Sponsored Program Services News

Important Information from the NIH and NSF

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Dear Investigator,

On July 10th, the National Institutes of Health (NIH) published a reminder on NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components.  This was followed on July 11th by a Dear Colleague Letter on protecting research funded by the National Science Foundation (NSF) from NSF Director, Dr. France Córdova. These notices relate to the ongoing concerns regarding foreign influence in federally funded research.

In response to these publications, the OVPR recommends that any collaborations with foreign entities or individuals, or appointments with foreign entities (including foreign talent or similar programs) be disclosed to the NIH or NSF program officer, your Dean, and the OVPR (contacts and additional information listed below).

The OVPR has posted additional guidance on our site regarding Active and Pending Support and Foreign Collaborations. For any questions or for guidance on this and other related matters, please contact:

Thank you for your cooperation,

Radenka Maric, PhD
Vice President for Research
UConn/UConn Health

Important Information from the NIH and NSF for UConn/UConn Health Investigators

The NSF Letter references the draft NSF Proposal and Award Policies & Procedures Guide published in May 2019.  Clarifications in the draft Guide related to current and pending support and biographical sketches include:

  • Providing information for all current and pending support irrespective of whether such support is provided through the proposing organization or directly to the individual.
  • Expanding examples of current and pending support to include non-profit organizations and consulting agreements.
  • Reporting all projects and activities requiring a time commitment (no minimum has been established), even if the support received is only in-kind.
  • Appointments should include any titled academic, professional, or institutional position whether or not remuneration is received.

The Dear Colleague Letter also states the NSF will be issuing a policy that NSF personnel and Intergovernmental Personnel Act (IPA) assigned personnel cannot participate in foreign government talent-recruitment programs.

The NIH Notice reminds applicants that in regards to Other Support, they must:

  • List all positions and scientific appointments, both domestic and foreign, held by senior/key personnel which are relevant to an application including affiliations with foreign entities or governments such as titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
  • Report all resources and other support for all individuals designated in an application as senior/key personnel – including the program director/principal investigator and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. All current support for ongoing projects must be included, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual who supports the senior/key personnel’s research efforts.
  • Report all current projects and activities involving senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees), including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support.
  • Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel.

The Notice also reminds applicants of the need to determine whether projects include a foreign component, defined as the existence of any “significant scientific element or segment of a project” outside of the United States including:

  • Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
  • Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

If a significant portion of a project will be conducted outside the United States, then there is a foreign component and NIH prior approval is required.  If all project activity is conducted within the United States, but there is a non-U.S. resource supporting the project, it must be reported as other support.

Sponsored Program Guidance during the Partial Federal Government Shutdown

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Updated: 12/27/2018 with additional agency specific guidance and information.

Effective Saturday, December 22nd at 12:00am, appropriations for fiscal year 2019 for approximately 25% of the federal government expired. Agencies who have full appropriations and are not currently impacted by the partial shutdown include Veterans Affairs, Department of Defense and Department of Health and Human Services (including NIH). Agencies that are impacted by the partial shutdown include the National Science Foundation, Department of Agriculture, Department of Transportation, Department of State, Department of Justice and NASA.

Interim guidance for agencies impacted by the partial shutdown is provided below. Additional guidance will be provided if the shutdown persists. If you have specific questions about a proposal or award, please contact Sponsored Program Services.

Proposals

  • If the electronic system for submission is operating, the proposal should be submitted by the deadline in the solicitation in accordance with standard practice.
  • If the electronic system for submission is not operational or offline, the proposal will not be submitted until further guidance is received from the federal sponsor. To be safe, SPS recommends that you prepare your proposal for submission as best you can by the published deadline, even if it cannot be submitted.
  • Currently Grants.gov and FastLane (NSF submissions) is available and operational.

Award Management

  • Current funded awards may continue regular activities and incur normal expenses (exception: NSF payments systems are not operational – contingency plans will need to be further discussed if the shutdown persists longer than a couple weeks).
  • Contact SPS prior to charging any major or capital expenses.
  • UConn may not receive new awards during the shutdown.
  • Sponsor required prior approval requests (i.e. No Cost Extension requests) may not be approved during the shutdown.
  • Please contact SPS with specific questions about your award.

 

Agency Specific Guidance during the Shutdown

NSF

https://www.nsf.gov/shutdown/grantees.jsp

  • No new funding opportunities will be issued.
  • FastLane and Research.gov is available for most functions but NSF will not process proposals or prior approval requests until normal operations resume.
  • Annual and final project reports should be submitted by the due date however they will not be processed and continuing grant increments will not be issued.
  • No new grants or cooperative agreements will be awarded.
  • No prior approvals and no payments will be made during the shutdown.

 

Additional Agency Specific Guidance and Information

UPDATE: Partial Federal Government Shutdown, 12/27/18

NASA

If your grant or cooperative agreement requires access to a NASA facility or participation from NASA personnel in order to perform the instrument’s stated research objectives, the guidance in paragraph (a) below is applicable.  If your grant or cooperative agreement does not require access to a NASA facility or participation of NASA personnel in order to perform the instrument’s stated research objectives, the guidance in paragraph (b) below is applicable.

 

    1. To the extent the grant or cooperative agreement includes work performed on-site at a NASA facility, the NASA facility will not be available for the performance of such work beginning on December 26, 2018.  You are instructed to commence an orderly shut-down of your onsite operations and you are to preserve resources and take all actions necessary to minimize costs incurred under the subject grant or cooperative agreement during this Government shutdown.  This includes notifying your employees immediately of this orderly shutdown. Contact Sponsored Program Services immediately if this applies to your award.

 

  1. Since your grant or cooperative agreement does not require access to a NASA installation, access to NASA IT resources and data, or participation of NASA personnel in order to perform the instrument’s stated research objectives, you are to continue to perform research under your grant or cooperative agreement as long you have available funding.  Special Condition 1260.53 Incremental Funding (for awards subject to 14 CFR Part 1260) or Term and Condition 1800.921 Incremental Funding (for awards subject to 2 CFR Part 1800) of your grant or cooperative agreement specifies the total amount of funding that has been allotted to your grant or cooperative agreement.  You are also reminded the Agency is not obligated to reimburse your institution for the expenditure of amounts in excess of the total funds allotted to this grant or cooperative agreement. Your institution is not authorized to continue performance beyond that period covered by the allotted funding and is cautioned to closely manage all available funding, as additional funding will not be provided while the Agency is without appropriations.  Any research performed during this time period should be carefully planned, taking into account that NASA technical and administrative personnel will not be available to support these activities during the Government shutdown. Expenses and work should not exceed the funding and time of the award even if additional funding and time is expected. Contact Sponsored Program Services if you have additional questions.

 

National Endowment for the Humanities (NEH)

NEH is currently shut down. We expect that grant proposals may still be submitted via Grants.gov but per their website, NEH will not update information, process transactions or respond to inquiries until funding is resumed. We also do not expect NEH to issue awards during this period.

 

Department of Commerce

https://www.commerce.gov/news/blog/2018/12/shutdown-due-lapse-congressional-appropriations

The Department of Commerce includes the following bureaus which are all impacted by the partial shutdown (UConn Storrs and Regional Campuses has funding from agencies that are listed in bold):

Bureau of Economic Analysis (BEA)
Bureau of Industry and Security (BIS)
U.S. Census Bureau
Economic Development Administration (EDA)
Economics and Statistics Administration (ESA)
International Trade Administration (ITA)
Minority Business Development Agency (MBDA)
National Oceanic and Atmospheric Administration (NOAA)
National Telecommunications and Information Administration (NTIA)
National Institute of Standards and Technology (NIST)
U.S. Patent and Trademark Office (USPTO)

The following services and activities will not be available during a lapse except to the extent funded by other than current annual appropriations:

  • Most research activities at NIST and NOAA (excluding real-time regular models on research computers used for hurricane and FAA flight planning)
  • Assistance and support to recipients of grant funding
  • Technical oversight of non-mission essential contracts
  • Services and activities provided by:
    • Bureau of Economic Analysis (BEA)
    • Economic Development Administration (EDA)
    • Economics and Statistics Administration (ESA)
    • Minority Business Development Agency (MBDA)
    • U.S. Census Bureau with the exception of the support of the Decennial Census, which remains funded and activities funded by other agencies and non-Federal entities through reimbursable agreements.
  • Most services and activities provided by the International Trade Administration (ITA)

Additionally, electronic systems utilized by the Department of may not be functional (Grants Online which supports EDA and NOAA is not currently functioning).

 

National Endowment for the Arts (NEA)

NEA is currently shut down. We expect that grant proposals may still be submitted via Grants.gov but per their website, NEH will not post messages or respond. We also do not expect NEH to issue awards during this period.

 

Department of Transportation

No cooperative agreements, contracts, purchase orders, travel authorizations, or other documents obligating funds will be executed by the Federal Railroad Administration and Federal Transit Administration

 

USDA – NIFA

NIFA program activities will be suspended during a shutdown. The scope of the activities includes all NIFA extramural funding programs supporting research, education, extension or a combination of two or more of these functions. This includes agency activities associated with competitively awarded, noncompetitive Federal financial assistance payments, capacity and infrastructure, endowment, and all other NIFA grant programs.

 

Environmental Protection Agency (EPA)

As a general rule, recipients of funded grants and cooperative agreements can continue work on their projects during any EPA shutdown. Grant recipients currently approved to utilize the Automated Standard Application Payment (ASAP) system may make drawdowns of authorized obligated levels during a shutdown. With the exception of grant recipients using ASAP, in the case of government shutdown no payment processing will be available for cost reimbursable or recipients with special award terms and conditions requiring EPA approval prior to payment disbursement (either by paper check, drawdown, or by ACT payment outside to the ASAP system). EPA staff will not be available to make payments until the shutdown ends. Recipients must stop work if they reach a point at which they require EPA involvement or approval.