Covered Visitor  Policy

Preamble

The University of Michigan School of Information (UMSI) has developed this policy in consultation with the Office of General Counsel (OGC), Information and Technology Services (ITS) Information Assurance to establish clear, consistent procedures for requesting and obtaining sponsored accounts. This policy is intended to be consistent with the University's Covered Visitor policy (SPG 601.42), the ITS Sponsor System, and the Background Screening policy (SPG 201.95).

UMSI is committed to sustaining a robust and open intellectual and academic community while meeting institutional needs.

1. Purpose

This policy establishes the procedures and requirements for UMSI faculty and staff to request sponsored accounts for university-affiliated individuals who do not otherwise receive uniqnames and online identities. Sponsored accounts provide identity credentials and access to U-M and UMSI services, documenting an active relationship between the individual and the Regents of the University of Michigan.

All individuals receiving sponsored accounts pursuant to this policy (“Sponsored Individiuals”) are considered by UMSI to be  Covered Visitors under the University's Covered Visitor policy (SPG 601.42). By their nature, sponsored accounts grant access to university non-public resources. Accordingly, all requirements of the Covered Visitor policy apply to every sponsored individual. 

The primary goal of this policy is to ensure that requests for sponsored accounts are properly vetted, that required screening and compliance steps are completed, and that sponsored individuals receive appropriate access to non-public university resources.

2. Scope

This policy applies to all UMSI faculty and staff who request a sponsored account on behalf of an individual affiliated with the unit. 

3. Roles and Responsibilities

Requesting Faculty or Staff Member (Faculty/Staff Sponsor): The UMSI faculty or staff member who identifies the need for a sponsored account should initiate the request. The requesting faculty or staff member is responsible for providing a business justification, ensuring the sponsored individual's information is accurate, and overseeing the sponsored individual's activities during their engagement with UMSI and the University. 

UMSI Human Resources: Receives and processes sponsored account requests, performs the restricted status check in M-Pathways, coordinates background screening, and ensures compliance requirements are met before an account is created.

Principal Investigator (PI): When a Covered Visitor will be engaged in research activities, the PI is solely responsible for reviewing all applicable research agreements, grants, and contracts to determine whether the Covered Visitor may be granted access under the terms of those agreements. This includes verifying that no restrictions — such as citizenship requirements, export controls, or sponsor-imposed limitations — prohibit the Covered Visitor's participation. The PI must confirm this review is complete before the sponsored account request is submitted.

4. Required Information

UMSI collects the following information.  Some of this information must come from the faculty/staff member, some will come from HR.   Please use our form to request a new covered visitor.  The form makes it clear what information the requestor needs to provide.   

• UMID (if known)

• Uniqname (if existing)

• Last name

• First name

• Non-U-M email address

• Date of birth

• Visit mode (in-person, remote, or combination)

• Visit type (e.g., Covered Visiting Researcher/Scholar, Covered Visiting Student, Covered Visiting Affiliate/Colleague)

• Visit start date

• Visit end date

• U.S. citizen or permanent resident (yes/no)

• Other citizenship/visa information (if applicable)

• Immigration status (if applicable)

• Employer/home institution (enter "None" if not applicable)

• Employer title (enter "None" if not applicable)

• Source of funding (e.g., Employer/Home Institution, fellowship name, grant award)

• Highest degree earned

• Criminal background check screening status (UMSI HR WILL PROVIDE THIS) 

• Restricted party screening status (UMSI HR Only)

• Sponsor requestor (must be active UMSI faculty or staff)

• U-M location (or remote) 

• Associated project grant status (if applicable)

• Full description of the type of work being performed

• Any other Notes

5. Request and Approval Process

5.1 Initiate Request

The requesting faculty or staff member submits a sponsored account request to UMSI HR, including all required information listed in Section 4, a business justification, and the proposed start and end dates for the sponsorship. The maximum sponsorship duration under this policy is one year. 

If the Covered Visitor will be engaged in research activities, the PI must confirm in writing that they have reviewed all applicable research agreements, grants, and contracts and that no restrictions prohibit the Covered Visitor's access or participation.

You may start the request here: https://umsi.jotform.com/261254267640052 

5.2 Restricted Status Check

As part of their workflow, UMSI HR will determine whether the individual has an existing M-Pathways identity record and check for a restricted status code. If a restricted status is found, UMSI HR must obtain approval from University Human Resources (via sponsorship-audit@umich.edu) before the sponsorship can proceed. This step is required per university policy effective June 25, 2025.

5.3 Background Screening

This policy requires that all Covered Visitors whose activities could be performed under a faculty or staff role must complete a background screening prior to engaging in any such activities. UMSI HR will coordinate the background screening process. The sponsored account will not be created until the screening has been completed and cleared.

5.4 Additional Covered Visitor Requirements

Because all sponsored individuals under this policy are considered Covered Visitors by UMSI, the following steps must be completed before the account is created and the individual begins accessing non-public resources:

• Completion of Restricted Party Screening as required by the Office of the Vice President for Research and Innovation (e.g., Export Controls), if applicable.

• Completion of the Covered Visitor Application, retained in the department file.

• The Covered visitor must complete: 

  • A waiver of liability 

  • A Visiting Scholar/Scientist/Student Agreement (if applicable)

  • A non disclosure agreement (if applicable)

• UMSI HR and UMSI IT will enter all required information into the Covered Visitor Central Information System (CIS).

• International Center support for international Covered Visitors as appropriate (e.g., for those whose immigration-related documents are sponsored by U-M).

5.5 Account Creation

Once all screening, compliance, and approval steps are complete, UMSI HR will coordinate with the designated staff to create the sponsorship in the ITS Sponsor System and assign a regular uniqname. The sponsored individual will receive instructions for setting up their password either through the Sponsor System's standardized notification or through a customized communication.

5.6 Access Provisioning

Following account creation, the requesting faculty or staff member and UMSI HR should coordinate to grant appropriate access (e.g., building, computer, data systems, equipment, and facilities). This includes ensuring the sponsored individual obtains an appropriate M-Card, receives building access, and is added to relevant department email groups as needed.

6. Required Training and Policy Review

All Covered Visitors must complete the following university-required training and policy review, as applicable within 7 days:

• Sexual and Gender-Based Misconduct Policy and Training

• Protection from Retaliation / Building a Culture That Thrives: Preventing Retaliation

• Responsible Use of Information Resources (SPG 601.07)

• Information Security (SPG 601.27)

• Reporting Requirements and Compliance Resources

• Required Disclosure of Felony Charges and/or Felony Convictions (SPG 601.38)

• Responsible Conduct of Research and Scholarship training (if applicable)

• Research Ethics and Compliance (if applicable)

• Environment, Health, and Safety training (if applicable)

• Radiation Safety Services (if applicable)

• HIPAA (if applicable)

The requesting faculty or staff member is responsible for ensuring that the Covered Visitor completes all applicable training before or promptly upon beginning their engagement with UMSI.  Failure for the covered visitor to complete training will result in the termination of covered visitors' access to non-public information. Confirmation of completion must be emailed to umsi.human.resources@umich.edu within 7 days of the visit’s start date. If the sponsored visitor does not complete training their access will be terminated and they will be unable to reapply for one year. 

7. Renewal

When a sponsorship approaches expiry, the requesting faculty or staff member must confirm whether renewal is needed. If renewal is approved, the following steps apply:

• The requesting faculty or staff member submits a renewal request to UMSI HR.

• If the Covered Visitor is engaged in research activities, the PI must re-confirm that all applicable research agreements, grants, and contracts permit the Covered Visitor's continued access and participation.

8. Offboarding

When a sponsorship expires or is terminated:

• The Covered Visitor must save any files, email, or other data to a non-U-M location before the sponsorship ends. Access to all computing services terminates on the expiry date with no grace period.

• Coordinate access changes and property returns, including keys, badges, equipment, and other physical assets.

• Update the individual's status in the Covered Visitor CIS or interim tracking tool.

• Conduct an exit interview as appropriate.

• Coordinate International Center support for international Covered Visitors as applicable.

• Retain all letters, forms, and agreements for the Covered Visitor in accordance with university records retention policies.

• Complete the covered visitor onboarding checklist. 

9. Policy Review

This policy will be reviewed annually by the policy owner and updated as needed to reflect changes in university policy, the Covered Visitor SPG, ITS systems, or UMSI operational needs.