Managing Your Award – Non-Financial

No-Cost Extensions

If project work is on-going and funds remain available to cover project expenses, it may be appropriate to request an extension of the project period. Considerations include award terms, funding for committed effort on the project, timing, and approvals required.

Under the Federal Demonstration Partnership (FDP), UAF is authorized to approve a single no-cost extension (NCE) of up to 12 months on eligible federal grants, provided it notifies the sponsor that it has elected to take such an extension, explains why the extension is needed, and provides the notification at least 10 days before the expiration date specified in the award.

A formal request to the sponsor may be required if the sponsor is not a member of the FDP, is a non-federal sponsor, or if this is not the first NCE requested for an award. The award's terms and conditions apply.

If an NCE is needed, an AwaRE form will need to be submitted with the following award and extension justification information:

Award Information

  • Project Number
  • Award Number
  • Current Period of Performance
  • Requested Extension End Date

Justification for Extension

  • Brief reason for the extension, including the reason(s) the project was not completed within the original period of performance.
  • Brief summary of work to be accomplished during the extension period.
  • Amount of funds expected to be available on the current end date and the intended use during the extension period.
  • If applicable, any updated compliance documents (IRB/IACUC/IBC data).
  • The request will be submitted according to the procedures of the sponsoring agency. With some sponsors the request will be submitted through an online system, such as FastLane, NSSC, or eRA Commons. In other situations a request will be submitted via e-mail to the grants official. Please note that there are deadlines for submitting these requests, which will vary according to sponsor requirements.

If additional funding is required, this will still be prepared as an extension (i.e., a modification), but will not be no cost and will require an OGCA analyst to review your budget.

Personnel Changes

Since the approval of the project has been, to some degree, based on the participation or qualifications of the PI and other key personnel, the sponsor requires notification whenever there is to be a significant change in the level of participation in the awarded project by the Principal Investigator (PI). The sponsor has the option to either approve or disapprove of any proposed alternate plans related to the research.

A significant change in the level of participation may be defined as:

  • The PI not giving active direction of the project for a continuous period of time greater than three months, (e.g., on sabbatical leave), or
  • A change of 25% or greater in the level of committed effort, or
  • A withdrawal from the project.

For non-federal sponsors, review the specific award’s terms and conditions.

The request should be initiated on the AwaRe form. The program officer at the awarding agency must be notified in a letter signed by the PI and a UAF Authorized Organizational Representative (AOR). The letter should detail the reason for the change in key personnel and provide the replacement PI's curriculum vitae. These requests must be made prior to implementing any changes. UAF will make the appropriate changes to award files and financial records once written approval has been received from the sponsor.

Specific Federal Agency Information For Significant Changes of Personnel or PI

Changes in Scope of Work

The Principal Investigator and the sponsor should discuss the need for any changes in the scope of work (SOW) before contacting OGCA. Common types of scope changes are changes in process, research direction, resources, and scheduling. A formal modification or amendment to the agreement may be required. The award's terms and conditions apply.

 

Harassment and Discriminations Protections

 

The University of Alaska Fairbanks (UAF) has empowered the Department of Equity and Compliance (DEC) to investigate and resolve complaints of employment discrimination, harassment, or retaliation prohibited by law or University policy. DEC works with the University community to implement and uphold policies and practices that are consistent with these federal and state mandates, as well as the existing University policies regarding equal access, equal employment, and educational opportunity for all persons. https://www.uaf.edu/equity/

The UAF is committed to creating and maintaining an educational, research, working, and living environment free from all forms of unlawful harassment and sexual misconduct.  The University has created policies and procedures that describe the community standards of conduct as well as the procedures for grievances and complaints alleging violations of its discrimination and harassment policies.

In addition to University policy, Federal and State sponsors of UAF’s research have notification and reporting requirements related to sexual harassment, harassment, sexual assault, and discrimination.  Many of these sponsors have recently issued rules and guidance regarding these requirements and the importance of adhering to them. 

Federal Agency Specific Guidance:

 
National Science Foundation (NSF)

 

NSF Requirements

On September 21, 2018, NSF published in the Federal Register a Final Notice of a new award “term and condition regarding sexual harassment, other forms of harassment, and sexual assault.”   That term and condition requires the University to notify NSF promptly of findings or determinations of “sexual harassment, other forms of harassment, or sexual assault” concerning an NSF-funded principal investigator (PI) or Co-PI, as well as of any interim administrative actions imposed by the University (e.g., administrative leave or curtailment of certain University duties) relating to any finding, determination, or investigation of an alleged violation by a PI or Co-PI of the University’s policies relating to harassment and assault.  

The term and condition is effective for NSF awards and amendments made on or after October 22, 2018. 

UAF has established procedures that comply with these requirements.  Please contact OGCA with questions or for more information.

NSF-Sponsored Conferences

NSF’s Proposal and Award Policies and Procedures Guide (PAPPG) (effective February 25, 2019) sets forth a requirement that conference proposers have “a policy or code-of-conduct that addresses sexual harassment, other forms of harassment, and sexual assault, and that includes clear and accessible means of reporting violations of the policy or code-of-conduct.”  Notably, “[t]his policy or code-of-conduct must be disseminated to conference participants prior to attendance at the conference and made available at the conference itself.” 

For more information on applicable UAF policies and how UAF can assist researchers with complying with NSF conference requirements, please contact OGCA.

NSF Agency Information

NSF Notification Requirements Regarding Findings of Sexual Harassment, Other Forms of Harassment or Sexual Assault - Final Notice (Sept. 21, 2018)

Important Notice No. 144: Harassment (Feb. 8, 2018)

NSF, Office of the Director, Sexual Harassment

NSF Term and Condition: Sexual Harassment, Other Forms of Harassment, or Sexual Assault

 
National Institutes of Health (NIH)

 

NIH Requirements

NIH requires that grantees have “policies and practices in place that foster a harassment-free environment.”  With respect to this rule, NIH has stated the following:

NIH expects that grantee institutions:

  • develop and implement policies and practices that foster a harassment-free environment;
  • maintain clear, unambiguous professional codes of conduct;
  • ensure employees are fully aware and regularly reminded of applicable laws, regulations, policies, and codes of conduct;
  • provide an accessible, effective, and easy process to report sexual harassment, and provide protection from retaliation;
  • respond promptly to allegations to ensure the immediate safety for all involved, investigate the allegations, and take appropriate sanctions; and
  • inform NIH of administrative actions that removes senior/key personnel on an NIH award.”

UAF has established policies and procedures that meet and provide mechanisms for researchers to comply with these expectations.  Please contact OGCA for more information.

NIH Training Grant Applications

In addition to these expectations, NIH has established parameters relating to harassment that are specific to certain types of grants.  For Institutional Training (T) Applications (T15, T32, T34, T35, T36, T37, T90/R90, TL1, TL4), NIH requires as follows:

“As part of the Letters of Support on the PHS 398 Research Training Program Plan form, applications currently include a description of the applicant institution’s commitment to the planned program in order to ensure its success . . .   In the same letter, applicants should include a description of the institutional commitment to the following areas: 

(i) ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices; 

(ii) responding appropriately to allegations of discriminatory practices, including any required notifications to OCR . . .; and

(iii) adopting and following institutional procedure for requesting NIH prior approval of a change in the status of the Program Director/Principal Investigator (PD/PI) or other senior/key personnel if administrative or disciplinary action is taken that impacts the ability of the PD/PI or other key personnel to continue his/her role on the NIH award described in the training grant application . . .

The signed letter should be on institutional letterhead from an Authorized Organizational Representative (AOR), or other key institutional leader with institution-wide responsibilities.

UAF has made the required institutional commitments.  Please contact OGCA for more information or for assistance with or questions regarding Letters of Support.

NIH Conference Grants (R13)

NIH requires that “NIH recipients of conference grant (‘R13’) funding must take steps to maintain a safe and respectful environment for all attendees by demonstrating an institutional commitment to ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices.”

UAF has made the required institutional commitments.  Please contact OGCA with questions about this requirement or assistance with conference grants.

NIH Agency Information 

NIH Process for Handling Allegations of Sexual Harassment on an NIH-Funded Project at a Recipient Institution(June 2020)

All About Grants Podcast on NIH Anti Sexual Harassment Policies Dr. Jodi Black (August 8, 2019)

How to Notify NIH about a Concern that Sexual Harassment is Affecting an NIH-Funded Activity at a Grantee Institution (June 14, 2019)

Update on NIH’s efforts to address sexual harassment in science (Feb. 28, 2019)

NIH Director's statement on changing the culture of science to end sexual harassment (Sept. 17, 2018)

NIH Anti-Sexual Harassment Statement, including links to regulations, policy, and FAQs

Anti-Sexual Harassment: for NIH Awardee Organizations and Those Who Work There

 

National Aeronautics and Space Administration (NASA)

 

In January 2016, NASA Administrator Charles Bolden published a letter to grantee institutions running NASA-funded programs regarding harassment policies, which stated as follows:

As a leader in the fields of science, technology, engineering and mathematics (STEM), NASA endeavors to make our collaborations with our grant recipient institutions as productive and successful as possible in all facets of our shared objectives. This means that we seek not only the most innovative and cutting-edge scientific and technological research from our grant recipients, we also expect strong efforts to create and sustain welcoming and inclusive educational environments. We view such efforts not as “something nice to do” if the time can be spared, or something that human resources or the diversity and equity offices are responsible for, but rather as an integral and indeed necessary aspect of all educational program environments. 

Let me be perfectly clear: NASA does not tolerate sexual harassment, and nor should any organization seriously committed to workplace equality, diversity and inclusion. Science is for everyone and any behavior that demeans or discourages people from fully participating is unacceptable.”

NASA Proposed Requirements

Following on this commitment, NASA published a notice in the July 10, 2019 Federal Register entitled “Reporting Requirements Regarding Findings of Harassment, Sexual Harassment, Other Forms of Harassment, or Sexual Assault,” seeking public comment on a proposed rule that would institute a new term and condition in NASA awards requiring reporting of sexual harassment, other forms of harassment, and sexual assault.   

The Notice explained NASA’s policy objective as follows: “The implementation of new reporting requirements is necessary as NASA seeks to help ensure research environments to which the Agency provides funding are free from sexual harassment, other forms of harassment, and sexual assault.”

Similar to NSF, the new term and condition would require NASA-funding recipients to report (1) findings and determinations regarding the PI or Co-PI that demonstrate a violation of the recipient’s policies or codes relating to harassment and assault and/or (2) administrative action relating to any finding, determination, or investigation of an alleged violation by a PI or Co-PI of the recipient’s policies relating to harassment and assault.

Comments in response to the Notice were due no later than August 16, 2019, and the new requirements will likely become effective in the fall of 2019.  OGCA will provide updates as they become available.

NASA Agency Information

NASA Administrator communicates harassment policies to grantees (Jan 15, 2016)

Compliance Requirements for NASA Grantees

NASA Office of Diversity and Equal Opportunity_ Mission STEM

Harassment and Discrimination Reporting for NASA Employees, Contractors and Grantee Beneficiaries

 

 

 

International Relationships / Foreign Influence and Activities

 

Introduction

Congress and the US federal agencies have been increasingly concerned that foreign entities may seek to unduly influence U.S. research. The NIH has specifically identified three main areas of concern (Collins letter to NIH awardee institutions, August 20, 2018):

  1. Diversion of intellectual property to other entities, including other countries;
  2. Sharing of confidential information on grant applications by NIH peer reviewers; and
  3. Failure by some researchers to disclose substantial resources from other organizations.

Several other federal agencies have expressed similar concerns and have issued statements outlined below:

Updated Developments

  1. The National Institutes of Health (NIH) issued a July 10, 2019 notice reminding recipient institutions and investigators of “the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.”
    1. Prior to issuing this notice, as of July 2019, the NIH contacted more than 60 institutions regarding scientists the NIH believes failed to disclose financial ties to foreign agencies or have failed to uphold the confidentiality of the peer review process. As a result of investigations conducted collaboratively between the NIH and the institutions, some dismissals have occurred, and grant funds have been returned.
  2. The Department of Defense (DoD) on March 20, 2019 issued a memo  outlining disclosure requirements for all key personnel listed on research and research-related educational activities supported by DoD grants and contracts.
  3. The National Science Foundation (NSF) on July 11, 2019 issued a letter addressing research protections that included:
    1. A reminder about disclosure requirements for all senior project personnel and noted that draft clarifications for reporting requirements have been published for public comment.  These clarifications indicate a requirement to disclose all current and pending support through the proposing organization or directly to the individual including 1) non-profit organizations and consulting agreements and 2) all projects requiring a time commitment.
    2. New policy prohibiting NSF personnel from participation in foreign government talent programs.
  4. The Department of Energy (DOE) issued a directive on June 7, 2019 mandating that “federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government-supported talent programs” on new DOE contracts and subcontracts.
  5. Long-standing restrictions prohibiting cooperation between NASA and China were upheld in March of 2018 in an omnibus spending bill, which stipulates that “None of the funds made available by this Act may be used…to develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese owned company…”
  6. Office of Science and Technology Policy Letter Over the last two years, there has been an increasing concern at the federal level regarding foreign influence in scientific research. Recently, a Dear Colleague letter to all U.S. researchers was released by Kevin Droegemeier, director of the Office of Science and Technology Policy. It establishes four areas of effort:

    • Coordinating outreach and engagement
    • Establishing and coordinating disclosure requirements
    • Developing best practices for academic research institutions
    • Developing methods for identification, assessment, and management of risk

 

Federal Agency Responses

While Federal agencies are responding to these concerns and have implemented some changes to begin to address them, it is not yet clear what the final outcome will be. Some federal agencies have sent "Dear Colleague" letters outlining their initial efforts to address these concerns.

Disclosure Requirements

As much of the attention focuses on appropriately disclosing foreign relationships and support, it is important to be aware of internal and external disclosure requirements.

Disclosures of “Other Support” and Foreign Components to Federal Funding Sources

Sponsors typically have specific guidelines of what to disclose as “Other Support.” The table below provides a summary of requirements. Ultimately, it is the investigator’s responsibility to ensure that disclosures are made in concurrence with sponsor policies. Disclosures must be made at the time of proposal and as situations change via update and reporting processes.

 
National Institutes of Health (NIH)

 

Agency Requirement:
Other Support:

For ALL Senior / Key Personnel who contribute to scientific development or execution of a project in substantive, measurable way regardless of whether salary or compensation is requested for each individual:

  1. All positions & scientific appointments (domestic & foreign)
    1. Includes compensated & uncompensated appointments
    2. Includes affiliations with foreign entities or governments
  2. All resources and other support for ongoing projects
    1. Include all irrespective of whether support is provided through the applicant institution (UAF), through another domestic or foreign organization, or is provided directly to an individual
    2. Include all even if in-kind support
    3. All research resources must be reported:
      • Foreign financial support
      • Research or laboratory personnel, lab space, scientific materials
      • Selection to foreign “talents” program
      • Other foreign or domestic support
    4. Total award amount for the entire award period covered & number of person-months per year to be devoted to each ongoing project by senior/key personnel
Foreign Component:

Foreign Components are “the existence of any significant scientific element or segment of a project outside of the United States.” Foreign components must be disclosed.

  1. Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
  2. 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.
 
National Science Foundation (NSF) 

 

Agency Requirement:
Other Support:

All individuals designated as senior personnel on NSF proposals must disclose:

  1. All current and pending support, including for the proposed project, for ongoing projects, and for any proposals currently under consideration by any source.
    1. Report all regardless of whether funds provided through the proposing organization (UAF) or directly to the individual [e.g., Federal, State, local, foreign, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects]
    2. Include the proposed activity and all other projects and activities, current and proposed, that require a time commitment, even if the support is only in-kind or no salary support is being provided
    3. Provide the total award amount for the entire award period covered (including indirect costs)
    4. Provide the number of person-months (or partial months) per year to be devoted to the project for each senior personnel
    5. If the project being proposed has been previously funded by NSF or otherwise, provide required information for the last period of funding
Foreign Component:

International Activities:

  • Identify all international activities - “defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies.”
  • List applicable countries

Foreign Organizations via subaward or consulting arrangement:

  • Explain in the proposal why local support is not feasible and why the foreign organization can carry out the proposed activity more effectively. The proposal must demonstrate that the foreign organization:
    • Contributes a unique organization, geographic location, and/or access to unique data resources not generally available to US investigators, or other resources that are essential to the success of the proposed project; or
    • Offers significant science and engineering education, training or research opportunities to the US
 
Other Agencies (general guidelines)

 

Other Support:

Proposers must submit the following for all key personnel, whether or not the individuals’ efforts under the project are to be funded through the award:

  • Previous (award period of performance ending within the past 5 years), current, and pending research support including:
    • Title
    • Time commitments
    • Supporting agency
    • Name and address of funding agency’s procuring contracts/grants officer
    • Performance period
    • Level of funding
    • Brief description of project goals
    • Specific aims
    • Identify any overlap with other existing and pending research projects or state there is no overlap
Foreign Component:

Identify any partner organizations and their contribution(s), including location/country of the partner.

Disclosures to the Public

 

Disclose all financial relationships related to your research in all public sharing of your research results, such as in presentations, publications or otherwise. It is important to note that journal disclosure requirements are often broader than UAF requirements, which may require additional disclosures.

Where to Get Assistance

 

Disclosure Type

Contact

Grant Proposal, Other Support & Foreign Components

Office of Grants and Contracts Administration (OGCA)

UAF Financial Interest Disclosures

Office of Research Integrity

UA Outside Activities Disclosures

University of Alaska Statewide
https://www.alaska.edu/hr/forms/hr_ethicsforms/
uaf-ori@alaska.edu


https://www.uaf.edu/ori/


And your Unit/Department Dean/Director

Foreign Travel

Office of Research Integrity (ORI)

uaf-ori@alaska.edu
https://www.uaf.edu/ori/

Export Control

Office of Research Integrity (ORI)

uaf-ori@alaska.edu
https://www.uaf.edu/ori/

                                                                                              

 

Freedom of Information Act (FOIA)

 

The Freedom of Information Act (FOIA) of 1967, 5 U.S.C. 552, requires federal funding agencies to release certain grant documents and records requested by members of the public, regardless of the intended use of the information. These policies and regulations apply to information in the possession of the federal agency and do not require grantees or contractors under grants to permit public access to their records. The regulations also indicate types of information that are generally exempt from release.

The Freedom of Information Act (FOIA) provides the public the right to request access to records from any Federal agency. It is often described as the law that keeps citizens in the know about their government. Federal agencies are required to disclose any information requested under the FOIA unless it falls under one of nine exemptions which protect interests such as personal privacy, national security, and law enforcement.

The following types of information/materials will generally be released in response to an FOIA request, whether the materials are maintained in paper or electronic format:

  • Funded applications;
  • Pending and funded non-competing continuations;
  • Grant progress reports; and
  • Final reports of any audit, survey, review, or evaluation of grantee performance that have been transmitted to the grantee.

The following types of information/records will generally be withheld in response to an FOIA request:

  • Pending competing grant applications;
  • Unfunded new and competing continuations and competing supplemental applications;
  • Financial information regarding a person, such as salary information pertaining to project personnel;
  • Information pertaining to an individual, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;
  • Pre-decisional opinions expressed by Government officers, employees, or consultants in inter- or intra-agency memoranda or letters;
  • Evaluative portions of site visit reports and peer review summary statements, including priority scores;
  • Trade secrets and commercial, financial, and otherwise intrinsically valuable items of information that are obtained from a person or organization and are privileged or confidential;
  • Information that, if released, would adversely affect the competitive position of the individual or organization; and
  • Patent or other valuable commercial rights of the individual or organization

If the federal funding agency receives an FOIA request and has substantial reason to believe that information in its records could reasonably be considered exempt, the appropriate agency FOIA Officer will notify the grantee before the information is released, allowing the grantee an opportunity to identify potentially patentable or commercially valuable information that should not be disclosed.

After agency consideration of the grantee's response, if any, the grantee will be informed of the agency's decision as to what documents will be released and to whom. If a document contains both disclosable and non-disclosable information, the non-disclosable information will be deleted by a designated agency FOIA Officer, and the balance of the document disclosed.

Federal agencies are required to respond to a FOIA request within 20 business days, excluding Saturdays, Sundays, and legal holidays. For the Privacy Act, the time limit is 10 business days. This period does not begin until the request is actually received by the FOIA office of the Federal agency.

In addition, a Federal agency may receive a request (not identified as FOIA) for a copy of a grant application (proposal). The awardee institution will be contacted by the Federal agency regarding this request, informing that the proposal will be released with certain person and salary data redacted from the proposal application. These requests are not required to follow the 20-day limitation response time as set forth in the FOIA Act.

All FOIA requests are coordinated with General Counsel and OGCA.

Advocacy and Outreach for Researchers

 

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