— Academic Affairs — Compliance — Compliance Areas — Export Control Office — CITI Training

CITI Training

To ensure we comply with federal laws and regulations, UNMC provides a training program for personnel who do or may engage in activities subject to export controls.

All personnel involved in or supporting export-controlled activities must comply with all applicable U.S. laws and regulations while teaching, conducting research, or participating in other activities at or on behalf of the university.

Such personnel must complete training through the Collaborative Institutional Training Initiative Program, an online training platform. We require a passing score of 80% for each assigned module to validate training through CITI. Once completed, CITI training is valid for three years.

Register for CITI

Generally, most training requirements can be satisfied by completing the prescribed CITI module(s). In some cases, we may require you to complete additional CITI modules and/or in-person training, depending on the nature and sensitivity of the activity.

Important: Be sure to read our guide with instructions for creating a CITI account, using an existing account not yet affiliated with UNMC/UNO, and adding the export control training track to an existing account already affiliated with UNMC/UNO.

CITI Details

Scope

Training Standards

Cohorts

These standards apply to all UNMC personnel engaged in or proposing to engage in activities subject to export controls. Activities subject to export controls include, without limitation:

Research subject to restrictions on the dissemination of results
Research subject to restrictions on participation by foreign persons
Research involving the use of items subject to export controls
Travel to embargoed or sanctioned countries for the purpose of conducting, presenting, or otherwise supporting research or other activities on behalf of UNMC
Establishing institutional relationships with restricted entities or entities in embargoed or sanctioned countries
Exporting controlled items, including shipping, traveling internationally with items subject to export controls, and deemed exports

Personnel requiring training are divided into cohorts depending on the nature of the activities they engage in and their role in those activities. All cohorts must complete at least an introduction to export compliance and an overview of federal sanctions programs.

Our office may also require in-person training for activities subject to elevated security requirements, such as research projects covered by technology control plans or travel to embargoed or high-risk destinations. In-person training is tailored to the personnel and the specific controlled activity they are engaging in.

We may also prescribe additional training or awareness measures not explicitly described in this policy. This may include completion of additional CITI modules, briefings by federal law enforcement or counterintelligence authorities, or other measures we deem appropriate in light of the nature and sensitivity of the activities UNMC personnel propose to engage in.

Cohort 1: Academic and research personnel

This cohort includes principal investigators, co-investigators, visiting scholars, postdoctoral researchers, students, volunteers, technicians, support staff, senior leadership, and anyone else engaging in the activities described in this section, irrespective of whether they are compensated for doing so.

Academic and research personnel include:

Personnel directly involved in the design, conduct, or reporting of export-controlled research
Personnel who may need access to controlled items (including hardware, software, materials, or data) in order to conduct or support research
Support staff within academic and research units who are not directly engaged in gathering or analyzing research data but perform other functions in support of research activities (like purchasing goods or services, scheduling travel, assisting with funding proposal submissions, coordinating access to UNMC resources, etc.)
Deans, chiefs, and associate deans for research in colleges or departments where export-controlled activities are taking place

Cohort 2: Administrative personnel

This cohort includes personnel in administrative units whose functions support export-controlled activities directly or indirectly.

Such administrative units include:

Sponsored Programs Administration
Purchasing
Human Resources
Environmental Health and Safety
General Supply and Mail Services
Information Technology Security
International Health and Medical Education
UNeMed

Cohort 3: Other personnel

This cohort includes faculty, staff, students, and other personnel who travel internationally (especially to embargoed countries) or provide support for export-controlled activities that does not place them in another cohort.

Cohort 4: Export Control Office Personnel

The personnel of the Export Control Office are committed to providing the highest level of service, and therefore are responsible for staying up to date on regulatory and policy changes.

Training Matrix

Note: Required training modules must be completed to fulfill the cohort's training requirements. At least two elective modules must be completed to fulfill the cohort's training requirements. Supplemental modules may be completed voluntarily in addition to any require and elective modules.
CITI Module	Cohort 1: Research & Academic Personnel	Cohort 2: Administrative Personnel	Cohort 3: Other Personnel	Cohort 4: Export Control Office
Introduction to Export	Required	Required	Required	Required
Export Compliance for Researchers (Part I)	Required	Supplemental	Elective	Required
Export Compliance for Researchers (Part II)	Required	Supplemental	Elective	Required
Export Compliance for Research Administrators	Elective	Elective	Elective	Required
Export Compliance when Using Technology in Research	Elective	Supplemental	Elective	Required
Export Compliance and Biosafety	Elective	Elective	Elective	Required
Export Compliance for Operational Departments	Supplemental	Required	Elective	Required
Export Compliance for International Shipping	Elective	Elective	Elective	Required
Export Compliance and Purchasing	Supplemental	Elective	Elective	Required
Export Compliance and International and Foreign Waters	Supplemental	Elective	Elective	Required
Export Compliance and Collaborations	Elective	Elective	Elective	Required
Compliance Compliance and Distance Education	Supplemental	Elective	Elective	Required
Export Compliance and United States Sanctions Programs	Required	Required	Required	Required