• UW-Madison expressed concern about the portion of Section 6.B regarding the institution being “prepared to identify foreign sources and affiliated or subsidiary relationships that may not be explicitly stated,” and requested that an objective benchmark be provided for the requirement that institutions may be audited against.
    • The section was revised to indicate that if a foreign address is indicated during the negotiation of any gifts, grants, or contracts, the institution will take reasonable steps to investigate to determine whether the source of the funds is a foreign source subject to the reporting requirements of the policy.
  • UW-Milwaukee requested that the second half of Section 6.A.I be removed as it doesn’t accurately capture what is required to be reported to each agency. UW-La Crosse also asked for more clarity in the federal reporting requirements.
    • Language was added to clarify and specify the reporting requirements for each agency.
  • UW-Milwaukee recommended that Section 6.C.II be amended to only include communication with departments that have relevant information, and having to communication with all campus departments, regardless of whether or not they engage in transactions required to be reported, is likely to cause confusion.
    • In Section 6.C.II language was added to clarify any institutional departments likely to handle transactions.
  • UW-Milwaukee recommended eliminating the reference in Section 7 to Section 10339B of the Research and Development, Competition, and Innovation Act of 2022 until the reporting requirements of the CHIPS Act are finalized.
    • No change was made. While the CHIPS Act guidance hasn’t been finalized, we want to provide similar information for both reporting requirements. Enough information on the requirement has been released to provide that information.
  • UW System Administration requested clarification on the role of UWSA to review and compile the information reported from the institutions.
    • No change was made. These reports are public records that UW System can access and review from every institution as needed.