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Preliminary Proposals to be Required for NSF submissions to Deb and IOS
Last month, NSF announced a change to submission requirements for applications to the Directorate for Biological Sciences (DEB) and Innovation and Organizational Sciences (IOS). Since funding levels have been so low for DEB and IOS, NSF is now REQUIRING preliminary proposals for all submissions to the DEB or IOS programs starting January 2012. This will also apply to RUI submissions to these directorates.
- NEW Effective immediately, DEB will implement an annual cycle of preliminary and full proposals beginning in January 2012. Preliminary proposals will be accepted in January. Following review by a panel of outside experts, each applicant will be notified of a binding decision to Invite or Not Invite submission of a full proposal. Solicitation NSF 11-573 provides further details.
- NEW Effective immediately, IOS will implement an annual cycle of preliminary and full proposals beginning in January 2012. Preliminary proposals will be accepted in January. Following review by a panel of outside experts, each applicant will be notified of a binding decision to Invite or Not Invite submission of a full proposal. Solicitation NSF 11-572 provides further details.
This arrangement provides a unique challenge to the Office of Sponsored Programs (OSP) related to these preliminary proposals. In nearly all cases, before OSP will submit a proposal, a scope of work and budget must be prepared and circulated with an Internal Approval Form for approval. This process identifies the resource needs the PI has for the project and allows the Department Heads and Deans the opportunity to review/approve those needs before involving the sponsor. While this review/approval process would be wasteful for preliminary proposals not selected to submit, it would ensure departmental support for projects that were selected.
OSP does not feel comfortable making a blanket requirement for all departments in this situation. Accordingly, we will start by enforcing our normal process of requesting a budget and internal approval form for the preliminary proposal with the understanding that, if the PI’s Department Head (or Dean if the PI is a Department Head) approves the preliminary submission without this additional work, OSP will waive these requirements and process the submission with just that approval. The project would then be subject to OSP’s budget development and Internal Approval Form requirements at the time of full proposal.
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Changes Coming for Disclosure of Significant Financial Conflicts of Interests
DHHS Publishes Final Rule Updating Regulations
We have provided a synopsis of the published changes below. The full publication may be referenced through the following links:
Late last month the Department of Health and Human Services published the Final Rule revising Financial Conflict of Interest (FCOI) regulations which have been unchanged since 1995. To view a summary of major changes use this link to a helpful side-by-side comparison table.
The following changes purport to expand and add transparency to Investigators’ disclosure of Significant Financial Interests (SFIs), enhance regulatory compliance and effective institutional oversight and management of Investigators’ financial conflicts of interests:
Disclosure of FCOI
• Expanding the scope of the regulations to include SBIR/STTR Phase I applications
• Significant Financial Interests (SFI) Threshold lowered to $5,000 from $10,000 The threshold of $5,000 for disclosure generally applies to payments for services and/or equity interests. Includes any equity interest in non-publicly traded entities.
• Which SFIs Need to be Disclosed (Once the Threshold is Met)
All SFI related to the Investigator’s institutional responsibilities.
• Travel Reimbursements and Sponsored Travel
Disclose the occurrence of any reimbursed travel or sponsored travel related to Institutional responsibilities (including purpose of trip, sponsor/organizer, destination, and duration).
• Types of SFI Excluded
Excludes income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
JMU must report information on an Identified FCOI to the sponsor including name of investigator, name of entity involved in the FCOI, and value of the financial interest. JMU must also publish this information publicly via a publicly accessible web site or by a written response to any requestor within five business days of a request
FCOI Training for PI’s
Each Investigator must complete training prior to engaging in research related to any PHS-funded grant or contract and at least every four years.
JMU will review existing FCOI policies, updating to comply with the new DHHS ruling. Stay tuned for direction concerning these changes. For now, please continue to reference the FCOI University Policy 1106, http://www.jmu.edu/JMUpolicy/1106.shtml. If a potential FCOI is identified, please use the existing Federal Conflict of Interest Form (http://www.jmu.edu/sponsprog/allforms.html) to report any significant financial conflicts of interest to the Office of Sponsored Programs.
Inquiries about the current university policy or form may addressed to the Compliance Director, Pat Buennemeyer at email@example.com or by phone at 568-7025.
Summary Slide Set for the revised 2011 FCOI Regulation (08/25/2011) - (http://grants.nih.gov/grants/policy/coi/FCOI_082511.ppt --PowerPoint - 3.82 MB) - Summary slides that describe the major changes to the 1995 regulations on Financial Conflict of Interest (FCOI) - Responsibility of Applicants for Promoting Objectivity in Research for Which Public Health Service Funding is Sought. http://grants.nih.gov/grants/policy/coi/