Federal Funding Proposal Review

To meet the federal government’s expectations of institutions that receive federal research funds, UCI must ensure all Senior/Key Personnel disclose complete and accurate information about their international engagements in compliance with federal agency disclosure requirements. This expectation applies to federal proposals, including subaward proposals where a federal agency is the prime sponsor (collectively referred to as federal proposals). Meeting this expectation and complying with the federal agency disclosure requirements is essential for ensuring that UCI remains eligible to receive federal research funds.

Kuali Research Proposal Development (KR PD) includes six questions regarding international engagements that all Senior/Key Personnel must answer before federal proposals are routed to Sponsored Projects Administration (SPA) for institutional review, approval, and submission. International engagements include, but are not limited to, employment, appointments, consulting activities, participation in foreign talent recruitment programs, and research support/funding from foreign sponsors not received through UCI.

Please note that delays will occur if the questions are not answered. Therefore, principal investigators, their support staff, and department/unit staff should take this into consideration in planning proposal submission timelines.

Questions

Are you employed by a foreign entity?

If Yes, please include all current foreign employment in your biosketch submitted with this proposal, and please provide the following for each employer:

Position title,
Employment percentage, and
Foreign entity name and country.

Are you a consultant (paid or unpaid) for a foreign entity?

If Yes, please include all current consultancies in your biosketch submitted with this proposal, and please provide the following for each consultancy:

Nature or purpose, and
Foreign entity name, and country.

Do you hold an academic appointment (including an honorific or merit-based title) or have an academic affiliation with a foreign entity?

If Yes, please include all foreign academic appointments or affiliations in your biosketch submitted with this proposal, and please provide the following for each appointment and/or affiliation:

Appointment title or nature/purpose of affiliation, and
Foreign entity name and country.

Are you currently participating in, have you been accepted into, or do you have an application pending with a foreign government talent recruitment program or a similar program?

If Yes, please disclose your foreign government talent recruitment program status in your biosketch and/or current and pending support forms (in accordance with the sponsor’s application requirements) submitted with this proposal, and please provide the following:

Program name
Foreign entity name and country, and
participation start and end dates.

Does any proposal to a foreign government research funding entity include support or funding for you that will not be received through UCI?

If Yes, please disclose any such proposals in your Current and Pending Support/Other Support form for this proposal, and please provide the following for each pending proposal:

Project title,
Foreign governmental sponsor,
Your role on the project, and
Project dates.

Do you have research support or funding from a foreign government research funding entity that was not received through UCI?

If Yes, please disclose this research funding or support in your Current and Pending Support/Other Support form for this proposal, and please provide the following for each research award:

Project title,
Foreign governmental sponsor,
Your role on the project, and
Project dates.

Printable Questions Reference- Updated

Key Definitions

Foreign Entity: A foreign entity is any foreign government (including any agency or subdivision), or any corporation, business association, partnership, trust, society, or any other entity or group that is not incorporated or organized to do business in the United States.

Consultant: For the purposes of these questions, "consultant" broadly refers to an individual that provided or provides a paid or unpaid service to a foreign entity whether or not there is a written agreement for the service performed. Disclose these activities unless specifically excluded by the federal sponsor (see Federal Sponsor Disclosure Requirements).

Foreign Government Talent Recruitment Program: A foreign government talent recruitment program is an effort organized, managed, or funded by a foreign government or entity to recruit science and technology professionals to promote, advance, and/or increase the prestige and global impact of that country's research enterprise.

Foreign Government Research Funding Entity: A foreign government research funding entity is any non-U.S. government (or component thereof) that supports research projects by awarding funds. For example, the foreign equivalent of the National Science Foundation, the National Institutes of Health, the Department of Energy, etc.

Procedures

Initiators are responsible for ensuring that all Senior/Key Personnel are listed in the Personnel tab of the Kuali Research Development Proposal (KR PD) system.
Initiators are responsible for clicking the "Notify All" button to send an auto-generated email notification to all Senior/Key Personnel with a direct personalized link to complete their certifications. This feature can be used multiple times for follow-up emails.
Senior/Key Personnel are responsible for completing the certification questions in a timely manner.
Senior/Key Personnel and Initiators are responsible for knowing what information must be disclosed in a federal proposal and ensuring that the proposal in KR PD (either as an attachment or a Cayuse link) includes all required disclosures. Please see the federal agency disclosure requirements webpage for additional information.
After all Senior/Key Personnel complete the certification questions and the proposal is otherwise ready, it may be routed to Sponsored Projects Administration, where Contracts & Grants Officers (CGOs) will review the KR PD responses and the proposal to identify any discrepancies. If a discrepancy is found, the CGO will notify the KR Initiator/department administrator (or other unit personnel, as appropriate) to resolve the discrepancy. After all discrepancies are resolved and the CGO has completed the institutional review, the CGO will submit the proposal to the sponsor.

As part of UCI’s research security due diligence process, when a certification question response is “yes”, the Research Engagement & Compliance (REC) team will review the certification question(s) as part of a risk analysis to determine if the foreign engagement is high risk and requires further review. If so, REC will collect additional information to develop recommendations on next steps for the REC Director's consideration. As part of its review, if REC finds any new discrepancies, they will notify the researcher and work with them to resolve it, which may include submitting corrected information to the federal sponsor.

Helpful Tips

Initiators should input Senior/Key Personnel in the KR PD proposal as early as possible, then click the “Notify All” button to send the certification questions. Sending the Senior/Key Personnel a reminder that they will receive an email from kr-admin@uci.edu with a link to the certification questions from the Initiator’s email may also be helpful.
- Also, make sure the KR PD list of Senior/Key Personnel matches the list in the proposal application.
If the Senior/Key Personnel are having trouble accessing the questionnaire off-campus or on the UCIMC network, we recommend to log into the VPN and then trying to access the questionnaire again through the email notification.
If Senior/Key Personnel respond "yes" to any certification question, they should check to make sure their certification responses match their biographical sketches and current & pending (other) support to avoid delays and additional work.
- Please note that any discrepancies between the proposal and the responses to the certification questions must be resolved before the CGO can submit the proposal to the federal sponsor.
Department/unit staff who support senior/key personnel should encourage them to maintain an up-to date list of all foreign affiliations, relationships, activities as a personal reference, as well as encouraging them (and/or assisting them) to regularly update their biographical sketches and current & pending (other) support information.
If senior/key personnel are unsure whether to disclose an international engagement, it is best to disclose. The federal sponsor will either include it or exclude it in their review as appropriate and consistent with their established procedure.

Frequently Asked Questions

Why is there a new Federal Funding Proposal Review process?

To meet the federal government’s expectations of institutions that receive federal research funds, UCI must ensure all Senior/Key Personnel disclose complete and accurate information about their international engagements in compliance with federal agency disclosure requirements. Meeting this expectation and ensuring that proposals are accurate and complete is important to maintaining UCI’s ability to continue receiving federal research funding.

Will my proposal be submitted to the sponsor with incomplete certification questions or unresolved discrepancies?

No, if the certifications are not complete or there is an unresolved discrepancy, the proposal will not be submitted to the sponsor.

What if the the researcher is out of town or unable to complete the certification questions?

This is a requirement, so all researchers should submit their certification responses early in the process. ERA does not have superuser access to bypass these questions.

If there are any concerns with meeting the federal deadline for a specific proposal application, share that information with your Contracts & Grants Officer for guidance.

Does this process apply to proposals where UCI is the subrecipient (incoming subaward)?

Yes. The main purpose of this new review process is to improve the accuracy and completeness of all of our researchers' disclosures to the federal sponsors.

Does this process apply to proposals where UCI is the pass-through entity (outgoing subaward)?

No. Our expectation is that those other institutions will be taking appropriate steps to ensure the accuracy of their researchers' disclosures.

Do we need to include other/current and pending support in the proposal if it is not required at the proposal stage?

Only include the disclosures required by the federal agency at the time of proposal submission. Please refer to Federal Sponsored Projects and sponsor's proposal instructions.

Note: If a draft proposal will be submitted for institutional proposal review, all required disclosures (biosketches and if applicable, current & pending support) must be in final form.

When Initiators copy a proposal, do the certification responses also copy?

No. When a proposal is copied, the system generates a new link to the certification questions for each Senior/Key Person to complete.

How will the Initiator know that corrections to a disclosure need to be made prior to proposal submission to the sponsor?

This will be requested by the Contracts & Grants Officer as part of the Institutional Proposal Review process. If edits need to be made, the proposal will be returned for revisions.

Can Initiators view submitted certification responses to confirm that information is accurately disclosed in biosketches and/or current and pending/other support prior to submitting to workflow?

Yes, by navigating to KR PD for that proposal and click "Summary/Submit," "Personnel," the "(view)" links under Proposal Person Certification for those who have "complete" statuses.

What is the difference between Key Person and Investigator roles in KR Proposal Development?

A new KR PD personnel role, "Investigator," will be available for federal and federal flow-through proposals. An "Investigator" is a person responsible for the design, conduct, or reporting of the project and captures individuals who are required to submit conflict of interest disclosures.

The role, "Key Person," captures individuals labeled as Senior/Key Personnel in the proposal application. These individuals are required to submit biosketches and other/current & pending support documents per federal agency requirements.

All Senior/Key Personnel are required to complete the certification questions and to submit conflict of interest disclosures (if applicable). However, not all Investigators are Senior/Key Personnel so those listed as Investigators will not be required to complete the certification questions. The Principal Investigator is responsible for ensuring researchers are accurately labeled in their proposals.

Will Initiators be copied on the email notifications to researchers with the certification question links?

Yes, Initiators who send the notification through KR PD will be copied on that email.