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Office of Sponsored Programs (OSP)

Time of Award

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Just-In-Time

Just-in-Time (JIT) refers to the process used by NIH, AHRQ, CDC and DOD of providing compliance documentation and other supporting project information after proposal submission for proposals that receive a fundable score. This usually occurs a few months before the anticipated award start date.

Participating funding agencies send out a JIT request to the authorized official (e.g., OSP) and the PI. Read and follow this document for your specific application.

NIH policy requires applicants to submit their information using the JIT feature of the eRA Commons at least 60 days before the application's proposed project start date.

Review information on submitting Institutional Certification for Genomic Data Sharing at JIT.

Benefits of this process include saving PI & department effort during proposal development, compliance offices and committees are not burdened with reviewing applications that do not have a high likelihood of being funded, and sponsors do not have to receive and store as many documents.

Upon sponsor's request, for incoming subawards a departmental representative fills out the UW Subrecipient PI contact information on the Federal Demonstration Project (FDP) template Attachment 3B page 1. UW institutional information has been pre-filled for your convenience.

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Time of Award

Time of Award refers to the period immediately preceding OSP accepting the award on behalf of the University. Most assurances and other information must be submitted to the sponsor before OSP can release the award.

Funding Action (FA) is an electronic mechanism used by OSP to transmit detailed award information to GCA for budget set-up and award distribution. An FA will be released by OSP only when the necessary compliance approval is in place, a revised budget breakdown is provided when needed, and an agreement has been signed by both UW and the sponsor.

Closeout / End of Award Ensure to prepare for closeout / end of award from the start!

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Plan Ahead

Compliance issues can sometimes be addressed before the award is received. Because they can involve multiple departments and levels of review, compliance issues should be dealt with as early as possible, to prevent foreseeable delays in administering the award. When OSP reviews an award, any compliance area that arises due to the nature of the project must be resolved prior to processing the funding for that project.

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Compliance

These are some of the issues that must be addressed before OSP is able to release your award.

Animal Subjects:

The Office of Animal Welfare must conduct a "side-by-side" review of the proposed work and approve the protocol before the funds can be released by OSP.

For more information:

Cost Share:

Cost sharing (sometimes referred to as matching or in-kind) is the portion of a project or program costs not borne by the sponsor, and must be paid by either a UW budget or third party. Before OSP can process the award, the department/PI must complete a cost share addendum and cost share calculator (when there is faculty effort cost share) and submit it to their OSP team.

For more information:

Environmental Protection Agency (EPA) Grants with "Fair Share Goals":

Plan for Environmental Protection Agency (EPA) Fair Share Goals also known as Disadvantaged Business Enterprises2 (DBEs), Minority Business Enterprises (MBEs) and Women's Business Enterprises (WBEs) in advance. The Principal Investigator (PI) is responsible for setting "fair share" goals for MBEs and WBEs within 120 days of accepting the EPA award, making progress towards these goals. Learn more about the UW Procurement Services Policy, Procedures and reporting responsibilities related to this requirement for DBEs, MBEs and WBEs.

E-Verify:

E-Verify is required for all employees working directly on a federal contract (not grants) that requires E-Verification. OSP will add a note to the award Funding Action and OSP Administrator will send a letter to the PI about this requirement. The PI is responsible for ensuring that E-Verify is completed for every employee under the contract. For new employee(s), e-verification must be completed no later than the end of three (3) working days after the employee's actual start date. For current employee(s), e-verification must be done within (thirty) 30 days after assignment to the contract.

For more information:

Export Control:

All activities undertaken by the UW, including research activities, must comply with the Export Control regulations and UW policies. It is the responsibility of the faculty and staff to be aware of the export control requirements under the regulations and program administered by OSP. Certain projects that include controlled information or technology may require a license, or other written approval from the U.S. Government prior to export, or a Technology Control Plan that is prepared by the PI and approved by OSP.

For more information:

Financial Conflicts of Interest (FCOI):

Primary Disclosure Status

OSP will release funding upon verification that all named investigators on the PI & Personnel page of the eGC1 have a Primary Disclosure and the Primary Disclosure status indicates one of the following:

  • SFI is not related;
  • No Review Required;
  • Review Complete; FCOI not found - OR - FCOI Management plan in place.

PHS FCOI Training Status

If an investigator is PHS-funded, the PHS training requirement applies. OSP verifies this requirement is fulfilled in the Compliance Details column of the eGC1 PI & Personnel page. The following training statuses allow OSP to release funding:

  • PHS FCOI Training not required, -OR-
  • PHS FCOI Training complete; expiration date is current as of date of FA processing.

Any PHS FCOI Training status indicating "PHS FCOI training required" will cause a hold on funding processing.

For more information:

For policy questions, email research@uw.edu

For technical questions, email sagehelp@uw.edu

Human Subjects:

At OSP's request:

  • For IRB applications requested via Zipline, provide letter of approval or letter of exemption
  • All other applications provide the reviewing IRB and the full IRB study number

Per the Federal Common Rule, all human subjects research requires review by an IRB, unless it is exempt. NOTE: minimal risk review is a type of IRB review.

OSP will release funds when the following IRB/HSD status applies to the funded project:

  • Active, Approved
  • Exempt
  • Not Research
  • Not Human Subjects

OSP will release funds with restrictions when the following IRB statuses or determinations apply:

  • Pending or Conditional approval for non-federal only
  • PI assurance that project qualifies as "delayed human subjects research" (e.g. human subjects may be involved within the period of support, but definitive plans for human subjects involvement cannot be described in grant application)
  • PI assurance that human subjects research will not begin until Year 2 or later
  • PI assurance that only subrecipient will carry out human subjects activities

OSP will hold funds when the following IRB status or HSD determination applies to the funded project:

  • Pending (All federal funding)
  • Deferred (All funding)
  • Conditional Approval (All federal funding)
  • Lapsed
  • Suspended
  • Denied

If spending restrictions exist, OSP will enter comments on the Funding Action.

For more information regarding the level of review required for anticipated human subjects research activity, see the Human Subjects Division webpage.

Institutional Certification for Genomic Data Sharing Policy:

The NIH Policy on Genomic Data Sharing applies to all NIH-funded research that generates large-scale human or non-human genomic data as well as the use of these data for subsequent research. The Policy requires that investigators provide a Genomic Data Sharing Plan within the Resource Sharing Plan section of the proposal.

Process to obtain Institutional Certification

  1. NIH institute requests Institutional Certification (Review the Human Subjects Division SOP Request for Genomic Data Sharing Certification - Investigators to learn more about when this is required.)
  2. Approximately six to eight weeks prior to intended start date, follow Human Subjects Division's Genomic Data Sharing Certification procedures for requesting Institutional Certification.
  3. Upon approval, Human Subjects Division sends certification to the PI.
  4. The PI needs to sign the Institutional Certification and:
    • If at Just-in-Time (JIT), include with JIT materials, route to Signing Official (SO) in eRA Commons & notify OSP via osp@uw.edu if not already in communication with someone at OSP.
    • OSP receives JIT materials in eRA Commons, reviews and submits to NIH.
    • OSP's submission of this documentation via eRA Commons to NIH signifies institutional certification.
    • If after award received, send signed certification to osp@uw.edu. OSP will sign and submit to NIH.

Institutional Certification cannot be provided until HSD carries out its review! While HSD approval is pending, use the NIH Provisional Institutional Certification and include with your JIT materials. OSP can then proceed with review and submission of those materials, pending the final certification.

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Budget

Advance Budget Number (ABN ) - a budget number can be provided in advance of the award set up if certain criteria are met. See the ABN webpage for additional information, use the Eligibility Tool to determine if your project meets the criteria and request that OSP release it, and then use the ABR in SAGE to request an advanced budget number. See GIM 9.

Revised Budget - When the award arrives at OSP, if the awarded budget is different from the proposed budget, OSP may request a revised budget breakdown into UW object codes from the Department. Only once OSP receives this budget breakdown can we process your award.

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