Sponsored Project Compliance: Policy and Procedural Guidance

• Memo from VPRED Nomura and VP Ewart (pdf)

GUIDANCE FOR IMPLEMENTING NATIONAL SECURITY PRESIDENTIAL MEMORANDUM 33 (NSPM-33) ON NATIONAL SECURITY STRATEGY FOR UNITED STATES GOVERNMENT-SUPPORTED RESEARCH AND DEVELOPMENT (whitehouse.gov)

National Security Policy Mandate 33 (NSPM-33) is a directive issued by the White House from January 2021 and which has continued through President Biden’s administration via Executive Order 14028 and further described by a January 2022 memo from the White House. This memorandum requires that federal research agencies standardize and strengthen disclosure requirements for entities and personnel (researchers) receiving federally funded awards. NSPM-33 also mandates the establishment of research security programs at research institutions who receive federal funds.

Goals of NSPM-33:

• Improving U of I’s overall security posture in research and the university in general. 
• Maximizing compliance with multiple requirements from multiple granting organizations as required by regulatory changes beginning in 2022. 
• Improving competitiveness and providing ability to respond quickly to research opportunities with enhanced collaboration, efficiency, trustworthiness, and repeatability. 
• Monitoring and quickly adapting to the constantly changing compliance requirements. 
• Supporting the university’s goal of achieving R1 status. 

• NSPM-33 – National Security Presidential Memorandum 33 must be implemented by all federal funding agencies and extends even to fundamental research performed at entities receiving more than $50 million in federal funding.
  • NSPM-33 can be broken down into two primary categories: Disclosure Requirements and Requirements for Research and Security and Training. 

• NIST 800-171 is for Controlled Unclassified Information (CUI) in non-federal systems. This could include data received from any federal agency, or through our subcontracts for such an agency.
• CMMC – is specific to research projects working with the Department of Defense and requires certification of a NIST 800-171 environment for CUI.

• The other support (current and pending support) reporting process will change as federal agencies release their implementation guidance in this area. Both National Science Foundation and National Institutes of Health have released their guidance to advance this facet of NSPM-33. Specific agency guidance is contained within the agency links in the “Sponsor Specific Information and Links” section of this webpage.
  • Examples of activities that may need to be disclosed include (but are not limited to):
    • Academic, professional, or institutional appointments and positions, whether or not remuneration is received, and, whether full-time, part-time, or voluntary
    • Postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whether or not they work on federally-funded research projects
    • Some Consulting activities
    • Travel supported/paid by an external entity to perform research activities with an associated time commitment
    • In-kind contributions
• The research security requirements are multi-faceted. See the Office of Information Technology (OIT) website on research security for details. Link coming soon.
  • Note that OSP has added data collection points to the VERAS proposal form in order to capture details relating to the compliance framework needs for each project.
  • The primary elements of the research security program and training piece of NSPM-33 are:
    • Cybersecurity
    • Foreign travel security
    • Research security training
    • Export control training

Your research processes and outputs are a vital part of the University of Idaho’s mission as a land-grant research university. The U.S. federal government recognizes this fact within the broader contexts of national security, global competitiveness in innovation, and protection of intellectual property from interference and exploitation. Under NSPM-33, the University of Idaho is required to establish a Research Security Program that addresses institutional research cybersecurity while also promoting necessary openness in the research community. The Research Cyber Support Program (RCSP) helps address institutional research security for NSPM-33 and other federal compliance standards.

To apply for and win federal research funding in the future, you will be required to address and disclose specific cybersecurity considerations related to your research. The UI’s Research Cyber Support Program (RCSP) is intended to provide a consistent mechanism so that researchers can easily and properly comply. 

Note that some costs relating to cybersecurity considerations can and should be included in your proposal application, in order to be considered for funding as part of the direct costs for a project. Consult with OIT (rcsp-team@uidaho.edu) early in the process to allow time to develop a compliance plan and to create accurate costing estimates for the project plan.

The University of Idaho is required by NSPM-33 to develop the Research Cyber Support Program (RSCP) in order facilitate compliance with new cybersecurity and disclosure requirements. This program is intended to support individual proposals, grants,contracts, and other agreement mechanisms, and awarded projects and will require a partnership between individual investigators, research computing, and OIT/RCSP.  RCSP will help investigators create and track systems security plans (SSPs) and will help monitor and mitigate cybersecurity risks associated with UI research.

RSCP will develop systems to make compliance relatively seamless. Research that involves Controlled Unclassified Information (CUI) or human subject/human health (IRB, HIPAA) may require additional scrutiny and specialized secure infrastructure as guided by the RSCP.

Note that agency policy will likely also require special information, data management and sharing plans, and other publication/release of information as part of the required transparency facet of NSPM-33. See the agency specific information in the ‘“Sponsor Specific Information and Links” section of this webpage or confer with pre or post-award team to get details regarding a specific agency or project.

Federal agencies have different and specific requirements for reporting other support (also known as current and pending support) – most federal agencies will require submission of another support/current and pending support form as well as a biosketch or Curriculum vitae (CV). See the agency specific accordions below for details on these requirements for each specific agency. 

Faculty and staff that are Principal Investigator and/or senior key personnel on a federal funded sponsored project have an obligation to ensure their other support (current and pending) is made available to the sponsor as required by that sponsor’s specific policy. Most sponsors require disclosure at pre-award (proposal stage) and require that personnel maintain regular updates to their other support through an individual report (ad hoc as support is received or discovered to have not been previously disclosed), foreign support or affiliation is realized, and/or through technical (progress) report updates. National Institutes of Health does not require other support reporting at the proposal stage for many types of Funding Opportunity Announcements (FOAs), but does require submission of the information at the Just-in-time (JIT) stage and with each Research Performance Progress Report (RPPR) as well as the final RPPR. See the agency specific accordions on this page (below) for details on reporting obligations during project life or at the JIT stage.

Foreign support reporting – note that specific agency policy may require reporting of any foreign support or affiliation, and that some agencies prohibit certain foreign support or affiliations. See the guidance in the agency links below for details per sponsor. 

Enter a ‘request current and pending support data’ ticket here. Note that OSP can only help to provide sponsored project data; other data types (departmental funding, affiliations, etc.) are not managed by OSP.

Details: OSP can provide you with a report from VERAS of your proposed support, and there is a second report available from Argos that departmental grant administrators (DGAs), OSP and faculty can access. Faculty must take the Banner navigation training and request Argos access through a TDNext ticket here however to gain access. Faculty who do not wish to gain access to Argos can also request the current support to be provided by OSP or their DGA.

ORCID – UI is a member organization and is working (as of Feb 2023) to active single-sign-on access to ORCID. ORCID can also help to populate data into Science Experts Network Curriculum Vitae (SciENcv), which will be the required formatting for National Science Foundation biosketches starting in October 2023. Note that an ORCID ID is already required for some types of NIH submissions.

Select the ‘submit current and pending support’ ticket type here to provide information to OSP on your foreign support or foreign affiliations. Note that you must upload the contract/agreement with the foreign entity to comply with requirements from some federal sponsors. If you need to report foreign support or affiliations are part of a just-in-time (JIT) or progress report, please select the Just-In-Time or Progress Report ticket type.

Submit a Just-in-time ticket request here.

Submit a Progress Report ticket here.

• Acronyms List

• APM Chapter 45: Research Office

a. The advance funding procedure is to be initiated by the PI, college, or unit (department) when a modification to an existing agreement (project) has not yet been received to extend and/or add additional funding to an established grant code (and index or indexes), or a modification has been received but not yet executed, to allow for expenditures in support of the next phase of the project. An authorized designee of the unit, per APM 45.05, must provide authorization for advance funding, to OSP Post Award, to allow for work to proceed for the next phase of the project in advance of the end-date or deficit spending. This process reduces the number of cost transfers, prevents disruptions in on-going project work, and helps to ensure that expenses are attributed to the project that they support. Advance funding differs from an early (preliminary) setup. Advance funding is for existing agreements as opposed to a new agreement. If a new agreement requires a project budget before the new agreement is received and executed, please see the early (preliminary) setup procedure for the relevant process and policy information.

Process: The unit Dean or institute equivalent, or designee, should submit an Advance Funding authorization email, utilizing the template below, via email to the Post Award unit of OSP. By providing the advance funding authorization, the unit is agreeing to absorb any incurred expenditures should an amendment not be received and executed for the advance funding amount and/or timeframe. Any pending charges beyond the project end-date or in excess of the awarded funding amount will not be permitted until advance funding approval is received from the College Dean or Dean’s delegate. For direct federally funded grant projects, the Vice President for Research and Economic Development will provide the advance funding guarantee, as long as the unit/college provides certification, using the template made available by the Office of Sponsored Program (below), that confirms that the PI is compliant with all deliverables and protocols per Section D-2 of APM 45.05.
If the advance funding approval, or certification of compliance for VP guarantee of advance funding, is not received by OSP prior to the end-date or expenditure of the current funding amount, the department will need to cease work and incurrence of charges for the project until such time as an amendment is received and executed. Should an amendment not be received from the sponsor (barring extenuating circumstances) within the financial closeout period, the department must transfer any overages or charges that occurred after the end-date from the account(s) as voluntary uncommitted cost share and OSP will close the project by sending a final invoice to the sponsor, as required under the terms of the agreement.

Template for advance funding authorization:“For project(s) INSERT GRANT CODE AND INDEX NUMBER(S), OSP and the department (college) have been informed that the sponsor intends to continue this project. However, UI has not yet received an official amendment from the sponsor. As the Dean or Dean’s delegate (or institute equivalent), I provide approval for the advance funding of this project. I understand that the University’s advance funding procedure allows for project expenditures to be incurred for the next phase of the project for up to 90 days and up to 25% of a 12 month period of funding. I certify that any expenditures incurred in the advance funding period will be the responsibility of the department or college, unless this project is a direct federal grant, should the sponsor not provide an amendment. By providing advance funding approval or request for VP guarantee of advance funding, the College certifies that the PI is compliant with all project deliverables and will remain compliant during the advanced funding period.”

APM 45.05

• NSF Audit Training (.ppt)
• Prior Approval (.pdf)
• Asset Management Training 1 (.ppt)

• Banner Forms & Reports Manual

• Contract Review Unit

• APM 45.06 - Allowable and Unallowable Sponsored Project Expenditures
• APM 45.07 - Cost Transfers on Sponsored Projects
• APM 45.08 - Cost Sharing ("Match") on Sponsored Projects
• APM 45.09 - Effort Reporting and Personnel Activity Reports (PARs)
• APM 45.10 - Facilities & Administrative (F&A) Rate
• Allowability
• ARGOS
• Budget and Cost Transfer Calculator for Sponsored Projects
• CAS Exemption Form
• Grant E-Code Lookup Tool
• NSF 2 Month Rule Justification Template
• Labor Redistribution Instructions
• Participant Support Costs Detail
• Effort Report Schedule
• Tools for Managing Research at the Transactional Level

• APM 45 - Preliminary Budget Setup
  • Agreements with Industry sponsors and Foreign Entities (including Canada) are generally not allowable for early setups due to state limitations on using appropriate funds for industry support, and a history of problematic terms and conditions (foreign). Project agreements and sponsors that typically utilize terms with start date as "date of last signature" are ineligible for early setups; OSP processes these agreements as a rush.
• Request an Early Setup by following the Early Setup Request Instructions and logging into VERAS

• Find Funding Site

• Fly America Act Information
• Fly America Act Presentation
• Fly America Act Exception Form
• APM 70.23 - International Travel

• APM 45.12 - Sponsored Project Closeout and Recordkeeping Responsibilities
• APM 45.16 - Payment Management
• Preparing for Closeout
• Reporting and Monitoring

If you assist in the management of a sponsored project that falls under a Master Agreement or Memorandum of Understanding (MOU), email the OSP Post Award team to request a copy of the agreement or amendment(s).

• Partnering With Business & Industry

• APM 45.02 - Sponsored Projects Proposal Preparation and Authorization
• Preliminary Proposal Submission Guidelines (.docx)
• Submitting a Proposal
• Proposal Submission Process
• Preparing a Budget
• Budget Template — 5 Year (.xlsx)
• NIFA Rate Comparison Calculator (.xlsx)
• NSF 2 Month Rule Justification Template (.docx)
• NSF Biographical Sketch
• NSF Current and Pending Support
• Subrecipient Commitment Form (.pdf)
• Voluntary Cost Share Waiver's are requested through OSP's ticketing system.**
• F&A Waiver's are requested through OSP's ticketing system.**
• Cost Accounting Standards (CAS) Exception Form (.docx)

Minimum Pay Rate under Executive Order 14026

• Memo regarding EO 14026 (.pdf)
• Does EO 14026 apply to my project? (.pdf)

**Please review the Quick Guide (.pdf) for additional instructions regarding OSP's ticketing system.

• APM 45.03 - Definitions for Grants, Contracts and Gifts
• APM 45.04 - Notice of Sponsored Projects and Establishment of Budgets
• What Happens When an Award is Approved?
• Additional Index request, are requested through OSP's ticketing system.**
• APM 45.05 - Early Set-up of Sponsored Project Budgets
  • Request an Early Setup by following the Early Setup Request Instructions (.pdf) and logging into VERAS
• Sub-budget Request Form (.pdf)
• APM 45.14 - Approvals for Post Award Changes to Sponsored Projects
• Prior Approval Process
• Managing Your Award
• Best Practices for Sponsored Projects
  • Best Practices Account Setup (.docx)
  • Account Setup Best Practices Checklist (.docx)
• PI Leaving-Retiring is requested through OSP's ticketing system.**
  • PI Leaving Spreadsheet (.xlsx)

  Note, the PI Leaving-Transfer request and all prior approvals must be submitted to agency sponsors at least 30 days prior to PI departure.

**Please review the Quick Guide (.pdf) for additional instructions regarding OSP's ticketing system.

• APM 45-13 - Program Income on Sponsored Projects
• Program Income on Sponsored Projects
  • Program Income PI DGA Instructions
  • Mock Program Income GRT

• APM 45.10 - Facilities and Administrative Rate
• Facilities and Administrative (F&A) Rates
• F&A Rate Definitions
• Fringe Benefits
• Travel/Per Diem Rates
• Tuition/Fees Rates

Effective January 23, 2023, Subawards and other services will now be requested through the University of Idaho ticketing system, rather than via email or a phone call to the Office of Sponsored Programs. Please review the Quick Guide for additional instructions. 

• APM 45.15 - Subawards and Subcontracts

• Office of Research and Economic Development (ORED) Entities & Initiatives

• VERAS Budget Preparation Guide (.pdf)
• VERAS Proposal Assistant User's Guide (.pdf)

• Council on Government Relations (COGR)

• eCFR (Electronic Code of Federal Regulations): Title 2 Subtitle A Chapter II Part 200

• Federal Demonstration Partnership

• National Aeronautics and Space Act (NASA)
• Grant Status
• NSPIRES — NASA Research Opportunities Online
• NASA Policy on Financial Conflict of Interest

• Policy and Terms and Conditions
• Research.gov
• Biographical Sketch

• Current and Pending Support
  • Additional information from U of I OSP for Current and Pending or Other Support Disclosures
• NSF - Foreign Affiliation/Support

Current or pending participation in, or applications to, programs sponsored by foreign governments, instrumentalities or entities, including foreign government-sponsored talent recruitment programs must be disclosed to the National Science Foundation at the time of proposal submission and during annual reports.

Any foreign affiliation or appointment would need be disclosed on the NSF Biosketch.  Foreign support or resources made available to an individual in support of and/or related to all of his/her research efforts (regardless of whether or not they have monetary value), need to be reported on the NSF Current and Pending Support form.

If any of the above information hasn’t been incorporated into applications or progress reports and should have been, the PI must contact OSP as soon as possible so that revised information can be submitted to NSF. A revision of the NSF Agency Specific Requirements which became effective on October 5, 2020 requires that this information be submitted to NSF by the institution’s Authorized Organizational Representative within 30 calendar days of the identification of the undisclosed support or contribution.

• NSF Safe and Inclusive off-site or off-campus research plan slides
• NSF Safe and Inclusive off-site or off-campus research plan template
• Term and Condition: Sexual Harassment, Other Forms of Harassment, or Sexual Assault
• NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support
• NSF PAPPG 24-1 Changes MEMO March, 2024

• eRACommons
• Grants and Funding
  • Forms H Change Summary– 1/25/2023
  • Forms H Notice from NIH
• NIH Other Support
  • Additional information from U of I OSP for Current and Pending or Other Support Disclosures
• NIH - Foreign Affiliation/Support

Current or pending participation in, or applications to, programs sponsored by foreign governments, instrumentalities or entities, including foreign government-sponsored talent recruitment programs must be disclosed to the National Institutes of Health at the time of proposal submission, the Just-In-Time Process and on annual research performance progress report (RPPR).

Any foreign affiliation or appointment would need be disclosed on the NIH Biosketch.  Foreign support or resources made available to an individual in support of and/or related to all of his/her research efforts (regardless of whether or not they have monetary value), need to be reported on the NIH Other Support form, including supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts/agreements are not in English, recipients must provide translated copies.

When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

• Data Management and Sharing Policy Information (.ppt)
• DMPTool
• U of I Library Services – Data Management and Sharing Plans

• Office of Naval Research (ONR)

• USDOC grants policies

• General Application Instructions (pdf)
• Other Support
  • FY22 (10/1/2021) General Application Guide: New Requirement: Certification Regarding Disclosure of Funding Sources. The proposing entity must comply with Section 223(a) of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, which requires that the PI, Partnering PIs (if applicable) and all key personnel:
    • Certify that the current and pending support provided on the application is current, accurate and complete;
    • Agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award; and
    • Have been made aware of the requirements under Section 223(a)(1) of this Act.

    False, fictitious or fraudulent statements or claims may result in criminal, civil or administrative penalties (U.S. Code, Title 218, Section 1001).

• For Proposals Submitted or Active Prior to 10/1/21: For all previous (award period of performance ending within the past 5 years); current; and pending (includes period of time awaiting funding status and/or period of time awaiting start date) research support; include the title, time commitments, supporting agency, name and address of the funding agency’s procuring Contracting/Grants Officer, performance period, level of funding, brief description of the project’s goals and list of the specific aims. If applicable, identify where the proposed project overlaps with other existing and pending research projects. Clearly state if there is no overlap.

List all positions and scientific appointments, both domestic and foreign, held by senior/key personnel that are relevant to an application, including affiliations with foreign entities or governments. This includes titled academic, professional or institutional appointments whether or not remuneration is received, and whether full-time, part-time or voluntary (including adjunct, visiting or honorary).

An updated previous, current and pending support document will be required if an award is recommended for funding.

• US Department of Energy (DOE)
• DOE PAMS
• Guidance and Forms
• Promoting Inclusive and Equitable Research plan (PIER plan)

• US Department of Homeland Security

• US Department of the Interior Bureau of Indian Affairs (USDI BIA)

• US Department of the Interior Bureau of Land Management (USDI BLM)

• United States Department of Agriculture Natural Resources Conservation Service (USDA NRCS)

• US Forest Service (USFS)

• US Geological Survey (USGS)

• USDA APHIS

• USDA Agricultural Research Services (ARS)

• USDA ezFedGrants

• USDA NIFA
• REEport

• US Office of Education
• Education Department General Administrative Regulations (EDGAR) and other applicable grant regulations