COVID-19 Related Notices
COGR |?NIH | NSF |?DOE?| DOD | NASA | NEH?| FDA | DHHS | NEA | CDC | AHRQ
COVID-19?RELATED ANNOUNCEMENTS?|?OPERATIONAL TRAVEL CHANGES?
COGR - Agency information?(5/6/20)
COGR - Institutional Information?(5/6/20)
COGR - FAQs??(5/6/20)
Information for NIH Applicants and Recipients of NIH Funding Related to COVID-19 - updated powerpoint (4/24/20)
Applicant/Recipient COVID-19 Update History (4/2/20)
Impact on Existing Deadline Dates?(Updated 4/24/20)
FAQs regarding the NSF Dear Colleague Letter on the Coronavirus Disease 2019 (COVID-19) (NSF 20-052)? (4/7/20)
Department of Energy Office of Science - Accommodating Interruptions from Coronavirus Disease 2019 (3/16/20)
DoD Financial Assistance Recipients Affected by the Loss of Operational Capacity and Increased Costs due to the COVID-19 Crisis (4/13/20)?
Office of Naval Research (ONR) Coronavirus Assistance and Acquisition-Related Information and Resources (4/1/20)
Closure of NASA Centers, Laboratories and Test Facilities for NASA Grant or Cooperative Agreement recipients due to Coronavirus (COVID-19) situation (3/30/20)
National Aeronautics and Space Administration HQ - Assistant Administrator for Procurement Message on Coronavirus? (3/16/20)
Food & Drug Administration (FDA) Guidance on Conduct of Clinical Trials of Medical Products during COVID-19 Pandemic (3/19/20)
National Endowment for the Arts (NEA) FAQs and Information for Applicants and Grantees in response to COVID-19 (Updated 3/31/20)
Flexibilities Available to Applicants and Recipients of Federal Financial Assistance Affected by COVID-19 (3/25/20)
AHRQ (Agency for Healthcare Research and Quality) Flexibilities Available to AHRQ Recipients and Applicants Directly Impacted by the Novel Coronavirus (COVID-19) Due to Loss of Operations (4/10/20)
An important reminder of the NIH Foreign Component notification requirement found in the NIH COVID?Flexibilities FAQs?here:
Yes,?this would qualify as a foreign component as per the?NIH Grants Policy Statement Section 1.2- Definition of Terms, which defines a foreign component as?“the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”
Further instructions from the NIH RPPR Question G.9 -?
Foreign component:??Provide the?individual &?organization name, country, and description of each foreign component.
Foreign component is defined as?significant scientific activity that was performed outside of the United States, either by the grantee or by a researcher employed by a foreign organization, whether or not grant funds were expended.?The following grant-related activities are significant and must be reported:
? Involvement of human subjects or research with live vertebrate animals;
? extensive foreign travel by grantee project staff to collect data, or conduct surveys or sampling activities; or
? any grantee activity that may have an impact on U.S. foreign policy.?
Examples of other grant-related activities that may be significant are:
??collaborations with investigators at a foreign site anticipated to result in co-authorship;*
? use of facilities or instrumentation at a foreign site; or
? receipt of financial support or resources from a foreign entity.
Foreign travel for consultation does not meet the definition of foreign component.
If a?Graduate Student?on an active NIH research grant must return home to a foreign country and work remotely due to COVID-19,?we recommend?(based on definition about co-authorship above) that this be reported to NIH as a foreign component.?
Federal agency guidance on charging costs to sponsored projects during the COVID-19 pandemic emergency continues to be published on the OSP announcements page (here).
Through June 17, 2020 many Federal Agencies (e.g., ?NIH, NSF, NASA, ONR, DARPA) are allowing grant/cooperative agreement recipients to continue to charge salaries and trainee stipends to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal.? This includes researchers who are unable to work as a result of or related to the effects of COVID-19 in accordance with university policy (see Brown University?notices dated 3/14/20 “Immediate steps to reduce community exposure”; 3/15/20 “Ramping down research”; 3/27/20 “Job continuity for Brown employees”).
If progress of the work will be impacted, PIs should consult with their program officer to determine if a scope of work change, time extension or other action is necessary. If so, the submission of an agency notification is done through OSP or BMRA.
The extension of these emergency federal regulations beyond mid-June employees is not known at this point. Per the authorizing Memo from the Office of Management and Budget (OMB) “these exceptions are time limited and will be reassessed by OMB within 90 days of this Memo” which is dated March 19, 2020. ?OSP will be posting further guidance as it becomes available.
Repurposing Existing Federal Financial Assistance Programs and Awards (Grants) to Support the Emergency Response to the Novel Coronavirus (COVID-19)?
In April Workday Communications notified the community of a new Program Worktag to track expenses related to the ongoing COVID-19 pandemic.? We encourage use of the?PRG300 COVID-19?for sponsored project funds as well.? With Federal Agencies allowing salaries, fringe benefits during the work remote order and allowing the repurposing of?grant?funds including supplies?and personnel, it is critical that Brown be able to track the financial impacts on internal and external funds. Details below:
?Note, that while NIH states that supplemental/ replacement funding requests will be considered (not a guarantee), NSF and NASA do not offer that option.?This information is current as of 5/5/20
To?meet?emergency needs, Brown may donate PPE and other research supplies purchased with NIH grant funds to support COVID-19 efforts (e.g., to hospitals and local healthcare facilities).
????????re-budget grant funds to repurchase supplies at a later date
????????use large unobligated balances
????????submit administrative supplement requests
? ? ? ? ?Note: NIH can only provide additional funds to support supplies that are directly charged to the project(s).
Recipients are authorized, as specified below, to donate medical equipment (including, but not limited to, personal protective equipment, medical devices, medicines, and other medical supplies) purchased with NSF funds to hospitals, medical centers, and other local entities serving the public for COVID-19 response. This class exception also extends to the donation of other resources (such as labor, supplies, and contract services) funded under Federal financial assistance to support COVID-19 emergency response activities.
To utilize this flexibility,?the Authorized Organizational Representative (AOR) in OSP or BMRA must submit the request to donate items or resources via use of “Other Request” in the Notifications and Requests module in Research.gov.?Each request should specify the items or resources to be donated and any anticipated impacts of the donation on the scope of the project.?If the anticipated impact of the donation will result in a change in objectives or scope, the “Change in Objectives or Scope” in the Notifications and Requests module must be used to reflect that change.
By submitting a request, Brown is certifying that the equipment, supplies, etc., is being donated to a hospital, medical center or other local entity serving the public for the COVID-19 response. Recipients must?not?assume that supplemental funding will be available should the donation result in a shortage of funds to eventually carry out the project. Recipients are required to maintain appropriate records to substantiate the donation in support of COVID-19 emergency response activities.
Please note that, pursuant to OMB guidance, these administrative relief flexibilities are intended to be time limited.
Personal Protective Equipment (PPE) was purchased using grant funding. Can PPE be donated to local first responders?
Donating Personal Protective Equipment (PPE) purchased with NASA grant funding to first responders is allowed under grants directly related to the COVID-19 emergency response and grants not related to the COVID-19 response on a case-by-case basis. However, the recipient should?not?assume that additional funds are available should the costs of donating the equipment result in a shortage of funding or supplies at a later date. Additionally,?before donating the PPE, recipients must first notify and obtain approval from their cognizant NASA program office.?The recipient must also document and maintain records on all PPE donated to local first responders in response to the COVID-19 crisis. The prior approval request should be submitted through OSP or BMRA to NASA.
For non-refundable tickets purchased prior to March 9, 2020, our current guidance is that cancellation fees on federal grant related activities can be charged to sponsored funds if the cancellation was a result of an external organization’s action, (e.g. a vendor cancelled a conference or site visit), is due to the CDC travel restrictions (see CDC Level 3 countries) or is due to Brown’s prohibition on travel. This guidance is subject to change as federal agencies provide updated information.
Departmental Cost Center Managers/Authorized Approvers must ensure any change or cancellation fees charged to sponsored funds are reasonable and allowable. Travelers should retain documentation of their cancellation request, change/cancellation fees and remaining vendor credits.
Please note that Trip Cancellation Insurance is not ordinarily allowed on sponsored awards. At this point in time, the preferred action is purchase of a refundable ticket. For non-federal sponsors, the award’s terms & conditions will require review as to allowability. Contact your OSP Staff Grant & Contract Administrator or Accountant with questions on non-federal awards.
On February 5, 2020, the NIH issued Notice NOT-OD-20-065, Guidance on Salary Limitation for Grants and Cooperative Agreements FY 2020 announcing that the Executive Level II salary cap? increased to $197,300 effective January 5, 2020. The new salary cap applies to awards from the NIH, CDC, AHRQ, SAMHSA, and other DHHS organizations.
?The?Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 20-1)??will be effective for?proposals submitted or due, and awards made, on or after June 1, 2020. Significant changes include, but are not limited to:
Chapter II.C.2.f, Biographical Sketches, has been modified to require use of an NSF-approved format in submission of the biographical sketch. NSF will only accept PDFs that are generated through use of an NSF-approved format.?More on the SciENcv?
Chapter II.C.2.h, Current and Pending Support, has been modified to require use of an NSF-approved format in submission of current and pending support information. NSF will only accept PDFs that are generated through use of an NSF-approved format.?
Chapter II.E.1 and 2, Rapid Response Research (RAPID) Proposal and EArly-concept Grants for Exploratory Research (EAGER) Proposal, have been supplemented with language which clarifies how RAPID and EAGER proposals may not be used. A new requirement that email documentation from a cognizant NSF Program Officer approving submission of a RAPID or EAGER be uploaded to the proposal also has been added.?
2020 Effort Reporting Schedule (12/10/19)
The highly anticipated 2020 effort reporting schedule is now available!?Please follow?this?link?to access the schedule and plan ahead.? Contact Robin Eubank at?[email protected]?with any questions.??
A new Principal Investigator Eligibility Policy will go into effect on January 1, 2020.? The Policy,?PI Approval form and a summary Chart are available?here.
Proposal deadlines following Thanksgiving Holiday. Please be mindful of the University's closure on November 28th and 29th when planning your proposal timelines.? Since 5 full days are required for review of proposals, you may need to adjust your proposal routing process to allow for these holiday closures.? As an example, proposals due to the sponsor on December 2nd would therefore need to be routed to OSP/BMRA by 5pm on November 20th.?
Winter Break Deadlines
Proposals due over the University's Winter Break (between December 21 and January 1st) must be submitted to the sponsoring agency on Friday, December 20th and are therefore due to OSP/BMRA by?5pm on December 12th. This will allow enough time for the review and approval process to be completed.
Due to the short time period between Brown's reopening and the January 7th NIH deadline, we recommend that all submissions for that deadline are routed for an initial review?before?Winter?Break. For these submissions, administratively complete proposals should be routed to?OSP/BMRA by?5pm on December 17th. Final science for these proposals will not be due until 5pm on Thursday, January?2nd.
With the new process, the effort reports for terminated employees will still be generated either as the termination notice is received by the Effort Certification Administrator (ECA) or when effort reports are generated through the regular scheduled reporting cycle.? The revised business process for the certification of terminated employee effort reports is summarized as follows:?
Terminated Worker Effort Certification Routing Process if PI is Active
- ECA will generate the effort report (as currently done today).
- ECA will reassign the effort report to the Effort Certification Partner (ECP) or Cost Center Manager (CCM) in Workday.
- ECP or CCM should review the report, make any necessary changes, and submit the effort report.??
- Effort report will route to the PI for certification.?
Terminated Worker Effort Certification Routing Process if PI is Inactive
- ECA will generate the effort report (as currently done today).
- ECA will reassign the effort report to the Effort Certification Partner (ECP) or Cost Center Manager (CCM) in Workday.
- ECP or CCM should review the report, make any necessary changes, and submit the effort report.
- Effort report will route to WD Operations once submitted.
- ECA will communicate with department personnel to determine the appropriate person with firsthand knowledge of the worker's effort that can certify the report.
- ECA will work with WD Operations to forward the effort report to the appropriate person for certification.
Upcoming Proposal Submission Deadlines?for OSP/BMRA Review (9/16/19)
*UPDATE* please note the updated date for F Series and Diversity Fellowships due to Holiday Closures
Federal Agency Guidance on Notification and Reporting of Discrimination and Harassment (9/5/19)
Brown University (“Brown” or “University”) is committed to creating and maintaining an educational, research, working, and living environment free from all forms of unlawful harassment and sexual misconduct.? The University has created policies and procedures that describe the community standards of conduct as well as the procedures for grievances and complaints alleging?violations?of its discrimination and harassment policies.
In addition to University policy, Federal and State sponsors of Brown’s research have notification and reporting requirements related to sexual harassment, harassment, sexual assault, and discrimination.? Many of these sponsors have recently issued rules and guidance regarding these requirements and the importance of adhering to them.
The specific Federal Agency Guidance can be found?here.?
Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (7/10/19)
NIH has released a detailed reminder to the extramural community about the need to report foreign activities through other support, foreign components and financial?conflict of interest.??NOT-OD-19-114.html? contains an expanded clarification and detailed FAQs.?At this time, NIH is?currently in the process of updating the Other Support Format Page and instructions. The requirements provided in the notice?will likely evolve further.? Should you have any questions, contact?OSP? or?BMRA?Pre-Award Staff.?
NSF released a communication on Monday stating "National Science Foundation (NSF) has designated the National Institutes of Health’s?SciENcv?(Science Experts Network Curriculum Vitae) as an NSF-approved format for submission of biographical sketch(es) and is encouraging its use to prepare a biographical sketch for inclusion in proposals to NSF.??The following website resources may be of assistance to proposers preparing a biographical sketch using the SciENcv format":
- SciENcv Background
- YouTube Video: SciENcv Tutorial
- YouTube Video: Integrating with ORCID
- SciENcv Help
Important Proposal Submission Update?(5/20/2019)?
After an 8 week pilot period where we tested the efficiency and effectiveness of submitting proposals in sponsor's systems, OSP and BMRA have determined that proposal submission via sponsor systems does not have a negative impact on either the proposal preparation or the review and submission processes.? As such, we are announcing a change to our submission guidelines.
Effective today, proposals that are eligible for System-to-System submission can either be submitted in COEUS or in a sponsor system such as ASSIST, FastLane, or Workspace.?There will no longer be a requirement that S2S-eligible proposals be submitted via COEUS.
Please note that regardless of which submission method is used, COEUS remains our official proposal repository. For this reason, a COEUS record will still be required at the time of submission for all proposals.
We've developed an?FAQ?to accompany this announcement, but please also feel free to reach out to your Pre-Award contact with any questions you may have.
2019 NIH Salary Cap Increase (5/6/2019)
The Executive Level II salary cap used by the Department of Health and Human Services (which includes NIH) has been increased to $192,300. This change is effective retroactive to January 6, 2019, so please be sure to use this new rate in NIH and AHRQ proposals going forward.
More information from NIH can be found here: NOT-OD-19-099.
If you have any questions, please feel free to call or email your OSP/BMRA Pre-Award contact.
Identifying all Sources of Support in Proposals for External Funding (3/14/19)
Federal sponsors are focusing more closely on the full disclosure of project support than in years past. There is concern about ‘under-reporting’ of available research funding and of foreign sources of research support (i.e., foreign components, defined below). It is critically important that complete and accurate information about research support is included in all grant and contract proposals whenever required. This requirement will vary from sponsor to sponsor, so be sure to include other support information in conformance with each Agency’s instructions.?Please keep reading for further information here.
Pre-Award Staff are responsible for:
Post-Award Staff are responsible for:
The Office of Sponsored Projects (OSP) supports Brown University faculty, students and staff in the acquisition, performance, and administration of projects and programs funded by external sources. OSP provides the University's central coordination and oversight of research by offering a wide range of services including review and submission of proposals; award negotiation and acceptance; dissemination of research policy information to campus; issuance of subaward agreements and sub-recipient monitoring; compliance with governmental and private funding agency standards; advising on financial management of sponsored projects, financial and expense reporting; cash management; effort reporting, and monitoring of cost-share arrangements; addressing financial and administrative issues that arise during the life of a sponsored project; coordination of award close-out process; and providing education and professional development opportunities in research administration for the campus community.