Working with USDA

The United States Department of Agriculture (USDA) released general terms and conditions (GT&C's) on December 31, 2025, which are applicable to all new awards and significant amendments issued by all its agencies. Since then, the USDA released two deviations (2026-USDA-0001-F and 2026-USDA-0001-M) that Legal Affairs has determined must be incorporated to accept an award by any USDA agency. 
 

All Covered Individuals conducting research on a USDA award must take the following compliance actions: 

• Complete Research Security Training before starting research work on the project (this is already required for anyone conducting federally-funded research at Ohio State). 
• Create and certify both the USDA Biosketch and USDA Current and Pending (Other) Support in SciENcv, which confirms that the Covered Individual is not currently participating, and has not participated in the past 10 years, in a Malign Foreign Talent Recruitment Program. 
• Attest that they are not subject to Foreign Ownership, Control, or Influence (FOCI). 

Note: Sponsored Programs is currently building an automated compliance process. In the meantime, your SPO will contact you with further instructions if you are a PI on an active USDA award.

The GT&C and Deviations require Covered Individuals to take specific compliance actions. Covered Individuals do not need to be paid from the award to be covered. The deviations define a Covered Individual as:

1. An individual who meets both of the following criteria:
   1. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
      1. Directing the overall scientific direction of the project;
      2. Designing or critically evaluating key experiments or methodologies;
      3. Interpreting primary research data or results;
      4. Serving as a primary or senior author on publications resulting from the project;
      5. Exercising direct supervisory authority over research personnel working on the research project; or
      6. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
   2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee.
2. Or, any other individual whom USDA specifically identifies in writing as a Covered Individual.

The USDA GT&C Deviations define FOCI as follows:

“Foreign ownership, control or influence (FOCI)” means a situation where the degree of ownership, control, or influence over the recipient or a covered individual by a foreign person or foreign entity that is a citizen or permanent resident of; representing; organized, chartered, or incorporated under the laws of; or otherwise substantially connected to a foreign adversary or foreign country of concern such that a reasonable basis exists for concluding that compromise to that foreign person or foreign entity of non-public research, development, scientific, or technological information associated with the Federal award may result.

What this means

FOCI exists when the university or a researcher on a federal award has ties to a person or organization connected to a foreign adversary or country of concern, and those ties create a realistic risk that non-public, federally funded research could be accessed or taken by that foreign party.

Examples of these ties include:

• Foreign funding
• Foreign ownership or board membership
• Close personal or organizational relationships

Effective December 31, 2025, the USDA requires that all Covered Individuals certify annually that they are not currently affiliated with a Malign Foreign Talent Recruitment Program (MFTRP), have not been affiliated with a MFTRP in the past 10-years, and will not be affiliated with a MFTRP during the award's period of performance. 

To certify compliance with this MFTRP requirement, Covered Individuals must complete and certify both the USDA Biosketch and USDA Current and Pending (Other) Support document within SciENcv. 

Getting Started with SciENcv

1. Log in to SciENcv through NCBI. Login options include Login.gov, eRA Commons, Research.gov, and others.
2. Select MyNCBI Dashboard at the top left to go to the main NCBI screen.
3. Select Manage SciENcv in the SciENcv box at the bottom right to go to the main SciENcv screen.
4. Select Edit My Profile to review and update your profile information.

Creating the USDA Biosketch in SciENcv

1. From the Manage SciENcv page, select + New Document.
2. Enter a document name, then select the document type USDA Biographical Sketch. Choose one of three data sources to start the document:
   • Use an External Source: Link to your ORCID profile to fill in data.
   • Use an existing document in SciENcv: Autofill data from a biosketch you created in SciENcv for another sponsor.
   • Start with a blank document: Enter all data manually.
3. Select the USDA agencies or staff offices you plan to submit to. You can select more than one. When finished, select Create.
4. Enter your data, or update any data imported into the form.
5. Review the certification statement, then select Certify.
6. Select Download PDF.

Creating the USDA Current and Pending (Other) Support in SciENcv

1. From the Manage SciENcv page, select + New Document.
2. Enter a document name, then select the document type USDA Current and Pending (Other) Support. Choose one of three data sources to start the document:
   • Use an External Source: Link to your ORCID profile to fill in data.
   • Use an existing document in SciENcv: Autofill data from a Current and Pending (Other) Support document you created in SciENcv for another sponsor.
   • Start with a blank document: Enter all data manually.
3. Select the USDA agencies or staff offices you plan to submit to. You can select more than one. When finished, select Create.
4. Select Edit to add your identifying information, organization, and location.
5. Select Add Proposals and Active Projects and enter the required information in the pop-up window. See the instructions in SciENcv for more guidance.
6. If you have in-kind contributions to disclose, select Add In-Kind Contribution and enter the information in the pop-up window. See the instructions in SciENcv for more guidance.
7. Review the certification statement, then select Certify.
8. Select Download PDF.

USDA requires that all Covered Individuals complete Research Security Training annually. 

Note: This requirement may already be completed as all Ohio State personnel named on federal award proposals or who are funded by federal grants are required to complete an annual research security training requirement each spring. 

USDA NIFA AFRI F&A Requirements

The 2018 Farm Bill currently governs the Facilities and Administrative (F&A) rates that are allowable on most competitive USDA NIFA awards.

F&A is capped at the lesser of:

1. Ohio State’s federally negotiated indirect cost rate (NICRA); or
2. 30% of Total Federal Funds Awarded (TFFA)
   1. A note on the 30% TFFA calculation:
      1. “TFFA” includes both direct costs and indirect costs combined (Total Budget=Direct Costs + Indirect Costs). When preparing a budget using the 30% TFFA rate, we express our indirect cost rate as a percentage of Total Direct Costs (TDC), so 30% TFFA is equivalent to 42.857% TDC.

When a budget includes subawards, the 30% TFFA cap is cumulative across all budgeted institutions. The total F&A claimed by the prime awardee and all subawardees together cannot exceed 30% of the overall TFFA. Subrecipients are also required to apply the lesser of their negotiated rate or the 30% TFFA on their individual budgets.

Please reach out to your SPO with questions as you prepare a USDA NIFA budget.

USDA NIFA Application Status Dashboard

USDA NIFA recently released the NIFA Application Status Dashboard. This dashboard can be used to check the status of grant applications/proposals submitted to USDA NIFA.

To use the tool, applicants will need to input their Grants.gov tracking number. Your SPO can help find a proposal’s Grants.gov tracking number, if needed.

USDA NIFA Grants Modernization Initiative

As part of NIFA’s Grants Modernization Initiative, a growing number of USDA NIFA programs now manage their grants through eRA, NIFA’s new grants management system. Applications are still submitted through Grants.gov, but there are important steps to take in eRA Commons before you apply:

• Confirm early that the PD/PI and all Senior/Key Personnel (including project partners and collaborators) have active accounts in eRA Commons as these individuals must be listed on the application.
• Contact your Sponsored Program Officer to request an account if you do not already have one.
• OSU is a registered organization in eRA Commons.

Please note: Applications will be rejected if your account is inactive; if your Senior/Key Personnel’s eRA Commons usernames are missing from the application; or if the organization’s UEI doesn’t match the one used to register in eRA Commons.

More information can be found on the USDA NIFA Application Checklist: Preparing and Submitting Your Application in eRA.