or the researcher. [The citation for the official definition of fundamental research under the EAR is 15 CFR §734.8; the ITAR citation is 22 CFR §120.11(8).]
A unilateral transfer of money, property, or other assets from a donor to the recipient for the recipient’s ownership and use, without restrictions on the recipient in connection with the gift. Unrestrictive gifts and grants normally have the following characteristics:
1. the Statement of Work allows the principal investigator significant freedom to manage the project and determine how the assets will be utilized
2. the award does not require deliverables or detailed technical reports
3. the award does not require separate accounting procedures or detailed financial reports
4. the award does not include provisions for audit by or on behalf of the sponsor
5. the award does not require regulatory oversight in areas such as animal care, human subjects, biosafety, or financial conflict of interest
6. the award does not utilize background intellectual property nor stipulate the ownership rights for foreground intellectual property.
An agreement to transfer money, property, services, or anything of value to accomplish a purpose, such as support or assistance in an area of interest to the grantor. For an award to be considered a grant, it normally will contain the following elements:
1. the statement of work allows the principal investigator significant freedom to change emphasis within the general area of work as the project progresses
2. deliverables are minimal, usually consisting of reports only
3. separate accounting procedures are required.
Any performance-based contract or award from a private, for-profit company with insufficient advance funding to cover current obligations.
A living individual about whom a researcher obtains:
Information from which the identity of the subject is or may be readily ascertained or associated.
The voluntary agreement obtained from a subject (or the subject’s legally authorized representative) to participate in research or related activity, before participating in that activity. The consent must permit the individual (or legally authorized representative) to exercise free power of choice without undue inducement or any element of deceit, fraud, force, duress, or other form of coercion or constraint.
Information-gathering and fact-finding to determine whether an allegation or apparent instance of misconduct warrants investigation.
A board or committee organized at the university to provide review at the institutional level for ethical concerns in research, such as laboratory animal care and the use of human subjects in research.
Communication or interpersonal contact between researcher and subject.
An agreement whereby two or more public agencies may contract with each other provided that such contracts are authorized by the governing bodies of each agency and that the contracts are executed in accordance with Arizona law (Arizona Revised Statutes § 11–951).
A process, effected by an entity’s management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in
1. effectiveness and efficiency of operations
2. reliability of financial reporting
3. compliance with applicable laws and regulations.
Any agreement with a foreign country or an agency of a foreign country (including companies, organizations, or governments), or any agreement in which the university will be acting in a foreign country.
The ITAR, codified at 22 CFR Parts 120-130, govern the export of articles, services, and related technical data that are inherently military in nature. The U.S. Munitions List (USML) identifies the defense articles, services, and related technical data that are inherently military in character and could, if exported, jeopardize national security or foreign policy interests of the United States. The ITAR are administered by the U.S. Department of State, Directorate of Defense Trade Controls.
Travel outside of the United States (i.e., the 50 states, the District of Columbia, and U.S. territories and possessions). A trip is considered international travel for all legs of the itinerary if the traveler does not return to his or her post prior to departure for an international destination.
Both physical procedures by which data are gathered and manipulations of the subject or the subject’s environment for research purposes.
The formal examination and evaluation of all relevant facts to determine whether misconduct has occurred.
The principal investigator and any other person (“investigator”) who is responsible for the design, conduct, or reporting of research funded in whole or in part by either a public funding entity or a private, for-profit funding entity or that is proposed for funding, in whole or in part, by either.
The OKED provides funds to principal investigators who gain external support for their research, service, and training activities. The purpose is to cover certain expenses associated with these activities and to develop additional programming (see RSP 106).
Written documents soliciting pricing and/or technical proposals to supply goods or services as specified in the requesting document. Use of RFPs constitutes full and open competition.
The academic unit to which the tenured or tenure-eligible principal investigator (PI) is assigned. This unit is designated on the faculty or academic professional’s Notice of Appointment or Joint Appointment. In the case of a Joint Appointment, an academic school, department or program appointment supersedes a center or institute appointment as lead unit.
Persons over 18 years, except where research involves the legal age for consumption of alcohol (21 years).
Mandatory Committed Cost Sharing
See Cost Sharing
Term often used interchangeably with “Cost Sharing.”
Materials shall mean tangible materials, including but not limited to research tools, biological materials, prototypes, and records used or produced in the course of university research projects.
The probability and magnitude of physical, psychological, or social harm that is normally encountered in daily life or in routine medical or psychological examination. In any assessment of degree of risk, the age of the subject must be considered.
Fabrication, falsification, plagiarism, and other practices that seriously deviate from those that are commonly accepted within the academic community for proposing, conducting, or reporting research. Instances of honest error and honest differences in interpretations or judgments of data are not considered misconduct.
Any change made to an existing sponsored agreement.
The portion of direct costs on which the facilities & administrative (F&A) costs are based, namely: salaries and wages, fringe benefits, materials and supplies, services, travel, and up to $25,000 on each subgrant and subaward.
The concept of “fundamental research” was established by National Security Decision Directive 189 (http://www.fas.org/irp/offdocs/nsdd/nsdd-189.htm), which established a national policy with regard to how such research should be treated for purposes of the various export control regimes.
Any agreement signed by both parties that agrees to protect proprietary or confidential information of one party or both for a specific period of time.
The Office of Foreign Assets Control, in the U.S. Department of Treasury, administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction.
A non-federal entity that provides a federal award to a subrecipient to carry out a federal program.
Typically, a faculty member who submitted a proposal that was accepted and funded by an external sponsor. The principal investigator has primary responsibility for technical compliance, completion of programmatic work, and fiscal stewardship of sponsor funds. See RSP 102 for further information on principal investigator eligibility requirements and RSP 103 for detailed principal investigator responsibilities.
Any private partnership, un-incorporated business, sub-chapter S corporation, or corporation to which an application for funding has been made or with which a contract for funding is being negotiated.
Information that an individual has provided for specific purposes and that the individual can reasonably expect will not be made public, or information about behavior that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place.
Program income means gross income earned by the awardee that is directly generated by a supported activity or earned as a result of a federal award during the period of performance. Program income includes but is not limited to income from fees for services performed, the use or rental of real or personal property acquired under federal awards, the sale of commodities or items fabricated under a federal award, and principal and interest on loans made with federal award funds.
For federal awards, if the federal awarding agency does not specify in its regulations or the terms and conditions of the federal award how program income is to be used, program income may be added to the federal award by the federal agency and the non-federal entity. The program income must be used for the purposes and under the conditions of the federal award.
Interest earned on advances of federal funds is not program income. Except as otherwise provided in federal statutes, regulations, or the terms and conditions of the federal award, program income does not include rebates, credits, discounts, and interest earned on any of them.
For more details on program income, see authoritative references in RSP 101, “General Research Policy.”
For non-federal awards, stipulations around program income should be addressed in the sponsor’s terms and conditions or by contacting the sponsor through the Grant & Contract Officer.
Any written presentation/application to a potential source of external funds, referred to as a sponsor, for a research or other sponsored project that provides pricing or cost estimates is considered a proposal. All proposals submitted by a university employee to an outside entity that may directly lead to a sponsored project award require initial review and coordination through the Office for Research and Sponsored Projects (ORSPA) prior to submission to a potential sponsor, utilizing a Proposal Routing and Approval Form. Proposals are generally grouped as formal proposals or preproposals:
Formal proposals prepared and submitted to a sponsor outline the scope of activities to be undertaken in response to sponsors’ Request for Proposal (RFP) or other requests from a potential sponsor (e.g., RFQ). Informal discussion may also result in the submission of a written formal proposal to be evaluated by the sponsor before a commitment is made to provide funds to support the program or project envisioned. All formal proposals require an institutional endorsement by an official authorized to commit university resources.
Preproposals (also referred to as informal proposals, letter proposals, miniproposals, preliminary proposals, pre-applications, concept papers, or white papers) are frequently requested by agencies in order to evaluate potential applicants. Preproposals require the signature of the lead principal investigator and approval by the Research Advancement staff member. If any university contribution/commitment is required, this should be discussed, in advance, with the appropriate parties. Please note that any university contribution/commitment outlined in a preproposal is subject to final review and approval if the preproposal is invited for submission as a formal proposal. Preproposals may take many forms, but typically the agencies request a brief summary (generally 2–5 pages) of the project, personnel, and cost estimate. Informal proposals do not involve a commitment of university resources or a signature on behalf of the university because they are not expected to result directly in an award. The purpose of an informal proposal is usually to inform and interest the potential sponsor reviewing such proposals and to persuade the sponsor to invite the applicant to submit a more detailed formal proposal application.
Any substantive change made by the principal investigator to the proposal after submission to a potential sponsor and before an award has been received.
Any agreement signed by both parties that agrees to protect proprietary or confidential information of one party or both for a specific period of time.
The federal government, any federal department or agency; all agencies, departments, boards, and commissions of the state of Arizona; counties; school districts; cities; towns; municipal corporations; and any other political subdivisions, including Indian tribal councils, of the state of Arizona or any other state.
Any public agency to which an application for funding has been made, or from which a grant has been received.
The institutional measurement that provides credit to investigators for their sponsored projects activities.
An actual shipment or transmission of tangible items, software, or information subject to export control regulations from one foreign country to another foreign country. The export or re-export of controlled tangible items, software, or information that will transit through a country or countries, or will be unloaded in a country or countries for reloading and shipment to a new country, or are intended for re-export to the new country, are deemed to be exports to the new country.
An employee who is employed to work for a period of six or more months at a minimum of 50 percent FTE.
Technology, software, or technical data is “released” for export through:
1. visual inspection by a foreign national of U.S.-origin equipment, facilities, or documentation
2. oral or written exchanges of information in the United States or abroad
3. the application to situations abroad of personal knowledge or technical experience acquired in the United States.
Interpreted in RSP 210, “Misconduct in Research,” to include scholarship and creative work, as well as scientific research.
All formal investigative efforts (whether funded or unfunded) by faculty, students, and staff that are designed to develop or contribute to generalized knowledge, including analyses of secondary data.
A percentage of the Facilities & Administrative costs recovered from sponsors by ASU that is returned to the responsible college as research incentive funds.
The researcher accused of misconduct.
Anything of monetary value, including but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights (e.g., patents, copyrights, and corresponding royalties). The term does not include:
1. salary, royalties, or other remuneration from ASU
2. income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities
3. an equity interest that when aggregated for the investigator and the investigator’s spouse and dependent children meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a three percent ownership interest in any single entity
4. salary, royalties, or other payments (excluding dividends) that, when aggregated for the investigator and the investigator’s spouse and dependent children over the next 12 months, are not expected to exceed $10,000.
The Select Agent and Toxin Program was established in its current form as part of the Patriot Act following the 2001 anthrax incidents. The program governs the use of all biological organisms or toxins that could potentially be used as agents of bioterrorism and is administered and overseen by the Center for Disease Control (CDC). The program requires that institutions that conduct research with any of these organisms/toxins register as participants of the program with the CDC. Each institution applying for participation must provide to the CDC information regarding the available layers of security, training, and medical surveillance. Prior to granting approval for participation, the CDC inspects each institution’s facilities and standard operating procedures. This inspection is repeated every two to three years, or if the institution changes any major aspect of its program.
SBU is information of a character such that its disclosure, loss, misuse, alteration, or destruction could adversely affect national security or other interests of the federal government. National security interests are those unclassified matters that relate to the national defense or the foreign relations of the U.S. government. Other government interests are those related, but not limited to, a wide range of government or government-derived economic, human, financial, industrial, agricultural, technologic, and law enforcement information, as well as the privacy or confidentiality of personal or commercial proprietary information provided to the U.S. government by its citizens.
Issuing an award to a subawarder without full and open competition. This may be done if an award is the result of a collaboration (where the ideas, concepts, and methodology were developed by the two parties jointly) or in those cases where performance of the prime contract would be jeopardized or delayed by going through the competitive process. There are restrictions on the use of this means of procurement under federally sponsored awards, and documentation must show justification for using single source acquisition.
A procurement that does not provide full and open competition, but is effected because only one source is available.
An application submitted by interested, eligible faculty or staff in response to a specific program announcement or call for proposals issued from a sponsor.
An external funding source that enters into an agreement with the university to support research, instruction, public service, or other sponsored activities. Sponsors include private businesses, corporations, foundations and other not-for-profit organizations, other universities, and federal, state, and local governments.
An “exchange transaction” between an external sponsor and the recipient under a grant, contract, cooperative agreement, purchase order, or any other mutually binding agreement that restricts the use of funds or property and stipulates conditions with which the university must comply. A sponsored project meets at least one of the following criteria:
1. the proposal responds to a formal RFA, RFP, or other formal solicitation and the project is initiated by a notice of award
2. the Statement of Work specifies programmatic objectives that are to be accomplished within a delimited period of time and budget
3. the award requires deliverables or detailed technical reports
4. the award requires separate accounting procedures and detailed financial reports
5. the award includes provisions for audit by or on behalf of the sponsor
6. the award involves the disposition of property, whether tangible or intangible, that may result from the project (e.g., equipment, records, inventions, copyrights, or rights in data)
7. the award requires regulatory oversight in areas such as animal care, human subjects, biosafety, or financial conflict of interest.
An award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of an award received by the pass-through entity. It does not include payments to a contractor for the procurement of goods and services or payments to an individual that is a beneficiary of a sponsored program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entitty considers a contract.
Non-federal entity that receives a subaward from a pass-through entity to carry out part of a sponsored project.
Includes but is not limited to: first-hand observations of the work being performed, written confirmation from the individual, physically verifiable information, notebooks, and/or sign-in sheets
Compensation for work performed for a different department or different duties beyond normal work assignment.
Additional support requested to assure adequate completion of the original scope of work.
Proposition 301, passed by the voters of Arizona in November, 2000, authorizes a 0.6 percent sales tax increase to support education. Approximately 20 percent of the funding will be spent on research related to the New Economy in Arizona’s three universities. Proposition 301 research funds are formally referred to as the Technology and Research Initiative Fund (TRIF) and are administered by the Arizona Board of Regents (ABOR).
Effort expended by PI’s and/or key personnel on a sponsored project that the sponsor does not compensate and/or require and is not considered a form of cost sharing.
University staff is an employment category comprised of non-academic staff and administrators. University staff are employed at will. As an at-will employee, university staff and ASU are entitled to terminate the employment relationship at any time and for any reason except an unlawful one.
A request for support submitted to a sponsor or donor without formal solicitation from the funding entity.
See Cost Sharing
See Cost Sharing
Policy implemented by some federal granting agencies that delegates certain prior approval authorities to grantee institutions. This delegation allows for internal university approval of administrative and spending actions, thus avoiding delays in project progress.
All property owned, used, leased, or controlled by ASU where university work is performed.
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University Policy Manuals Group,
ASU’s Office of General Counsel, 480/965-4550