Federal Funding Proposal Review

To meet the federal government’s expectations of institutions that receive federal research funds, UCI must ensure all individuals required by the federal sponsor to submit biographical sketches and other/current & pending support are submitting 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?

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

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

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?

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

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

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 and Investigators are appropriately identified in the Personnel tab of the Kuali Research Development Proposal (KR PD) system. The Key Personnel section in the KR Proposal Development (KR PD) collects information about UCI researchers for two processes: Federal Proposal Review for Research Security & International Engagement (RSIE) and Conflict of Interest in Research for federal sponsors/prime sponsors. It is important to complete this section correctly so that the system can electronically trigger the processes as necessary. Note: Non-UCI researchers should not be included in the KR PD Personnel tab.

Federal Proposal Review Does the Federal sponsor/prime sponsor require a biographical sketch from this individual?	Conflict of Interest Is the individual an “Investigator” (responsible for the design, conduct, or reporting of the project)?	KR PD Personnel Role(s) Which KR PD Personnel Role should be used for that individual?
Yes	Yes	Principal Investigator, PI/Contract, PI/Multiple, Co-PI, or Key Person
Yes	No	Other Significant Contrib. (Contributor) (available 2/28/24)
No	Yes	Federal sponsor/prime sponsor with COI Policy (PHS, DOE, NSF, and NASA): Investigator
No	Yes	Federal sponsor/prime sponsor without a COI Policy: Do not include the individual in the KR PD Personnel tab
No	No	Do not include the individual in the KR PD Personnel tab

Initiators are responsible for clicking the "Notify All" button to send an auto-generated email notification to all Senior/Key Personnel and Other Significant Contributors with a direct personalized link to complete their certifications. This feature can be used multiple times for follow-up emails.
Senior/Key Personnel and Other Significant Contributors are responsible for completing the certification questions in a timely manner.
Senior/Key Personnel, Other Significant Contributors, 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 and Other Significant Contributors 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 Security & International Engagement (RSIE) 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, RSIE will collect additional information to develop recommendations on next steps for the REC Director's consideration. As part of its review, if RSIE 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.

KR PD Personnel Tab Roles

Senior/Key Personnel

Roles: Principal Investigator, PI/Contact, PI/Multiple, Co-PI, Key Person

This UCI individual will be sent an email with a custom link to the RSIE questionnaire they need to complete prior to the proposal being submitted to workflow. In addition, if the federal sponsor/prime sponsor has a conflict of interest policy (PHS/NSF/DOE/NASA), they also must have a current KR COI Annual Disclosure on file prior to proposal submission.

Other Significant Contrib. (Contributor)- available 2/28/24

Role: Other Significant Contrib. (Contributor)

Use this KR PD Personnel role when an UCI individual is required by the federal sponsor to submit a biographical sketch and other/current & pending support but does not meet the COI definition of an Investigator. This individual will be sent an email with a custom link to the RSIE questionnaire they need to complete prior to the proposal being submitted to workflow. No COI disclosure requirements.

Investigator

Roles: Investigator

This UCI individual is responsible for the design, conduct, or reporting of a research project with a federal sponsor or prime sponsor with a conflict of interest policy (PHS/NSF/DOE/NASA) but was not required by the federal sponsor to submit a biographical sketch or other/current & pending support. These UCI individuals must have a current KR COI Annual Disclosure on file prior to proposal submission. No RSIE questionnaire required.

Helpful Tips

Initiators should input Senior/Key Personnel and Other Significant Contributors 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 and Other Significant Contributors 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 and Other Significant Contributors matches the list in the proposal application.
If the Senior/Key Personnel and Other Significant Contributors 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 and Other Significant Contributors 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.
- Please remember to include the locations and names of entities/organizations affiliated with each relationship/position/affiliation.
Department/unit staff who support Senior/Key Personnel and Other Significant Contributors 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 and Other Significant Contributors 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 individuals required by the federal sponsor to submit biographical sketches and other/current & pending support are submitting 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?

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

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

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

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

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

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

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?

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