Most likely, consultants will not be considered investigators and will therefore not be affected. If consultants, who are not UW employees, are investigators on a UW project, they will likely be contracted through their academic institution, rather than personally. The subawardee, whether through purchasing or a subcontract, will be required to have a compliant policy in order to get federal funding. To meet the mandatory training requirement, an investigator who is not UW personnel could take our training, via a sponsored UW NetID.