Award Acceptance / Award Obligation Set up Process
Once a new award or an award increment comes into Northeastern, NU-RES undertakes an award acceptance process to ensure that all the relevant regulatory and fiduciary obligations met the specifications of the proposal, as well as funding agency expectations. Northeastern calls this the Award Obligation Set up (AOS) Process.
Based on the funding agency requirements, NU-RES will need to verify several key pieces of information:
The NU-RES conflict of interest review is comprised of three parts, which are driven by funding agency conflict of interest requirements and Northeastern policy:
- Investigator Determination Form: Northeastern is required to confirm which individuals engaged in the project are considered “Investigators,” responsible for the design, conduct, or reporting of the research. “Responsible for” is the operative phrase and indicates that the individual exercises control over their activities. For example, a student reporting the research independently would meet the definition of Investigator. However, if the student is working as part of a team supervised by a faculty member, they would not meet the definition of Investigator.
- Verification of outside activities disclosure: NU-RES must verify that Northeastern has an outside activities disclosure on file for each Investigator.
- Training: This requirement only applies to awards funded by a Public Health Services (PHS) federal agency or other funding agencies that adhere to the PHS Financial Conflict of Interest (FCOI) guidelines (including subawards). Investigators participating in research under a project subject to the PHS FCOI regulations are required to complete the CITI FCOI training module. NU-RES completes compliance checks of all awards to ensure CITI training is complete and up-to-date. If an Investigator does not have a current CITI training completed at the time a notice of award is received, they will have to complete the training, and email NU-RES@northeastern.edu upon completion to ensure timely processing of the award obligation.
NU-RES requires confirmation that all institutional approvals associated with the project have been obtained. Please provide NU-RES with any approval letters related to the award, especially those related to:
- IACUC: Please see the DLAM website to submit a request for an IACUC approval.
- IBC: Please see the IBC website to apply for an IBC registration.
- IRB: Please see the HSRP website to request a Human Subjects Determination review and/or submit a request for an IRB approval.
- UAS: Please see the UAS Committee website to submit a request for an UAS approval.
If a grant or contract is associated with multiple organizations (orgs) or departments, each org / department should have their own index. The college(s) should provide the credit split and budget breakdowns to NU-RES at the time of award set up. NU-RES recommends that the college review the organizations (orgs) and credit splits associated with each research project on an annual basis (at minimum). Any faculty members that have left Northeastern or ceased working on the project should have their credits re-assigned to someone else in the org/department/college, as appropriate.
If a faculty member has left Northeastern, but is still working on the project, NU-RES recommends that they be removed from the credit split. Their participation and effort will be captured via any subaward or consulting agreement that may be issued to them.
Should the college(s) need to amend a credit split or org/department, please complete a Transaction Form and have it approved by any impacted department chairs and PIs. In the event that the signature of multiple PIs and/or chairs is required, please be advised that the Transaction Form does not have additional signature blocks, thus an email approval from the relevant department chairs and PIs are sufficient.
Completed Transaction Forms should be routed to firstname.lastname@example.org. NU-RES will update the database, typically within 10 business days.
Once all documents have been verified an AOS sheet will be prepared summarizing the award and a final award package will be compiled. The PI and their designated administrators will receive the final award package upon completion of the AOS review.
Please note that the specific award obligation components listed above are the most common elements of the AOS review. Specific grants or contracts may include additional requirements, not listed above. In such cases, NU-RES will work with PIs on a case-by-case basis to identify and verify any award-specific requirements.