Kelly:
You can read the series at DFAR 209-470 to get a sense of the law being implemented through 252.209-7005, Reserve Officer Training Corps and Military Recruiting on Campus, which is prescribed for use in all solicitations and contracts with institutions of higher education. Start here: http://www.acq.osd.mil/dpap/dars/dfars/html/current/209_4.htm#209.470-4
If you look closely at paragraph (b)(4) of the DFAR itself, it details 8 specific pieces of information. 5 of the 8 would seem to require institutional student records - not just student directory information (name, address, phone). Your institutional compliance officer would be able to tell you if the institution's compliance program accommodates the requirements. I do not consider this a negotiable issue - although there is a carve-out for schools with “a long-standing policy of pacifism based on historical religious affiliation.”
We do comply because we enjoy monies originating in DOD agencies - especially DTRA. (I'm thinking of ordering "DTRA ♥ Vanderbilt" t-shirts for one of my groups of engineers.)
I hope this helps a little. Good luck!
With kind regards, Madison
Madison Gray, J.D.*, C.R.A., C.C.R.P.
Senior Assistant Director
Office of Contract & Research Administration (OCRA)
Vanderbilt University
email: xxxxxx@vanderbilt.edu
phone: 615-343-1374
*Not legal counsel for Vanderbilt University. The Office of the General Counsel is the only authorized legal counsel for Vanderbilt University.
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-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Kelly DelFatti
Sent: Wednesday, February 15, 2012 2:05 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] DTRA Terms & Conditions
Hello,
Does your educational institution have grant or contract from the Defense Threat Reduction Agency (DTRA)? If so, may I contact you off-list, or can you please provide advice on the following.
The DTRA administrative requirements/terms and conditions include a section about Military Recruiting. Specifically, this section requires that recipients (that are institutions of higher education) provide access to directory information pertaining to students.
Please advise if you comply with this requirement, or if you have you successfully negotiated it out. I will appreciate any feedback!
Thanks very much
Kelly
--
Kelly L. DelFatti
Director of Sponsored Research
Lewis and Clark College
Phone: 503.768.7211
Fax: 503.768.7105
Email: xxxxxx@lclark.edu
http://www.lclark.edu/college/offices/sponsored_research/
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