Legislative Mandates
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
Reporting Requirements
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.
Acknowledging Sponsor Support
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.
Public Release of Project Information
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.
Modifications to Sponsored Agreements
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.