It depends on the prime award. If the award is from NIH, we must get permission when adding a foreign subrecipient. Where NIH is the sponsor, we must also get approval for adding any new Fixed Price subagreement, or modifying a Cost Reimbursable Subagreement to a Fixed Price. Other prime awards may or may not require approval. Your Subawards Team member will review the prime award and work with you to make this determination.
In most cases, yes. The payment type of the subaward does not have to match the payment type of the prime award. There may be other sponsor restrictions on issuing a fixed price subaward, however, including prior approval or a dollar threshold. Contact the Subawards Team for more information.
Yes.
You will receive update emails from the Subagreement Checklist System, which will reflect the current status of the modification.
The Subagreement Checklist System will send you automatic emails: when the sub checklist has been assigned; when the subaward is sent to the subrecipient; when JHU receives the partially executed back from the subrecipient; and when the subaward is fully executed and sent back to the site. The Subagreement Checklist System is available to allow departments read-only access to see what stage the subaward is currently in.
You can access the Subagreement Checklist System to check the status. Additionally, you will receive update emails from the Subagreement Checklist System, which will reflect the current status of the aaction, both for new subawards and modification of existing subawards.
The Subagreement Checklist System will send you automatic emails at the following times:
JHURA is responsible for removing the encumbrance from the PO once the end date of the subaward has passed and the final invoice has been submitted and paid. Please send an email to the member of the Subawards team responsible for deobligating the remaining amount on the PO, currently Sydney Slaski.
The Uniform Guidance, 2 CFR Part 200.330 sets forth the criteria to determine whether a collaborator is a subrecipient or a vendor/contractor.
Sponsored project awards made to JHU are generally conducted within the physical boundaries of JHU by University faculty and staff. Occasionally, however, a significant portion of the required work may need to be provided outside the University by a third party. The third party is made responsible for a discrete portion of the project award, providing the leadership and direction of a responsible investigator and the resources necessary to conduct that portion of the work. Costs associated with this work may include personnel costs, supplies, equipment, travel, and overhead. Such an arrangement is carried out through the issuance of a subaward.
Comparatively, a contractor is an entity which performs the service it is offering to JHU to other customers in a commercial market. A contractor generally will not own anything it creates nor will it seek to publish.
Subawards are handled through JHURA; contractor agreements are handled through Purchasing.
If you have any uncertainty on the classification of the collaborator, please be in touch with Subawards team member.
You will need to submit the modification as a NEW SUBAGREEMENT in the Subagreement Checklist System. The prime award will have a new SAP grant number, and therefore the subaward will need to obtain a new PO number. You also will need to set up a shopping cart to obtain a new 96IO number for the new PO number.
Please note in the “Verify and Submit” field of the Checklist that this is for a G to P, so that this action can be clearly identified as a modification even though the checklist says “new.”
Also, please note in the “Verify and Submit” field if there is approved or restricted carry forward into the new PO, so that this can be noted in the action, and note the amount that you anticipate will be in the shopping cart.
For a NEW Subaward, you must enter a record into the Subagreement Checklist System and attach:
The prime award must already be set up in SAP.
We have found that issues around intellectual property ownership and control of publications can be sticking points. See the Contracts Quick Guide for more information about JHU policies regarding these subjects.
Average turnaround times change based on our volume at any given time, but, generally, your new subaward should go out the door to the subrecipient approximately three to four weeks after you submit the request via the Subagreement Checklist System. If the information in the checklist is not correct or is incomplete, however, the turnaround time will increase. Generally your subaward modification turnaround time should be within three weeks.
NSF now allows self-registration for a FastLane account. For a demonstration, please view this Video Tutorial from NSF. Frequently Asked Questions about setting up an account for FastLane are answered Here. If you have any questions, please contact your assigned Grants Associate.
Contact your assigned Grants Associate who can go into eRA Commons and re-set your password for you. A generated email from eRA Commons will be sent to you automatically with a link to create a new password.
It depends. For Federal Agencies, the answer is almost always no unless specifically required in the program announcement. All sponsors asking for a cost share commitment, approval needs to follow your schools cost share approval policy. If you are unclear of your schools policy please contact your JHURA representative.
You can click on the link here to see JHU’s latest Negotiated Indirect Cost Rate Agreement (“NICRA”) which includes the current F&A rates for the University. *Anticipated rates for fiscal years not listed on the rate agreement should not be used for proposal budgeting.
Please see the link to our policy here.
The complete and final proposal, including all the necessary School-level approvals, certifications and representations, as well as any other attachments or approvals required by the sponsor or the University, must be received by JHURA at least three (3) full business days prior to the sponsor’s due date.
See the full policy here.
Alexandra M. Albinak, Associate Vice Provost for Research Administration, and certain delegates within JHURA, have the authority to sign agreements relating to research and related services conducted under JHURA purview, including without limitation: contracts, grants, cooperative agreements, subcontracts and contracts for goods or services that support such research activities at the University.
Eligibility varies by School. Generally speaking, Professor Track faculty, Scientist Track faculty and, in some cases, Research Associate Track faculty can be listed as Principal Investigator (PI) on projects. Post-docs can only be listed as PI on post-doc fellowships. Graduate students cannot be PIs on proposals or awards. Contact your JHURA Associate for more information.
In most cases it can be your JHURA Grants or Contracts Associate. If the authorized official will also be the person responsible for signing the award then you should list:
Alexandra M. Albinak, MBA, JD
Associate Vice Provost for Research Administration
Johns Hopkins University Research Administration (JHURA)
You will need to fill out the eRA Commons Access Request form and submit it to your department’s assigned JHURA Grants Associate.
No. As a policy matter, the University must retain the right to publish its research without the prior approval of the sponsor. However, we may be willing to allow the sponsor 30 –90 days to review any proposed publication to make sure that no confidential information is inadvertently disclosed. In addition, if a student dissertation will be supported by a contractual agreement, no delays on publications supporting the dissertation are permitted without the General Counsel’s Office approval.
Absolutely. JHURA has developed and maintains a library of model agreements that can be adapted to most situations. It is the strong preference of JHURA that these model agreements be utilized whenever possible, in order to minimize negotiation and expedite the review and signature process, reach out to your JHURA representative early in the process.
No. JHURA is the central research administration office at the University and is responsible for the Bloomberg School of Public Health, the Whiting School of Engineering, Jhpiego, the School of Education, the School of Nursing, the Carey Business School, the Peabody Institute, the Paul H. Nitze School of Advanced International Studies (SAIS), and other centers and institutes. Both the School of Medicine and the Krieger School of Arts and Sciences are serviced by their own divisional Offices of Research Administration.
Departmental personnel wishing to ascertain the status of any agreement being processed by JHURA may log into the JHURA Agreement Workflow System (JAWS), which can be found here.
There are a variety of factors that can affect the amount of time it takes to get agreements finalized and signed. These may include, but not be limited to, whether the sponsor has engaged contractually with the University previously; the nature of the sponsor (i.e., University, non-profit corporation, for-profit corporation, foundation, government agency); whether a JHURA model agreement is being utilized; whether JHURA has all information needed to understand the context of the project; the specific terms and conditions at issue; whether additional review is needed by an office other than JHURA (i.e. The Office of General Counsel, the Office of the Provost, The Office of Risk Management, the Institutional Review Board, etc); and whether the delay is on the part of the sponsor. JHURA does maintain an Agreement Review Process timeline that provides the general expected timeframes for reviewing agreements.
No. The Principal Investigator is the University’s Project Director for that contract, but the actual parties to that contract would be the corporate partner and the University. This is true for all sponsor types, not just corporate partners.
Fixed price (FP) agreements have fixed payments based on a milestone payment schedule or the submission of deliverables. Cost reimbursement (CR) agreements are paid as costs are incurred and invoiced, typically monthly or quarterly. One significant difference between fixed price and cost reimbursement agreements is the allocation of risk. With FP agreements, the University assumes greater risk while the sponsor bears the greater risk with CR agreements. FP is appropriate if there can be a clear scope of work, a solid cost estimate, and well-articulated deliverables. These FP agreements, which involve lower administrative burden, are commonly used by for-profit sponsors and foreign entities. CR agreements are used where the work being performed cannot be precisely defined or the cost precisely estimated, which applies to much of the sponsored research projects the University undertakes. CR agreements are commonly used by other educational institutions, hospitals, and non-profits. They allow for greater flexibility, as additional funding or period of performance may be added as mutually agreed upon, and performance of the scope of work continues until funds or period of performance is exhausted.
Each of these functional areas plays an important part in the life cycle of an award. In the pre-award stage, the faculty member has principle responsibility for identifying funding opportunities, with JHURA’s Research Development team providing assistance as to limited submissions. The departmental administrative staff would then work with the faculty member in developing a proposal. Once completed, the departmental staff routes the proposal to JHURA through Coeus for review and approval. When an award is received, JHURA receives, reviews and negotiates (as needed) the award document, and signs on behalf of JHU. Post-award, JHURA routes the fully executed agreement to Sponsored Projects Shared Services (SPSS) for account set-up. During the life of the award, each of JHURA, SPSS and the academic department perform award management functions, such as issuing subawards, invoicing, and submitting required reports to the sponsor, respectively.
JHURA is the central research administration office for the University. It reviews issues in sponsored project agreements, one of which is protecting the University’s intellectual property (IP) rights by including appropriate IP provisions in contracts, grants, and cooperative agreements. Johns Hopkins Technology Ventures (JHTV) is the University’s intellectual property administration center, serving University researchers and inventors as a licensing, patent, and technology commercialization office and acting as a liaison to parties interested in leveraging University research or materials for academic or corporate endeavors.
JHURA facilitates the submission of sponsored project proposals on behalf of JHU by reviewing for compliance with University, sponsor and federal policies and regulations, approves and signs proposals prior to submission, negotiates and executes agreements, provides coordinated advice and guidance regarding applicable rules and regulations, and assists faculty, staff, and students in proper stewardship of the University’s sponsored projects.
JHURA does not handle the procurements of goods and services from vendors, as this is the responsibility of the University’s Supply Chain Shared Service Center. Additionally, philanthropic gifts directed to the University are processed through divisional Offices of Development. Johns Hopkins Technology Ventures (JHTV) handles all Material Transfer Agreements for the University.
Contracts, grants, and cooperative agreements are the three most commonly used instruments through which the University accepts sponsored funding. The purpose of a grant is to provide assistance; there is generally little involvement by the sponsor, and the award instrument refers to general terms and conditions. Cooperative agreements also provide assistance, but with substantial sponsor involvement, typically described in a set of specific terms. The basic purpose of a contract is to procure tangible good and services through an acquisition. The involvement by the sponsor may be extensive and the award instrument will contain detailed specifications, clauses, regulations, and expected results and deliverables.
The authorized signatory for sponsored research agreements (contracts, grants, and cooperative agreements), as well as certain non-sponsored agreements (i.e. data use agreements, teaming agreements, material transfer agreements, nondisclosure agreements, memoranda of understanding) is the Associate Vice Provost for Research Administration (AVPRA), the Executive Director, or those staff members within JHURA to whom the AVPRA has delegated signature authority.
While you may contact any member of JHURA regarding your matter, please know that JHURA is comprised of four primary teams: the Workflow Team, the Proposal Team, the Agreements Team, and the Subawards Team. For the convenience and reference of the University community it services, JHURA maintains a Departmental Assignment list, complete with contact information, which can be found here. As we like to say in JHURA, please get in touch with us as early and as often as possible regarding proposed sponsored research projects.
In some instances, yes. If the U.S. Government believes that a tangible item or information has been exported to another country in violation of U.S. law, then it will investigate to determine how and why the export took place. If it can be shown that you arranged for an unauthorized shipment of an item to another country, then you may be asked to account for your actions. If it is then found that the unauthorized export was unintentional, for instance due to an oversight on your part, or insufficient training or screening practices generally at JHU, then JHU will likely be the only party that will be held accountable and may be subject to a warning or some kind of penalty (e.g., a fine). If, however, it is found that you intentionally shipped an item, knowing that to do so was unauthorized, then you could be incarcerated and/or required to pay criminal fines.
To learn how to develop a comprehensive data management and sharing plan visit…
U.S. export control regulations generally treat Lawful Permanent Residents (people who have “Green Cards”) as though they are American persons. For instance, an Iranian citizen might not be able to access certain devices or technical know-how in one of our labs until she becomes a Lawful Permanent Resident of the United States. The same approach would apply if she were lawfully in the U.S. under special protection, such as is offered to those who are allowed to stay in the U.S. as refugees, or those who have been granted asylum.
Please note that there are instances in which the U.S. Government may take an interest in a Lawful Permanent Resident’s prior citizenships, when more highly restricted goods and information are involved.
Fundamental research is considered to be any basic or applied research in science and engineering with results that are ordinarily published and shared broadly within the scientific community (see National Security Decision Directive 189). For those who need definitions of basic research and applied research, we offer the following (taken from an OMB guidance document)
The application of knowledge acquired through basic or applied research to meet specific requirements, such as for the production of useful materials or the deployment of certain systems or methods is not considered fundamental research.
Additionally, in order to qualify as fundamental research, the activity must be conducted free of certain kinds of publication (or other types of dissemination) or access restrictions.
If you are still uncertain whether your activity is fundamental research, please contact the Export Control Office.
Whether or not U.S. export controls apply to your research or other work at JHU depends upon four, primary factors: 1) the subject matter associated with your work, 2) the foreign countries that are likely to be associated with your work, 3) the foreign entities or individuals with which/whom you expect to share certain items or information; and 4) how you reasonably expect those entities/individuals to use what you share with them.
When you carefully and fully answer the Research Compliance Questions that are asked for each proposal that is submitted through Coeus, the Export Control Office has an opportunity to assess whether your project might involve exchanges with foreign parties that would require export licenses. This, however, is not a foolproof way to filter out restricted subject matter, countries, entities/individuals and end-uses from the thousands of proposals submitted yearly through Coeus. We must depend upon a variety of checks and information sources (not to mention training) to help us identify research projects that are impacted by U.S. export controls.
The FAR Clause may apply to personal devices when those devices are used to a significant extent in the performance of a covered contract. The FAR Clause does not apply when a device is “incidental to” the performance of work on a covered contract.
While the FAR Clause does not define what constitutes “significant” or “incidental” use, using a device to occasionally respond to emails about a covered contract does not trigger the prohibition on TikTok.
No, not necessarily. We are usually able to interact with citizens of sanctioned countries when they are lawfully working or studying with us in the United States, although there might still be certain subject matter that we cannot share with them without a license. There are typically more restrictions upon the interactions that we can have with citizens of sanctioned countries when they are in their home countries. Even so…
Some U.S. sanctions programs are more restrictive than others. Your project may involve a country that is subject to a sanctions program but one that does not restrict the kind of transactions into which you will need to enter with its organizations or people. For instance…
Iran is a comprehensively sanctioned country, and the regulations that embody the Iran sanctions program generally forbid any export/import of goods, services or technical know-how to/from that country. There are a few exceptions to this broadly restrictive policy towards Iran, but it is typically quite difficult (if not impossible) for us to involve Iranian entities and individuals in our research, technical assistance and educational activities, if they are not lawfully in the U.S., or if we are unable to procure a license from the Department of the Treasury’s Office of Foreign Assets Control.
Zimbabwe, on the other hand, is also a sanctioned country, but unlike the Iran sanctions program, the Zimbabwe sanctions program only targets certain entities and individuals and does so in such a limited way as to rarely prevent us from being able to pursue our professional goals in or with Zimbabwean organizations and individuals.
If your research project or other work will involve a sanctioned country, the Export Control Office can help you to determine whether any or all of your proposed activities are forbidden in the absence of a license. If a license is required, we can advise as to whether submitting a license application would be worthwhile, and if it is, we can assist with application drafting and submission.
Remember that it is only the results/findings of fundamental research that are excluded from export controls. It is possible that certain devices, materials or information used in the course of performing fundamental research cannot be shared with foreign persons because they are controlled for export to one or more countries and, in the case of information, it was not the product of fundamental research.
The Export Control Office helps to prevent items and information from going to other countries in violation of U.S. export control and sanction-program regulations. It looks for opportunities to screen items that members of the Hopkins community intend to send outside the U.S. However, it is not responsible for addressing the numerous other issues that you should consider when shipping internationally, including customs (both U.S. and foreign), proper handling and packaging (e.g., hazardous or perishable materials) and insurance. For this reason, we encourage you to visit our international shipping page [link needs to be added], which offers resources that you can use to ensure that your outgoing and incoming international shipments are managed with minimal cost and maximum compliance with the numerous regulations that apply to international shipping.
Federal Acquisition Regulation 52.204-27 (“FAR Clause”), which bans the downloading of TikTok and related apps on certain devices, applies to certain federal contracts. Grants and other non-contract federal awards are not subject to this FAR Clause.
The federal contracts most likely to be subject to the FAR Clause are funded by the Department of Defense and NASA. Other federal funders may require compliance with the FAR Clause on specific contracts, and will notify the university in that case.
The FAR Clause prohibits the use or presence of the TikTop app on information technology (“IT”), including computers and cell phones, used in the performance of a covered contract. The prohibition applies regardless of ownership of the IT, but does not apply to IT that (1) is not used to a “significant extent in” the performance of a covered contract, or (2) is “incidental to” the performance of such a contract.
If you have a question about the applicability of the FAR Clause to a specific contract, please reach out to your grants and contracts associate to discuss further.
Failure to comply with the FAR Clause may result in the loss of the specific contract at issue, debarment from participation in government contract and research programs, and potentially criminal sanctions.
If you have any questions about whether a specific award is subject to the TikTok ban, please contact your grants or contracts associate, JHURA (jhura@jhu.edu) or ORA (ora@jhmi.edu).
Many US funders, both federal and private, now require grantees to provide a data management or sharing plan and to have their data available at the end of funded projects.
U.S. export control regulations forbid us to take or send certain devices, materials (organic or inorganic), or software to certain other countries, unless we have a license to do so. They also forbid us to release technical information about those items to persons who are in certain other countries and to citizens of those countries, when they are working or studying with us in the U.S. The kind of technical information that the regulations are referring to is that which a person would need to develop, produce or understand (very intimately) the devices, materials and software that are restricted for export. Such information is referred to as “technology” in the Dept. of Commerce’s Export Administration Regulations (the “EAR”) and as “technical data” in the Dept. of State’s International Traffic in Arms Regulations (the “ITAR”). The Export Control Office works with academic and administrative units throughout the organization to prevent technology and technical data from being released in violation o
Planning for data sharing during the design phase of a research project can make compliance with these requirements much easier.
Review the below overview designed to inform JHU researchers of the new requirements and things to consider when developing a comprehensive data management and sharing plan. Please note that JHU has an existing policy on data access and retention, as well as rules for the responsible conduct of research., which include requirements for data storage, retention, and ownership.
Individual schools and sponsors may have additional requirements. For more context, read the initial JHU communication on the new data management and sharing policy published on 11/11/22.
These requirements apply to all projects in which data is collected, whether or not the data is derived from human research participants.
U.S. export control regulations forbid us to take or send certain devices, materials (organic or inorganic), or software to certain other countries, unless we have a license to do so. They also forbid us to release technical information about those items to persons who are in certain other countries and to citizens of those countries, when they are working or studying with us in the U.S. The kind of technical information that the regulations are referring to is that which a person would need to develop, produce or understand (very intimately) the devices, materials and software that are restricted for export. Such information is referred to as “technology” in the Dept. of Commerce’s Export Administration Regulations (the “EAR”) and as “technical data” in the Dept. of State’s International Traffic in Arms Regulations (the “ITAR”). The Export Control Office works with academic and administrative units throughout the organization to prevent technology and technical data from being released in violation o
To increase the impact and accelerate the pace of scientific discovery.
A visa issued by the United States Government authorizes an individual to study and/or work at JHU, but it does not confer on them a right to access any technology with which our faculty might be working at any given time. As an entity subject to U.S. export control regulations, JHU is responsible for monitoring the tangible items and information that it shares with foreign persons, including those who have visas authorizing them to study and work with us.
The informational results of research that qualifies as “fundamental research” are generally not subject to export controls. What this means is that a JHU research team could lawfully share with their peers at foreign universities new findings about items described on the Commerce Control List – such as certain harmful viruses or bacteria – if the findings arose while performing fundamental research. If the research was not fundamental, perhaps because JHU agreed to the imposition of publication or access restrictions in connection with the project, then, depending upon the countries involved, a license might be needed to share the discoveries with foreign parties.