Dear Colleagues,

I am writing to provide you with important information about new federal government requirements regarding disclosure of all support for your and your colleagues’ research.  This change will impact all individuals listed as Key Personnel (PI, Co-PI, Co-I and other Key Personnel) when requesting federal research funding.  I have communicated with you previously about NIH and NSF disclosure requirements, and I am writing to you now as all federal agencies have begun requiring these disclosures.

Under newly-implemented federal law, all “covered individuals” on a project must disclose in all federal funding applications the amount, type, and source of all current and pending research support they receive or might receive – whether that support has already been received, is expected to be received at the time of the disclosure, or is pending (and thus not even certain).

Covered individuals are all people who contribute in a substantive, meaningful way to the development or execution of a project.  Most funding agencies designate who they consider a “covered individual,” and JHURA and ORA maintain updated information on agency-specific rules.  In general, any principal investigator or co-investigator and anyone who would qualify as “key personnel” are considered “covered individuals.”

Additionally, the federal definition of “research support” that must be disclosed is very broad, and means:

“all resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of (1) whether the source of the resource is foreign or domestic; (2) whether the resource is made available through the entity applying for a research and development award or directly to the individual; or (3) whether the resource has monetary value… [Research support] includes in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or students.”

This means that “research support” includes both resources that you receive through Johns Hopkins University and some resources that you may receive outside of a formal contract through JHU.  For example, if visiting faculty or scholars who are supported by their home institution work in your lab on federally-funded research, that constitutes reportable support.

Finally, the federal government now requires all covered individuals to certify that they have been made aware of these disclosure requirements.  You will complete this certification within the University’s proposal submission system.

JHURA and ORA have further information about the specifics of current-and-pending-research-support on their websites.  In addition, members of the Provost’s office and the research administration offices are available to provide departmental briefings as needed.  Thank you again for your compliance with federal laws and regulations.

Best,

Denis Wirtz, PhD

Vice Provost for Research

Theophilus Halley Smoot Professor of Engineering Science

• Competing Compliance Questionnaire
• Non-Competing Compliance Questionnaire
• Personnel Certification Form

• The Personnel Certification is for JHU personnel only and should be signed by the JHU PI, any JHU Co-I, and any JHU Key Personnel
• All other Coeus Questionnaires must be signed by the JHU PI
• Signatures may not be delegated

• If your department has subrecipients receiving federal funds from JHU, they are required to have a Unique Entity Identifier (UEI) through the System for Award Management (SAM).
• The UEI is required in order for JHU to report FFATA (Federal Funding Accountability and Transparency Act) activities as required under federal awards

• If your subrecipient was registered in SAM.gov prior to the UEI conversion (April 2022), then SAM.gov automatically provided a UEI number and you can:
  • Check this USA Spending crosswalk tool for legacy DUNS numbers and their corresponding UEIs
  • Check the FDP Clearinghouse (this is for domestic higher education institutions)
  • Ask your subrecipient for the UEI

• Your subrecipient will need to request a UEI directly from SAM.gov. JHU cannot complete this step on behalf of the subrecipient
• Also, please note, the subrecipient does not need to "register" their organization.
  • Registering an organization with SAM.gov is a separate and more arduous administrative procedure for an organization receiving U.S. federal funds directly from a federal agency.
• The subrecipient only needs to "request" a UEI.
  • Requesting a UEI is a streamlined procedure with SAM.gov that is not administratively burdensome. 

• NCURA: Guidance on NIH RPPRs with COVID-19 Impact (1/27/22) 
• NCURA: Cost Share- Tackling the Challenges (10/25/21) 
• NCURA: Here's What PI Transfers are All About (9/20/21) 

• Brown Bag: Ask JHURA (5/11/22)
• Brown Bag: Subrecipient Determinations (4/13/22)
• Brown Bag: Introduction to the IRB and Considerations when working with the JHU IRBs (3/9/22)
• Brown Bag: Research Access to JHM Data (2/9/22)
• Brown Bag: Subrecipient Monitoring (1/10/22)
• Brown Bag: JHURA Systems Review & Fibi Updates (12/10/21) 
• Brown Bag: Foreign Currency Sponsored Awards (11/10/21) 
• Brown Bag: JHU Data Services- Management and Sharing (10/13/21) 
• Brown Bag: Students and Employees Working Abroad (9/8/21)