Tag Archives: Compliance


When OSP creates a child Funding Action (FA) for an awarded eGC1, the system will automatically create compliance holds, if appropriate.

The system applies automatic holds to the FA based on the conditions in the following chart.

Compliance Hold Due to
Administrative Support Budget & Fiscal Compliance page question F2 = Yes
F&A Budget & Fiscal Compliance page question F1 = Yes
IRB Approval Compliance Q&E page question HS-1 = Yes
Cost Share Budget & Fiscal Compliance page question F3 = Yes
Fed Flow-Through Details page has an Originating Sponsor listed with a Sponsor Type of Federal Government
SFI/FCOI One or more investigators on the PI, Personnel, & Organizations page has an SFI value of Yes or Unknown
Export Control Compliance Q&E page question SEC-1 and/or SEC-2 = Yes
IACUC Compliance Q&E page question AC-1 = Yes
PHS Training One or more investigators on the PI, Personnel, & Organizations of a PHS-sponsored eGC1 has either not done the FCOI training or the training has expired.




You must answer each of the three fiscal compliance questions in this section of the eGC1 Budget & Fiscal Compliance page.

Question F1: Will F&A costs be reimbursed at less than a federally negotiated rate for the UW?

The F&A Cost Rate is determined by the location(s) where the research is performed and is charged as a percentage of total Direct Costs. Rates can be found in GIM 13 Supplement: Table of F&A Rates and Base Types. A Primer on F&A Costs, GIM 13 Facilities and Administrative (F&A) Rates, can provide further detail. Guidelines for determining split rates when projects are conducted at two or more locations are found in GIM 13 Supplement: Activity at Two or More Locations.

See also GCA’s page on Facilities & Administrative Costs.

If you answer Yes:

  • Item F1a will display: Attach GIM 13 waiver in attachments section, or provide documentation of sponsor F&A policy (e.g. RFP, application documents, or website URL)
  • Use the text box to enter your documentation, or upload an attachment on the Attached Documents page.

Note: for RRF applications, the answer to this question must be No.

Question F2: Will administrative or clerical support be included in the budget as direct costs? (see GIM 23)

NIH grants do not allow administrative or clerical personnel costs unless they meet the criteria in GIM 23.

If you answer Yes:

  • Explain how administrative or clerical personnel will be used in the proposed project, following the criteria in GIM 23 Appendix A (Examples of Direct Costs).  This must be appropriately justified in the sponsor application, following sponsor guidelines.

Question F3: Does this application commit funds for cost sharing or matching?

Cost Sharing, Matching or Continuation occurs when an application promises to deliver a support or service for which the research grant does not pay.

  • Cost Sharing may be mandatory (required by sponsor) or committed (a contribution of effort or other costs offered by the Principal Investigator which the sponsor does not require as condition of the award).  Cost sharing occurs when an application commits allowable expenses (i.e., personnel, tuition, equipment or services) for which the research grant will not pay. You must charge these costs to an alternate source (UW or third party). You need to identify all sources and they must agree (via the eGC1 approval process) to commit the necessary funds. For more information, see the GCA Cost Sharing Overview page or GIM 21: Cost Share on Sponsored Programs.
  • Matching funds occur when proposal funding is contingent on a unit’s agreement to commit a matching amount of funding ($) to a project. Matching funds may come in the form of a gift or a grant.
  • Continuation funding takes three forms:
    • (a) it provides funding from a secondary source for ongoing support of a project after the original funding is depleted
    • (b) continuation funds may also be granted if the project is unable to be completed by the original time line and the sponsor has agreed to provide supplemental funding to see the project through to completion
    • (c) continuation funding also occurs when a portion of the original funding commitment is continued and the remaining budget must be found in grant money.

If you answer Yes:

  • Identify whether you are including cost sharing, matching or program continuation.
  • Provide a brief explanation in the text box and attach the completed Addendum form on the Attached Documents page. (On the Addendum, complete all fields including faculty effort, budget number and third party contribution.)
  • Indicate the cost sharing amounts and sources in the Personnel section of the eGC1’s Cost Sharing page.

October 2017 SAGE Compliance Release 1

As part of a larger effort to improve usability and content of the eGC1 Compliance page, this release makes a number of alterations to better focus the Compliance page on non-fiscal compliance questions. This was accomplished by either removing questions or relocating them to more intuitive sections of the eGC1.

There are more changes coming to the Compliance page in a later release that will build upon these enhancements.

Compliance Page Changes

Question Change
FG-1 Cost Share Relocated to Budget & Fiscal Compliance page
FG-2 Conducted off campus Replaced by Activity Locations section
FG-3 F&A at less than federally negotiated rate Relocated to Budget & Fiscal Compliance page
FG-4 New, rental or renovation Relocated to Activity Locations page
FG-5 Compensation for overtime Removed
FG-6 Deliverables Removed
FG-7 Administrative support Relocated to Budget and Fiscal Compliance page
FG-8 Interdisciplinary facilities Relocated to the PI, Personnel & Organizations page
FG-9 Review by other organization Relocated to the PI, Personnel & Organizations page
NG-1 Advancement assistance Removed
NG-3 Originating sponsor Relocated to the Details page with other sponsor information

New Activity Locations Page

A new page has been added to the eGC1 that centralizes details related to the location of research activities in a proposal.

This page includes relocated questions, as well as more detailed tracking on each location where UW work will take place. The sections on this page are:

Activity Locations

  • Includes identification of each location where UW research activities are taking place along with details helpful for budgeting and F&A rate determination.
  • The Location Search integrates with the UW’s space tracking system GeoSIMS, allowing you to partially enter a facility name, address or facility code and populate the eGC1 with the data for that location.
  • You can also manually enter locations not found in GeoSIMS.

Space Planning

  • Includes the “construction or renovation” question formerly on the Compliance page, along with approval details when answered ‘Yes’.

International Involvement

  • Includes the international involvement question and country identification formerly on the Details page. Country is now sourced from the more comprehensive international standard ISO 3166.

This new page introduces an updated, intuitive and more modern experience for SAGE. Based on feedback from users, we will be incrementally updating SAGE to new design standards with each new release.

Fiscal Compliance Combined with Budget

The existing FG-1, FG-3, and FG-7 compliance questions related to fiscal compliance have been relocated to the top of the Budget page (now rebranded “Budget & Fiscal Compliance”), along with the useful explanations when ‘Yes’ is selected.

Details Page Updates

The existing NG-3 “originating sponsor” compliance question has been relocated to the Details page directly below the Sponsor selection.

The international involvement question has been relocated to the Activity Locations page.

PI, Personnel, & Organizations Page Updates

The existing FG-8 Compliance question on interdisciplinary facilities, service centers, etc. has been relocated to the PI, Personnel, & Organizations page. In a previous release, the FG-9 “other organizational reviewers” question was relocated to this page as well. With these two changes, you can now better manage your eGC1 approvals in one location.

SAGE Toolbar Update

The “reset form” icon on the upper SAGE toolbar has been removed. Removal of this rarely used feature will allow the application design to progress to more modern standards.

SPAERC: Intellectual Property Questions Added to FA/PAC/NAA

A new question has been added to the FAs, PACs, and NAAs in SPAERC for OSP post-award administrators to indicate when an agreement includes an upfront exclusive commercial license or ownership over the project’s intellectual property. CoMotion will receive notification when these are marked YES in order to get a jump start on IP negotiation.

SPAERC: BUG FIX – Internal OSP Notes no longer display in SAGE Subawards “Latest Update”

An issue that was causing internal OSP notes for subawards to display in SAGE under “Latest Update” for requests in process has been resolved. The “Latest Update” will now only display the most recent status update and any accompanying comments to/from campus and OSP.

March 2016 SAGE Maintenance Release

General Updates

A New OAW Compliance Question for Significant Protocol Changes

A new compliance question, AC-1-D, has been added to identify grants that will require a Significant Change at the time of submission. An answer is required if the Animal Use question AC-1 is answered “Yes”.

A few textual enhancements (for existing compliance questions) were made to allow OAW to process the grants more efficiently, and they include:

  1. Removing the facility name and location of the work to be done on the AC-1-A for UW work
  2. Requesting the 3-year approval date range
  3. Updating electronic document submission contact info.

Sub-Object Codes 05-47 and 05-48 Added to Sage Budget for Grandfathered Awards

Effective July 1, 2016, UW’s equipment capitalization threshold will increase from $2,000 to $5,000. This change applies to all competing proposals submitted to sponsors on or after May 1, 2016. The following changes were made in Sage Budget to accommodate this threshold change:

  1. Two new object codes will be added to (05) Supplies and Materials to allow grandfathered awards to continue to use the old threshold for non-capitalized equipment:
    • 05-47 Non-Capitalized Equipment ($2,000-$4,999) – Grandfathered Awards
    • 05-48 Non-Capitalized Equipment – M&E Tax Exempt ($2,000-$4,999) – Grandfathered Awards
  2. These two new object codes will be excluded from F&A calculation when using the following cost bases for budgets associated with grandfathered awards:
    • Exclude 05-47 and 05-48 form Total Direct Costs less Equipment & Tuition (TDC less E&T)
    • Exclude 05-47 and 05-48 from Modified Total Direct Costs (MTDC)
  3. The following object code descriptions will be updated as listed below to reflect the new threshold of $5,000:
    • 05-40 Non-Capitalized Equipment (less than $5,000)
    • 05-41 Non Capitalized Equipment –M&E Tax Exempt ($200 – $4,999)
  4. The following object code descriptions will be updated as listed below to reflect their INACTIVE status upon 4/1/2016:
    • 06-10 Inactive – Computing Equipment ($2,000-$4,999)
    • 06-12 Inactive – Computing Equipment – M&E Tax Exempt ($2,000-$4,999)
    • 06-90 Inactive – Other Equipment (Non-computing) ($2,000-$4,999)
    • 06-92 Inactive – Other Equipment (Non-computing) – M&E Tax Exempt ($2,000-$4,999)

Personnel with an Invalid NetID will not be selectable

With this change, all active staff in the Person Web Service will continue to show in the results on staff search, but those without NETIDs will not be selectable, and users will see a note indicating that the NETID must be established before the person can be selected.  Allowing personnel without NETIDs to be selected as personnel caused errors on the personnel list afterward.

Grant Runner Forms-D Implementation

Grants.Gov will be updating its systems to FORMS-D, for all applications submitted for due dates on or after May 25, 2016. The Grant Runner forms that will be updated to comply with FORMS-D requirements are identified below. There may be some application packages which include both a FORMS-C and a FORMS-D as options, and in this case users will be prompted in SAGE to select the appropriate one based on the due date. Per NIH, FORMS-C application packages will be set to expire after the May 7, 2016 AIDS due date.

Update of PHS 398 Cover Page Supplement to Forms-D

For Grants.Gov FORMS-D, users will notice the following changes applied to the Grant Runner Coverage Page Supplement form:

  • A new “Vertebrate Animals” section, which includes questions on euthanization and use of AVMA guidelines.
  • Removal of the PD/PI section
  • Removal of the Disclosure Permission section
  • The ability to add Program Income information for 10 budget periods (previously 5)
  • Re-ordering of fields to accommodate the new additions and removals

Update of PHS 398 Research Plan to Forms-D

For Grants.Gov FORMS-D, users will notice the following changes applied to the Grant Runner PHS 398 Research Plan form:

  • New “Data Safety Monitoring Plan” attachment
  • New “Authentication of Key Biological and/or Chemical Resources” attachment

Creation of a New PHS Inclusion Enrollment Form for Forms-D

For Grants.Gov FORMS-D, users will notice a new form called “PHS Inclusion Enrollment Report” in Grant Runner. This single form will replace the 2 separate forms in FORMS-C applications (Cumulative Inclusion and Planned Enrollment Report). With the Forms D changes, users will notice some additional fields to identify the type of reporting being done (“Delayed Onset Study?”, “Enrollment Type?”, “Existing Data Set or Resources?”) When “Delayed Onset Study” is marked YES, the remainder of the form will be disabled, per form rules.

Store activity type code for Grant Runner Applications

In order to aid in the analytics of Grant Runner usage, the SAGE system will begin to retrieve and store the Activity Type code from Grants.Gov, as we are retrieving submission status information.


Error when Inactivating Advances

An issue that was causing users to receive an error when trying to discard advances has been fixed.

September 2015 SAGE Maintenance Release

EHS-2 Compliance Question Update

The EHS-2 question on the Compliance Questions and Explanations pages of the eGC1 has been updated on all new eGC1s created after the September 2015 release.

Updated logic for the display of the HS-1-B Compliance Question Explanation

The HS-1-B question on the Compliance Explanations page of the eGC1 will now display under the additional condition of a Contract that is utilizing Just-In-Time human subjects approval.

Compliance question HS-1-B was not displaying/hiding in real time, when Project Type = Contract

Conditional questions and instructional text in the Human Subjects section of the Compliance Explanations page of the eGC1 now update in real-time when the eGC1 is for a Contract.

 Prevent multiple RegIDs for the same person from being entered into SAGE

When a user is erroneously assigned multiple RegIDs at the University, it has caused problems with accessing their FIDS information. A change has been made to disallow multiple RegIDs for the same person in the SAGE database.  Upon logging into SAGE, the user will receive an error that is also recorded in the SAGE Suite error log. This error will alert the SAGE team to take the necessary action to resolve the issue with UW IT.

Grant Runner Validation Update on Detailed Budget

A validation was added to the Grant Runner detailed budget form to disallow zero entries in the “other” cost field. This will help mitigate submission errors.


Older FAs in SERA have problems opening

An issue that had prevented Funding Actions that predated the creation of the Authorized Action field from being opened in SERA has been fixed.

SEC-1. Will any export-controlled items be transported outside the United States in connection with this project?
If any part of the project and/or collaboration takes place outside of the U.S., you will need to determine if your items would be considered export-controlled by U.S. laws and regulations: Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

SEC-2. Will any export-controlled technology be shared with or transferred to foreign persons (including UW employees and students), on or off campus?
If the project or collaboration involves an export-controlled technology AND a foreign person, a Technology Control Plan may be required. Location is not relevant; the transfer of export-controlled technology to a foreign person in the U.S. or in a foreign location is an export.

  • If you answer Yes, please provide a short explanation of what will be shared or transferred.
  • For assistance determining whether your items would be considered export-controlled, use the Catalyst WebQ tool.
  • For additional help and examples, see OSP’s Export Compliance – SEC-2.
SEC-3. Will this project potentially involve restrictions on participation, restrictions on access to research facilities, or restrictions on publication?
Restrictions can be imposed by various means including, but not limited to:

  • Export Controls
  • Security Classification
  • Proprietary Rights

Accepting such restrictions may require a review of the proposed grant or contract by the Faculty Council on Research (FCR) to ensure that the academic benefits to the University, and the communities it serves, will justify the exception. More information is available in UW Executive Order 8.

SEC-4. Will this project potentially involve access to classified national security information?
These projects can take place at the UW or another facility and involve access to classified information or sensitive government facilities, and thus require U.S. persons with a “need-to-know” status to receive appropriate personnel security clearance to perform on such tasks and orders. For more information, see UW’s Industrial Security Program and OSP’s Export Compliance – SEC-4.



The Environmental Health and Safety compliance questions were revised in March 2013. If you have questions, see the Environmental Health and Safety (EH&S) Web site, send an email message to ehsdept@uw.edu, or call EHS Research and Occupational Safety at 206.221.7770.

You do not need to enter any data if you answer Yes to an EHS question. Do be sure to read the additional information provided.

EHS-1. Will this project involve the use of biohazardous agents which include recombinant or synthetic DNA, human cell lines or tissue, viral vectors, bacteria, viruses, parasites, or other biohazardous agents as defined here? For projects involving human research participants, select yes if 1) the research involves recombinant or synthetic DNA (e.g. human gene transfer, recombinant or synthetic DNA vaccines), or 2) if work with human blood and source material will be performed in a non-clinical UW research laboratory.
 Biological Use Authorization (BUA) from the UW Institutional Biosafety Committee (IBC) is required as defined on the EH&S webpage. Please note that some categories of research require BUA prior to initiation. The BUA application submission deadlines are also posted on this website.
EHS-2. Will this project involve the acquisition, possession, use, transfer, or shipping of Select Agents and Toxins (at any quantity)? Agents include but are not limited to: Botulinum neurotoxins (Botox); Tetrodotoxin; Burkholderia mallei/ pseudomallei; SARS-associated coronavirus; 1918 and Avian influenza virus (highly pathogenic); Bacillus anthracis; Francisella tularensis; Coxiella burnetii; Yersinia pestis; Botulinum neurotoxin producing strains of Clostridium; Conotoxins. See the complete list on the CDC Select Agent Program website.
 EH&S approval of this eGC-1 is required due to federal regulations. EH&S will work with the PI to obtain necessary federal clearances, approvals, and training.Documentation of due diligence is required for any transfer of Select Toxins in any amount. Some Select Agent and Select Toxin research is subject to review by the Dual Use Research of Concern (DURC) Institutional Review Entity (IRE).

See the EH&S website for information about Select Agents and Select Toxins, Select Toxin Due Diligence, and DURC.

EHS-3. Will the proposed project generate mixed radioactive and hazardous chemical waste (i.e., radioactive materials mixed with heavy metals, flammable, reactive, and/or environmentally persistent chemicals)?
 EH&S will follow-up with the Principal Investigator to explore alternatives to avoid mixed radioactive and hazardous chemical waste.
EHS-4. Does the proposed project involve any of these specialized uses of radiation: transuranics, gaseous alpha-emitters, or intentional release of radionuclides to the atmosphere?
 EH&S will follow-up and explore alternatives with the Principal Investigator.
EHS-5. Will your research require the use of highly toxic, highly unstable, highly water reactive, pyrophoric, flammable gas, explosive or materials of similar hazard in quantities in excess of this table?
 EH&S will contact you with planning assistance as fire department requirements may not allow these quantities in your space or may require building modifications.
EHS-6. Does this sponsor require UW Environmental Health and Safety (EH&S) review prior to submission to the sponsor?
 EH&S will contact the PI to initiate review and obtain necessary signatures. For Department of Defense (DOD) Certificates of Environmental Compliance (CEC), please complete the steps listed on the EH&S DOD CEC website.
EHS-7. Will the project involve scientific diving?
 Anyone diving under the University of Washington’s auspices must have current certification as a University of Washington Scientific Diver and adhere to the standards set forth in the UW’s Diving Safety Manual. EH&S will contact you to assist in meeting Diving Safety Program requirements prior to diving.

If this is an NIH new or competing renewal application utilizing Just In Time policy, provide as much information as is available at this time. All of the following will need to be provided prior to grant and eGC1 review and sign-off by the IACUC office (for example, after the PI receives a fundable score from Study Section).

Note: Send any documents or questions to the UW IACUC office at oawsend@uw.edu

AC-1: Does this application involve the use of vertebrate animals?
Answer Yes if this application or subaward involves the use of vertebrate animals.

If you answer Yes:

  • Complete questions AC-1-A, B, C and D as described below.
AC-1-A: Does the application involve the use of live vertebrate animals, at any location, by UW faculty, staff or students, or non-UW personnel visiting the UW and working under a UW IACUC protocol?
If you answer Yes, provide the following information for each UW IACUC protocol:

  • IACUC Protocol Number: List all relevant IACUC protocol numbers. If IACUC will be writing a new protocol, use 0000-00.
  • IACUC Approval Date Range (3 years): Provide the 3-year IACUC approval date range for each protocol number listed above.

See also the IACUC web site.

AC-1-B: Does the application involve use of live vertebrate animals at any domestic (US) location other than the UW (e.g. custom antibodies, contracts, subawards or any collaborative work in support of the specific aims of the grant)?
If you answer Yes, please provide the following for each non-UW protocol:

  • Name of Facility: Indicate the facility where the work will take place (for example, “R & R Rabbitry”, “University of Pittsburg”).
  • Facility Location: Indicate the location where the work will take place (for example, “Pittsburg, PA”).
  • Animal Welfare Assurance Number: Indicate the Animal Welfare Assurance Number for each facility listed above (for example, “A3187-01” for the University of Pittsburg).
  • IACUC Protocol Number: List all relevant IACUC protocol numbers. A response of “Pending” or “JIT” is no longer an option.
  • IACUC Approval Date Range (3 years): Provide the most recent IACUC approval date range for each protocol number listed above.

If the PI does not know which protocol(s) will be used, or if IACUC will be writing a new protocol, only then should the protocol number be listed as “0000-00” (zeros) with no dates entered.

Provide a letter from the IACUC office of each of the facilities cited. The letter must confirm the protocol number and approval dates listed above, and it must indicate that the animal work is approved as described in the grant. A confirmation letter is not required from institutions that have inter-institutional agreements with the UW, such as the Fred Hutchinson Cancer Research Center and the Veterans Administration (VA) . However, for those institutions, the protocol(s) cited must be filed with the UW IACUC office. If they are not already on file, please provide them.

See also the NIH’s list of domestic Assurance Numbers.

AC-1-C: Are you citing any foreign sites for performance of live vertebrate animal work?
If you answer Yes, please provide the following for each foreign protocol:

  • Name of Foreign Facility: Indicate the name of the foreign facility where animal work will be conducted (for example, “University of London”).
  • Location: Indicate the location of the facility (for example, “London, United Kingdom”).
  • Animal Welfare Assurance Number: Indicate the Animal Welfare Assurance Number for each facility listed above (for example,  “A5195-01” for the University of London). A response of “Pending” or “JIT” is no longer an option.

Also provide:

  1. A letter from each foreign institution confirming that they have approved the protocol, and the date of approval.
  2. An English language copy of each protocol, for review and approval by the UW IACUC.

See also the NIH’s list of foreign Assurance Numbers.

AC-1-D: Will a Significant Change to any protocol associated with this proposal be required to perform the animal work?
Select Yes if the current protocol does not contain the studies, procedures, or animals that are in the proposal. It is highly advisable to prepare and submit an SC as soon as possible after you receive an indication of the likelihood of funding.

Select No if the protocol already covers all aspects of the proposal.

No further explanation is required.



HS-1: Will the project involve interaction with Human Subjects, or identifiable data or specimens from human subjects?

Answer Yes if this application or subaward involves the use of human subjects in biomedical, behavioral, minimal risk, or exempt research.

If you answer Yes, questions HS-1A and HS-1B will display. You must answer both of these questions either Yes or No.

  • HS-1A: Is any portion of the human subjects research pending IRB approval?
  • HS-1B: Is any portion of the human subjects research delayed onset?

If you answer No to both HS-1A and HS-1B, then you must select and/or enter an existing IRB application.

Add Approved IRB Application


NG-2: Does this application have funding from a foreign source or foreign subsidiary entity?
Check Yes if the funding sponsor is a foreign company or organization.

If you answer Yes:

  • Provide the name of the country where the foreign funding sponsor is located.