Award Terms and Conditions

Ohio State is committed to compliance with all applicable laws and regulations. The Consolidated Appropriations Act, which annually funds federal agencies, includes limits or conditions on the use of the funds. These limitations are commonly referred to as the Legislative Mandates. Some mandates are agency specific (e.g., the DHHS salary limitation) while others (e.g., anti-lobbying) apply more broadly. After each Appropriations Act is passed, agencies publish a list of the mandates that impact funding. Among the more enduring mandates are: 

• salary limitation  
• gun control  
• anti-lobbying
• acknowledgment of federal funding
• restriction on abortions
• exceptions to restriction on abortions
• ban on funding human embryo research
• limitation on use of funds for promotion of legalization of controlled substances
• restriction of pornography on computer networks
• restriction on distribution of sterile needles

The end product or deliverable of almost every research project is, at minimum, a final technical report. In addition, sponsors may have additional reporting requirements (such as periodic progress reports, patent reports, fiscal reports, etc.).

It is the principal investigator’s responsibility to ensure that required technical progress reports are submitted on time and in the format required by the sponsor. Reporting requirements are extremely important, and failure to adhere to these reporting requirements can jeopardize new awards campus-wide even if in connection with a specific grant or contract, or may result in a federal agency withholding or suspending payments for costs incurred by the university on other projects funded by the agency.

Delinquent reports may cause a sponsor to:

• postpone action on further awards, continuations or extensions until all reports are received
• withhold payment of invoices
• suspend the award
• request return of awarded funds

Specific sponsor requirements for the technical report are usually defined in the award package – sponsored program officers can help locate the requirements if necessary. All upcoming reports are listed in the PI Dashboard in the ‘My Tasks’ pane. Fiscal reporting is completed by the Office of Sponsored Programs Fiscal Services.

Whether required or not, it is a good practice to acknowledge sponsor support. Such support contributes to the university’s reputation as a research institution and may enhance the university’s position in receiving future research funds. The Stevens Amendment requires that in journal articles, reports and presentations at scholarly meetings, investigators recognize the federal government for its support of research by clearly stating:

• the percentage of total costs of the program or project which will be financed with federal money;
• the dollar amount of federal funds for the project or program, and
• percentage and dollar amount of the total costs of the project or program that will be financed by non-governmental sources.

There may be occasions when sponsors specifically request names not be used, or be used only with approval. Such restrictions would usually be part of the award document (generally a contract) and are noted in the PI Portal Award Overview tab. Sponsored program officers can answer specific questions about sponsor acknowledgment.
 

The university encourages the public dissemination of research results, while also recognizing the sponsor’s rights with respect to certain kinds of project-related information. Public announcements about new programs, for example, are often released by the sponsor or simultaneously by the sponsor and the university. When the project results are newsworthy, most sponsors wish to be informed before any public announcement is made. Before submitting a manuscript for publication, or an abstract of a meeting presentation, principal investigators should review the award document or the PI Portal Award Overview tab for sponsor requirements concerning release of project information.

Premature public disclosure of an invention or other potential intellectual property can compromise the university or sponsor's ability to obtain potentially valuable patents. All potential inventions should be disclosed to Office of Innovation and Economic Development (OIED) as soon as possible. OIED should also be consulted prior to submission of a publication or abstract or before any other public disclosure of project intellectual property. OIED will not ask that any publication or presentation be delayed.

Sometimes it is necessary for a sponsored project agreement to be modified. For instance, the principal investigator may need to rebudget funds from one category to another, require additional time to complete the project or change the scope of work. For federally funded projects, only grant or contracting officers can modify agreements. The sponsor’s program officials (i.e., technical contacts) are not authorized to approve any changes to agreements.

For most agreements, principal investigators should prepare a letter to the sponsor describing the desired change and explaining why it is necessary. The letter is countersigned sponsored program officer in the Office of Sponsored Programs and submitted by the Office of Sponsored Programs to the appropriate sponsor representative. To ensure enough time for a response, requests should be made at least 30 days in advance of the desired effective date. In certain circumstances, the Office of Sponsored Programs is authorized to initiate changes without sponsor approval. The sponsor must still be informed, however, of the changes that have been made.

University Position Statement

The Ohio State University (Ohio State) opposes human trafficking in all forms. Human trafficking is the recruitment, harboring, transportation or provision of a human being for labor and/or services through the use of force, fraud, or coercion for the purpose of involuntary servitude, peonage, debt bondage or slavery, or sex trafficking (definition adapted from FAR 52.222-50(a)).

Human Trafficking violates the University’s core values and conduct policies and is illegal under U.S. and state law.  Ohio State complies with all applicable regulations regarding Combating Trafficking in Persons, including FAR 52.222-50 Combating Trafficking in Persons for federal contracts and 2 CFR Part 175 Trafficking in Persons, for federal Grants and Cooperative Agreements.

What is prohibited?

Pursuant to the FAR 52.222-50 and similar DFARS clauses, University employees, agents, and subcontractors are prohibited from engaging in severe forms of trafficking in persons (as defined by FAR52.222-50), procuring commercial sex acts or using forced labor in the performance of any federally funded contract, grant or cooperative agreement.  This prohibition includes but is not limited to practices like using misleading or fraudulent recruitment methods such as concealing key terms and conditions of employment including wages, work location, living conditions and nature of the work; in certain circumstances, failing to provide return transportation or pay for the cost of return transportation upon the end of employment; and providing or arranging housing that fails to meet the host country housing and safety standards.

Who is responsible for compliance?

The Principal Investigator overseeing the work is responsible for the implementation of this Compliance Plan, including:

• notifying all employees, consultants, and vendors working under the award of the United States government’s zero-tolerance policy regarding trafficking in persons and the actions that will be taken against its employees or subrecipients for violation of this policy, including but not limited to removal from the contract, reduction in benefits, or termination of employment.
• immediately reporting any information received from any source that alleges an employee or subcontractor employee has violated the policy.
• working with Ohio State administration to take any appropriate actions up to and including termination of employees or subrecipients that violate the policy

The Office of Sponsored Projects (OSP) will:

• Notify subrecipients/subcontractors by flowing down applicable anti-trafficking requirements in subrecipient/subcontract agreements; and
• Notify any vendor by including the relevant anti-trafficking requirements in purchase agreements as needed.

Notification

Principal Investigators and other Ohio State employees must immediately report any information they received from any source that alleges an employee or subcontractor employee has violated the policy by using any of the methods in the table below and/or by calling the Global Human Trafficking Hotline at 1-888-373-FREE or sending an email to help@befree.org.

• Policy questions:
  • Office of Institutional Equity, 614-247-5838, equity@osu.edu
• To make a report:
  • Office of Institutional Equity, 614-247-5838, equity@osu.edu, titleIX@osu.edu
  • Anonymous Report - Anonymous Reporting Line (does not satisfy employee duty to report), 866-294-9350
  • Criminal report - University Police (to report criminal activity only, does not satisfy employee duty to report)
    • 911 (emergency)
    • 614-292-2121 (non-emergency)

Additional Information

Additional information about Trafficking in Persons and associated laws and regulations can be found at the U.S. State Department's Office to Monitor and Combat Trafficking in Persons website: http://www.state.gov/j/tip/, and the National Human Trafficking Resource Center website: https://traffickingresourcecenter.org/.