UPDATE March 7, 2023: NSF Requirement: Plan for Safe and Inclusive Working Environment for Off-Campus Research

It is National Science Foundation (“NSF”) policy to “foster safe and harassment-free environments wherever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. NSF’s new policy requirement states that there must be a plan for a safe and inclusive work environment created and on file at the proposal stage.  PIs are responsible for distributing the plan to each participant in advance of departure for an off-campus research activity. Off-campus or off-site research is defined by NSF for this requirement as “data/information/samples being collected off-campus or off-site, such as fieldwork or research activities on vessels and aircraft.”

Effective as of January 30, 2023, NSF grant applicants, including Syracuse University, are required to certify that we have a plan in place for a safe and inclusive work environment. The plan specifically addresses:

  1. Abuse of any person, including but not limited to harassment, stalking, bullying or hazing or any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and
  2. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly

The creation and distribution of the plan is the responsibility of the award PI. To ease the administrative burden, the Office of Sponsored Programs has created a Plan Template for your use.

  • Page 1. of the template plan provides instructions for the PI,
  • Page 2. of the plan outlines Syracuse University’s compliance with NSF’s requirement and provides links to all relevant University policies, and
  • Page 3. of the plan is the project specific information PIs will prepare and share with OSP prior to proposal submission.

PIs are responsible for distributing a copy of the plan to all required participants (See Participants definition in the FAQ) in advance of departure for an off-campus research activity, as well as maintaining documentation of who received the plan. Unless specifically requested, applicants should not submit the plan to NSF for review.

For additional information and examples of the applicability of the new NSF policy, please see the FAQ, or contact your OSP Research Administrator.

New NIH Data Management and Sharing Policy Effective Jan. 25, 2023

New NIH Data Management and Sharing Policy Effective Jan. 25, 2023
The NIH has released new policy for data management and sharing that applies to all research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data. The Syracuse University Libraries and Office of Research have developed Syracuse University guidance to aid researchers on adhering to the new policies. This guide will be updated over the next month with more resources.

NIH R15 Change in Eligibility Projected: Effective October 1, 2022

The Office of Sponsored Programs has analyzed the University’s eligibility for the National Institutes for Health (NIH) Research Enhancement Awards (R15) and based on the University’s recent success with receiving consistent NIH funding, we are projected to be ineligible to submit proposals for the NIH R15 program in the next federal fiscal year, starting October 1, 2022. 

The NIH R15 Program includes the Academic Research Enhancement Award (AREA) for Undergraduate-Focused Institutions, and the Research Enhancement Award Program (REAP) for Health Professional Schools and Graduate Schools.

This eligibility determination is contingent on receipt of at least $6 million in select NIH funding for October 1, 2021 to September 30, 2022. For the past two fiscal years, we have exceeded $9 million in such funding and thus fully expect to exceed $6 million in the current fiscal year. The analysis of our eligibility has been conducted using NIH public resources and confirmed by NIH program officers.

FAQs for R15 Eligibility, based on NIH provided clarifications:

  1. I’ve already submitted my R15 proposal. Will I be denied an award if it comes after October 1, 2022?
    • No, the eligibility is only for proposal submissions. Awards may come after this deadline.
  2. Will this prevent no-cost extension of current R15 awards?
    • No, current awards will remain in effect and extensions are allowable.
  3. Will this prevent renewals of current R15 awards?
    • Yes, the R15 eligibility will cover new and renewal applications. Renewals of current R15 awards will not be allowed.
  4. Can we apply in September 2022 for an October 2022 deadline? The submission will come while we are still eligible although the deadline will come after our eligibility expires.
    • To the best of our knowledge and interpretation of NIH guidance, our understanding is that Syracuse University remains eligible to apply in September 2022 for an October 2022 deadline. PIs should verify this information with a Program Officer from the Institute or Center to which they are applying.

If you have further questions, please direct questions to Stuart Taub, Director, Office of Sponsored programs at staub@syr.edu.

New Guidance: Other Support/Current & Pending Support

Federal agency guidance on current and pending (C&P) support is changing:

  • NSF – further updated their current and pending support requirements for proposals submitted on or due, and awards made, on or after October 4, 2021.
  • NIH – changes impact applications, Just-in-Time submissions, and Research Performance Progress Reports with due dates on or after January 25, 2022.
  • Other Federal Agencies – Specific requirements for other agencies may differ. Check the program solicitation for requirements.

Current and Pending Support, also known as Other Support, is a form typically used by federal sponsors to request information for the PI(s) and Key Personnel’s current and pending research projects. Most federal agencies require Current & Pending Support documents to be submitted:

    • with the proposal or
    • just before an award is issued, and
    • if awarded, they may require any changes to be disclosed in progress reports.

When required, please remember to include ALL support including grants, and contracts from all non-U.S. and domestic sources, including internal Syracuse University project support (e.g., CUSE Grants). The format of this requirement varies by sponsor. It is the responsibility of the Investigator/Key Personnel to make sure that all research projects and affiliations are fully disclosed and that the document is completed in its entirety.

Recently the Federal Government has been placing additional scrutiny on foreign influence and the impact to federal research.  Please see the Foreign Influence in University Research page on the Office of Research website for additional guidance applicable to Syracuse University researchers. These government concerns around foreign influence have resulted in some federal agencies providing additional guidance on what needs to be included in Current and Pending/Other Support documents.  Guidance for the specific agencies can be found on the Other Support/Current & Pending Support  page of the Office of Sponsored Programs website.  This information will be updated as we learn of new requirements from federal agencies. If you have any questions related to Current and Pending Support being reported at the proposal or just-in-time stage or to report changes to Current and Pending Support at the award stage, please contact your OSP Research Administrator.

NIH Policies on Other Support, Financial Conflicts of Interest and Foreign Components

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components:

The intent of this notice is to remind the extramural community about 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.

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html

Third Party Engagement on Sponsored Programs – New Form

A new Third Party Engagement on Sponsored Programs form has been posted in the forms section of the Sponsored Programs website.  The purpose of this form is two-fold.  The first to assist in identifying the collaborative relationship and the second to comply with procurement policies requiring full and open competition.

When working with third party (external) collaborators on a sponsored project, determining the proper method of engagement (subrecipient/consultant/contractor/vendor) is determined by evaluating the type of work to be performed and the characteristics of the collaborating entity.   It is recommended that this determination be made at the proposal stage so that budgets can be prepared accurately.  Page 1 of the form will assist in this determination.

When a sponsored project with third party collaborators is awarded, a process is initiated to formalize the collaboration.  The process differs based on the subrecipient / consultant / contractor determination that is made.  However, justification related to the selection process is required for most third party relationships.  Requirements for Subrecipients and Consultants are included in Page 2 of the Third Party Engagement on Sponsored Programs form while requirements for Contractor/Vendors are managed by Purchasing.

The Office of Sponsored Programs ensures that Subrecipient and Consultant engagements are properly established and executed.  Therefore, both pages of the new Third Party Engagement on Sponsored Programs form must be submitted when requesting subawards or execution of consulting agreements on your awards.

Contact the Purchasing department for direction regarding requirements for Contractor / Vendors / Purchased Services relationships.

Changes to the Subrecipient Monitoring Process

Effective July 1, 2019, the Office of Sponsored Programs (OSP) will no longer accept subrecipient invoices forwarded from parties other than the authorized financial representative of the subrecipient entity.  This change is being made to preserve an “arm’s length” relationship between Syracuse University and every subrecipient.  Moving in this direction will also increase efficiencies and transparency.

Invoices are to be submitted directly to the Subaward Administrator at subawardadmin@syr.edu.

Subrecipient invoices must:

  • Be generated by the subrecipient entity’s financial system of record;
  • Be formatted using the method consistent with the independent entity’s invoicing practices;
  • Reflect charges that are approved and allowable under the terms of the subaward agreement;
  • Itemize charges in a manner that is constant with the approved budget contained in the subaward agreement;
  • Include only expenditures that are supported by detailed backup (i.e. receipts, payroll…). This backup must be made available on request.

The Office of Sponsored Programs is responsible for managing contractual and financial aspects of all collaborations involving subrecipients.  In order to improve efficiencies and minimize confusion, OSP will work directly with the personnel from each entity to insure that the relationship is properly communicated from the beginning of the project period.

OSP understands that failure to adequately monitor the compliance of subrecipients could result in damage to Syracuse University’s reputation, and has the potential to jeopardize current and future funding.  It is the responsibility of The Office of Sponsored Programs on behalf of Syracuse University, as the pass-through entity, to ensure the good stewardship of sponsored funding.

Further information can be found at Working with Subrecipients

Important Changes to the NIH Academic Research Enhancement Award (AREA)/R15 Program

As announced in guide notice NOT-OD-19-015, the National Institutes of Health (NIH) has changed its approach to how it uses the R15 activity code.  The current AREA Parent Announcement, PA-18-504, expires after January 7, 2019.

Research enhancement opportunities will now be split between two distinct programs:

  1. Academic Research Enhancement Awards (AREA) will be reserved for grants to undergraduate-focused institutions that do not receive substantial funding from NIH; and
  2. Research Enhancement Award Program (REAP) that will support graduate schools of arts and sciences and health professional schools that grant baccalaureate or advanced degrees.

As background, the goals of the R15 program are to support meritorious research, expose students to research, and strengthen the research environment of an institution.

It is important to note that each funding opportunity announcement includes detailed program-specific eligibility information that supersedes any general information listed here.

Eligibility for the Academic Research Enhancement Award (AREA) program for undergraduate-focused institutions requires that:

  • The applicant institution must be an accredited public or non-profit private school that grants baccalaureate degrees in biomedical sciences.
  • At the time of application submission, all the non-health professional components of the institution together have not received support from the NIH totaling more than $6 million per year (in both direct and F&A/indirect costs) in 4 of the last 7 federal fiscal years.*
  • A signed letter is required from the Provost or similar official with institution-wide responsibility verifying the eligibility of the applicant institution at the time of application submission. The Office of Sponsored Programs (OSP) will coordinate with the Office of the Provost to obtain the signed letter.

Organization eligibility for the Research Enhancement Award Program (REAP) program for graduate schools and health professional schools require that:

  • The applicant organization must be an accredited public or non-profit private school that grants baccalaureate or advanced degrees in health professions or advanced degrees in biomedical and behavioral sciences.
  • At the time of application submission, the applicant institution (all components) may not have received support from the NIH totaling more than $6 million per year (in both direct and F&A/indirect costs) in 4 of the last 7 federal fiscal years.*
  • A signed letter is required from the Provost or similar official with institution-wide responsibility verifying the eligibility of the applicant institution at the time of application submission. The Office of Sponsored Programs (OSP) will coordinate with the Office of the Provost to obtain the signed letter.

*For both AREA and REAP program eligibility, please note that all activity codes are included in the eligibility calculations except the following: C06, S10, and all activity codes starting with a G.

Syracuse University currently meets the eligibility requirements for both the AREA and REAP programs, however specific program announcements/solicitations from NIH institutes/centers may have additional requirements/limitations so it is important to ensure that you read these documents carefully. Questions regarding eligibility may also be directed to the Office of Sponsored Programs.