Approximately eighty percent of all sponsored research funding at Harvard is provided by federal agencies, primarily NIH and other DHHS offices, NSF, Department of Defense, Department of Energy, and NASA (exact sponsored research figures may be found in the Harvard Fact Book). When awards are made, they are accompanied by requirements that are based on federal statutes, regulations, and Office of Management and Budget (OMB) Circulars.
These requirements apply to the University, called the “recipient,” the Principal Investigator or other individual on whose behalf the University receives the award, and other members of a research team working on a project that is supported by the award. When a federal sponsor makes an award, the University and the sponsor enter into an agreement that includes terms and conditions.
Among the terms and conditions are numerous representations that the University makes promising compliance with federal requirements. These requirements concern nondiscrimination, confidentiality of protected health information, protection of human research subjects and animals, and numerous other concerns arising out of federal statutes and regulations. While the University, as “recipient,” is the party to the contract with the federal agency, almost all the requirements are commitments that obligate the Principal Investigator and the research team.
Although there have been efforts to standardize the terms and conditions, the range of obligations that attach to a particular federal award still varies. For example, individual agencies may add or modify requirements. An NSF site collects the standard terms and conditions, and lists links to agency sites where their specific requirements can be found.
Before an award is finalized, principal investigators need to familiarize themselves with the assurances and obligations that they must satisfy by reviewing their award and asking Office of Sponsored Programs (OSP) staff or research administrators in their departments if any of the terms are unclear. During the negotiation stage, OSP has the opportunity to raise issues with the awarding agency, though the range of revisions that the agency will accept may be limited.