Federal

Contents

The next steps necessary to set up your federal award will vary based on the type of award (contract vs. grant or cooperative agreement) and the awarding agency.

Many requirements and restrictions can impact how you set up and manage federal awards. Some standard examples to be aware of include:

• Equipment – Federal awards typically have prior approval and disposition requirements on equipment and equipment purchases. Review the award documentation, sponsor guidelines,  and consult guidance from:
  • Post Award Fiscal Compliance – Equipment:  includes information on prior approvals, cost allocations, and more…
  • Equipment Inventory Office
  • Equipment Closeout
• Foreign Interests – review Foreign Interests in Sponsored Programs
• Telecommunications Purchases – review Telecommunications Purchase Restrictions

Other examples may be agency or award specific.

Agency Specific Requirements and Systems

Department of Defense (DoD)

US Army Medical Research and Materiel Command (USAMRMC)

Awards under the Congressionally Directed Medical Research Program (CDMRP) may need approval from the USAMRMC’s Office of Research Protections, in addition to UW Institutional Review Board and UW Institutional Animal Care and Use Committee protocol approvals.

Resources including the Funded Investigators Guide from CDMRP, will guide the PI through setting up awards from USAMRMC.

Department of Education (DoEd)

The DoEd has a Grant Management System, G5, that OSP uses to retrieve awards and submit changes. We have a different DUNS number for DoED than for other sponsors.  Use this DUNS #: 042803536.

New to DoEd grants?  Check out DoEd’s e-learning opportunities.

Department of Energy (DOE)

The Portfolio Analysis and Management System (PAMS) is used for:

• Viewing award documents
• PI submission of Progress Reports
• OSP submission of  Award Modification Requests

Foreign-Government Talent Program Disclosure

The DOE does not allow participation in the Foreign Talent program by its employees or contractors. Additionally, when the UW receives DOE awards that reference Order 486.1A, the PIs and other participating UW personnel must complete this Foreign Government-Sponsored Talent Recruitment Programs (FGTRP) Disclosure form. These awards will be placed on HOLD until OSP receives the completed forms.

Foreign National Participation on DOE Awards

When foreign national participation is anticipated on DOE awards that include FAR Clause 142.3A or 142.3B, the PI/Dept. must notify osp@uw.edu. This email should provide the following information:

• eGC1#
• Note there needs to be  foreign national participation on the award
• Unit HR contact who will complete foreign national information (e.g. citizenship) details
• List of foreign nationals (first, last) who need to participate

An OSP reviewer will contact the sponsor to initiate the secure DOE NETL Form or DOE FAST system process used to make a formal request to include foreign nationals. The appropriate departmental HR contact must provide personally identifiable information (PII) regarding each foreign national participant. Separately, the UW Export Control office may follow up with the PI to implement any needed security plan.

Department of Justice (DoJ)

DoJ grants run through the Office of Justice Programs (OJP). They use JustGrants for the award set up and post award activities such as progress reporting.

Work closely with your OSP reviewer to setup your DoJ award.

Department of Health and Human Services (HHS)

Many agencies that fall under the HHS such as National Institutes of Health (NIH), Agency for Healthcare and Research Quality (AHRQ), Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA) and Substance Abuse and Mental Health Services Administration (SAMHSA) use eRA Commons for certain pre-award, post award, and closeout activities.

Review the eRA Commons roles to determine which role you need, and contact OSP for access.

More select agency guidance is available below.

Health Resources and Services Administration (HRSA)

HRSA Electronic Handbook (EHB) is the single access point for all HRSA grant and non-grant programs for grant submission and administration. Create your EHB account following HRSA instructions.

National Institutes of Health (NIH)

Notice of Grant Awards (NOAs) from NIH are sent directly to the Office of Sponsored Programs. PIs do not need to provide a copy to OSP. NOAs are also available in the eRA Commons.

Be sure to review the NIH Grants Policy Statement in addition to the terms of your award.

National Oceanic and Atmospheric Administration (NOAA)

NOAA uses the Department of Commerce’s eRA Commons.

Resources

NOAA Grants Policy

National Science Foundation (NSF)

Awards from NSF are sent directly to OSP. PIs do not need to provide a copy to OSP. Awards are also available in the sponsor system (Research.gov).

PIs get access during proposal preparation. The same user information is used to log into Research.gov for project reporting and financial management.

Federal Contracts

Federal Contracts require compliance with numerous federal rules and regulations including the Federal Acquisition Regulation (FAR).

Project set up, reporting, and management must be handled according to specific requirements in the contract. There can be a significant amount of planning, work, and cost involved to implement and follow these requirements.

In some cases, this planning and work must be done before the contract is even awarded.

Failure to comply, perform or follow deadlines in federal contracts can result in criminal/civil and financial consequences for the PI and the University.

E-Verify

Many federal contracts and flow-through federal contracts require the use of E-Verify to establish employment eligibility of designated employees. This requirement does not apply to grants.

During the award set up process, OSP notifies departments and PIs if their federal contracts contain the E-Verify clause. Visit the Integrated Service Center’s E-Verify guidance for details on the process.

Vendor Diversity Goals

Pay attention to time frames in your award document for when diversity goals need to be in place and work with UW Procurement to develop those goals.

Learn more about the UW Procurement Services policies related to requirements for supplier diversity.

Small Business Subcontracting Plans

If the contract proposal requires the submission of a Small Business Subcontracting Plan, review the Procurement Services small business subcontracting plan instructions and worksheet.

Information and Security Requirements

Check your contract to determine whether it includes requirements related to Homeland Security Presidential Directive 12 (HSPD-12), Federal Information Processing Standards (FIPS), and/or Federal Information Security Management Act (FISMA).

If the contract includes them, these requirements may impact your budget, consider costs when preparing your proposal.

Typical HSPD-12/FIPS/FISMA Requirements:

Information Technology (IT) Security Plans, Risk Assessment and FIPS 199 Assessment are all due within 30 days of the contract being awarded. Security Certification & Accreditation is due within 3 months after a contract has been awarded.

Due within 30 Days After Contract Award

IT Security Plans (IT-SP)

These plans must describe the process and procedures that will be followed to ensure the security of IT resources. It must also comply with numerous federal regulations such as: FISMA, National Institute of Standards and Technology (NIST) 800-18 and 800-26, HHS Office of the Chief Information Officer (OCIO) Information Systems as well as others.

IT Risk Assessment (IT-RA)

Must be consistent with NIST 800-30-Risk Management Guide for Information Technology Systems and any additions for augmentations described in the HHS-OCIO Information Systems Security & Privacy Policy

FIPS 199 Assessment

Must follow the NIST standard.

Due within 3 Months After Contract Award

IT Security Certification & Accreditation (IT-SCA)
Must follow the HHS Chief Information Security Officer’s Certification & Accreditation Checklist, NIST 800-37, and 800-53.

Contractors must submit written proof that an IT-SCA was performed for applicable information systems. The draft IT-SCA must be signed by a senior management official.

Federal Post Award Grants Management Systems

Many sponsors have their own post award grants management systems. Set up access for required individuals including the PI.

Human Subjects Research Considerations

See the Human Subjects Division (HSD) website for information about all aspects of human subjects research.

Almost all federally funded human subjects research must comply with several specific requirements that are part of setting up the project.

Obtain Institutional Review Board (IRB) approval or an exempt determination before conducting any human subjects activities or spending any research funding on such activities.

Complete Required Training

Federal sponsors require senior/key personnel to complete training in human subjects protections. In addition, principal investigators and clinical trial staff conducting NIH supported clinical trials must complete a Good Clinical Practice (GCP) course every three years.

Establish a single IRB for multi-site clinical trials

A single IRB must be used to review all domestic sites participating in federally-funded multi-site or collaborative research, beginning January 20, 2020. Contact HSD for consultation about who should be the single IRB and how to start the single IRB process.

Register Clinical Trials

Studies that meet the definition of “clinical trial” must register at ClincalTrials.gov.

Genomic Data Certification

NIH funded studies that will create human genomic data are required to send the data to an NIH database, for broad sharing with other researchers. This data must be “certified” by the PI’s institution prior to sending the data. The certification process is usually part of the Just-in-Time process and part of the initial IRB process.

Specific Federal Agency Requirements

See HSD’s Worksheets for information about specific human subjects requirements for the following federal agencies: Department of Defense, Department of Justice (includes the National Institute of Justice), Environmental Protection Agency, and Department of Energy.