December 18, 2025
MRAM Q&A December 2025
Meeting materials are available for your review along with a list of links shared during the session. Q&A from our session are included here for reference and are available in the MRAM announcements.
Within a week or so following every MRAM, an email like this one typically goes out with Q&A from the session and a link to the meeting materials.
SAGE Update
Q1: Can SAGE be updated to auto-send out emails when a proposal is submitted by OSP?
A1: Yes, this is possible. ORIS will raise this with OSP for prioritization.
Q2: If SAGE Budget Snapshots are going away, does that mean we need a new copy of the budget for every MOD with any schedule or funding change? We cannot re-use anything that is linked elsewhere?
A2: You will be able to use the same SAGE budget for the full award lifecycle, as long as the MOD requests are for the same award. There may be times, however that GCA requests a separate budget, if it will be difficult to clarify intent within a full award budget.
Q3: Can SAGE send an auto email when an ASR or MOD is put on hold?
A3: Yes, this is possible. ORIS will raise this with the AIDE award workstream group for prioritization.
Q4: what date is the roll out date for SAGE budget integration to MODs?
A4: MODs budget integration is planned for December 18 at 5:30 p.m.
Q5: Are the list of updates to the eGC1 questions posted anywhere so we can review them? We went over them very quickly.
A5: These are published with the MRAM slides for the December Meeting.
Export Controls Compliance
Q1: What’s the definition of foreign person in question D-3?
A1: A ‘foreign person’ for U.S. export compliance purposes is anyone who is not:
- a U.S. citizen;
- a U.S. permanent resident/green card holder; or
- someone granted U.S. asylee or U.S. refugee status
Q2: Does faculty need security clearance to conduct export controlled but unclassified research?
A2: No. Security clearances relate to the classified system. Questions regarding the classified information should be directed to the UW’s Facility Security Officer: uwfso@uw.edu
Q3: How much extra time should we plan for submissions that answer yes to D2 or D4?
A3: Timing can vary depending on the circumstances, but the earlier the better. Please feel free to reach out to exports@uw.edu with any questions related to export compliance, including before submitting a proposal to OSP or even unrelated to a sponsored project.
Q4: if we have international travel planned then, with the PI presumably taking their laptop, should we be saying YES to any export?
A4: No, eGC1 question E-2 specifically excludes UW owned laptops and cell phones. That said, there may be export restrictions on software and/or technical information on such devices, which we are happy to help determine if an export license may required. Please reach out to exports@uw.edu
Q5: On occasion, sponsors seek to have research results considered the confidential information of the generating party until the same are published in accordance with the agreement’s publication clause with an additional sunset clause which eliminates the confidentiality obligation a period of time after the agreement’s expiration. Does this temporary confidential status present export control concerns?
A5: Potentially yes, but we would need to look into the specific details. This is the definition of fundamental research under the Export Administration Regulations (EAR). If the publication restriction is for proprietary or national security reasons, then the resulting technical information may not be considered fundamental research, and consequently may be subject to U.S. export control laws.
Q6: What if someone is doing Fieldwork in a Foreign Country?
A6: Not directly related to export compliance, but important to note: “All official international travel is required to be registered with the OGA through the UW Global Travel Registry before the expected departure date.” (see APS 75.1 Official International Travel). Questions related to the travel registry should be directed to: travelemergency@uw.edu
The Office of Export Controls is working on export compliance questions in the travel registry to help with our export compliance efforts.
Generally speaking in terms of export compliance, the Office of Exports Control would be interested in knowing:
- what items they may take out of the U.S. to perform the fieldwork (e.g. eGC1 question E-2);
- the country/countries where the fieldwork would take place (e.g. eGC1 question E-2);
- if they are collaborating with any parties (question in the travel registry asks if collaborating with an institution, and if yes, to provide the institution’s name);
- if the project is fundamental research or not (e.g. eGC1 question D-3)
Secure Research Computing
Q1: Where should the memo be attached in the eGC1?
A1: Attach these in the Internal Documents for OSP.
Q2: Do we need to prorate using this secure environment across our projects?
A2: Response provided by Post Award Fiscal Compliance: If we are incurring costs for users, those costs could be allocated across all funding sources which require this level of computing environment. Sponsored awards which do not require secure computing should not be charged, as there is no direct benefit to the award objectives.
Additionally, units need to be cognizant of the term for the computing environment coverage in relation to the period of performance of their awards; awards should only be charged for the proportional benefit of the cost. For example, if an award ends 6/30/25 and the secure environment cost covers 1/1/25-12/31-25, the award can only be charged for the proportional share of the value of six months.
Q3: Will you be sending an email notification to PIs about the increase in cybersecurity requirements?
A3: We are working on PI communications around all of the updated compliance requirements and resources for early January.
Q4: What does CUI stand for?
A4: Controlled Unclassified Information (CUI)
Q5: What CMMC level is the WFS provided by UWIT?
A5: WFS has no CMMC compliance level.
Q6: Does this mean Klone will be NIST SP 800-171 compliant by April 2026? Has UW-IT secured funding for this?
A6: Klone will not be 800-171 compliant, that is CMMC Level 2 roughly. Klone will be Level 1, self-assessed.
Q7: With the IT charges to plan for grants, will the UW be waiving the new WA State Dept Revenue new tax charges for IT?
A7: For UW GCC, we’re already paying sales tax and that is built into the costs we pass along to PIs.
NIH Update
Q1: How can a proposal be deemed competitive if it hasn’t been reviewed? Apologies if I’m misunderstanding.
A1: NIH is likely indicating that while a smaller proportion of applications will be discussed in peer review meetings, others are still reviewed individually by the people on the study section and receive a score.
Q2: If an RPPR is due Feb 1 but the PI wants to submit on or before Jan 24, is it ok to use the old Other Support document – not housed in SciENcv ?
A2: The existing format should be used for RPPRs submitted on or before Jan. 24, not the Common Forms.
Q3: For NIH RPPRs, do you have suggested language or a template for Key Personnel to certify non-participation in an MFTRP?
A3: Although we have not seen a separate template for RPPR certifications, a statement with language that matches the certification in the Common Form for NIH biosketches should be acceptable. Please note the instructions in NOT-OD-26-018 for how to identify and upload each certification to the RPPR.
Q4: Where can we find a good definition of Malign Foreign Talent Recruitment programs? Investigators are asking.
A4: The definition of a Malign Foreign Talent Recruitment Program (MFTRP) is from the CHIPS and Science Act. This is summarized in an Office of Science and Technology Policy memo to federal research agencies. A number of circumstances are listed that might turn a relationship into an MFTRP. We encourage investigators who engage in foreign collaborations to be watchful of any potential for these circumstances to apply to their activities.
Q5: Is research training certification required for biosketches submitted in an RPPR that have new key personnel and is submitted after January 2026?
A5: For NIH, research security training is required for deadlines/submissions on or after May 25, 2026. We expect that the relevant certification will be available in SciENcv prior to that time.
Q6: The NOT says: #2: NIH will enforce the use of the Common Forms via eRA system validations immediately as a warning when the wrong form is used. By February 6, 2026, the warning will be elevated into an error preventing submission of the incorrect or uncertified forms.
Will OSP accept the old biosketches until 2/6/26?
A6: As the NOT continues, “Failure to utilize the correct forms during the timeframes specified in the table below [i.e., on or after 1/25/26] will cause NIH to withdraw your application from consideration.” We highly encourage using the correct biosketch form based on your deadline or submission date, regardless of whether eRA validations in ASSIST, for example, treat this as a warning or an error. PIs are responsible for following sponsor technical instructions in preparing the application and assume the risk of withdrawal if these are disregarded.
Guidance Updates
In anticipation of the SAGE release planned for later tonight the following resources have been updated: