Designating Proprietary Information in Federal Grant Applications

In general, disclosing proprietary information in a grant application should occur only when needed to present information that is critical to the review of the grant proposal.   If a proposal is funded, most grant-related information in the proposal is considered public information and may be made public, so if  proprietary information is included it is important to indicate it appropriately on the forms pages and in the body of the application or cover page.   Doing so ensures that the federal agency will only use the information for the evaluation of the application, and aids in the identification of what may be exempt from disclosure to the public.     

Funding agencies may have a required question or field on their standard forms to capture whether proprietary information is included.  An affirmative to the question indicates that patentable ideas, trade secrets, or privileged information is included.  Consulting the agency specific grant application guidelines will advise on how to identify such information in the body of the application materials.

For example, the National Science Foundation (NSF) requires the “Proprietary or Privileged Information” box on the Cover Sheet to be marked, in addition to clearly marking the information in the proposal with an appropriate label or legend.  [NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1]   

Similarly, to identify proprietary information on a National Institutes of Health (NIH) grant proposal, check “Yes” to Question 3 on the “Other Project Information” page on the application forms pages, and clearly mark each line or paragraph containing the proprietary information.

[General Instructions for NIH and Other PHS Agencies (Section G. 220)]

Other federal agencies may have similar application requirements, please read your grant solicitation or guidelines carefully.

Federal Demonstration Partnership September 2019 Meeting Updates

The University of Missouri-Columbia is a member of the Federal Demonstration Partnership (FDP). FDP is an association of federal agencies, academic and nonprofit research institutions, and research policy organizations that work together to streamline the administration of federally sponsored research. FDP meets three times a year in which faculty and administrators talk face-to-face with decision-makers from agencies that sponsor and regulate research. Member institutions have an administrative representative and a faculty representative. MU’s representatives are Jeremy Cox, OSPA (Administrative Representative) and Sara Gable, Office of Research Faculty Fellow (Faculty Representative).

Presentation slides from the September 2019 meeting can be found here, including the Federal Agency Updates, linked below.

One item of interest from NSF is that their annual update to the Proposal & Award Policy & Procedures Guide (PAPPG) will be delayed.  In a typical year,  the PAPPG is posted in October, with a January implementation date.  Due to comments received in response to the draft PAPPG, many related to coverage on Current and Pending Support, the actual dates of posting & implementation remain TBD.  OSPA will keep the Grants community apprised of the status of this important guide.

Another hot topic discussed, and can be found in the presentation slides, is Foreign Influence, what various Institutions are doing to stay compliant, and what our federal FDP partners are doing to address this topic.  Here at Mizzou, this website has been dedicated, containing a plethora of information useful to the grant community, including best practices to follow, FAQ’s, and who to contact for questions.

• NIH Update
• NSF Update
• OSTP Update
• AFOSR Update
• USDA Update
• EPA Update
• GUIRR Update
• Grants.gov Update

Staff Spotlight - New Post-Award Analysts

Post-Award Analysts Cathrine Rivas [Left], Marissa Stealey [Right]

We are happy to introduce two of our new Post-Award Analysts that joined the OSPA team over the summer. A graduate of Saint Louis University, Marissa Stealey worked at a small accounting firm in Fenton, MO prior to coming to MU. She moved to Columbia when her husband was accepted into the medical school, and she says that she really enjoys the culture of staff development at OSPA. In her free time, she enjoys playing sand volleyball at the Deuce and spending time with her dog on the city’s beautiful MKT Trail.

Cathrine Rivas has traveled around quite a bit as a military spouse, but she has found a welcome home at OSPA. She says the work environment has been a breath of fresh air compared to past jobs, and everyone has been eager to support her as she learns the ropes. As an added bonus, it has been great working within a university research office, Cathrine says, because she gets to see firsthand the research being done on creating a more sustainable and eco-conscious society, such as the much-anticipated Missouri Hyperloop. When she is not busy being a mom to three kids, she tries to get outside and garden, hike, or play sports.

MU Grants & Contracts at NCURA 61

In August, staff members from OSPA and MU-Extension attended the 61st Annual Meeting of the National Council of University Research Administrators, held in Washington, D.C. The four-day conference included educational sessions on a variety of research administration topics, including updates from major federal sponsors, as well as a variety of networking opportunities that helped connect people who face the same daily challenges from across the nation and even the world.

The conference was abuzz with the challenges of working in a global research atmosphere. Institutions have been strongly urged by a number of federal sponsors to ensure that all foreign collaborations are properly disclosed, and many of these sponsors are working to issue formal guidance and best practices to assist. A number of sessions highlighted the importance of data security in a day and age when it can be commonplace for researchers to present their research at international conferences, bringing along with them laptops, tablets, and other electronic devices with the potential to be hacked by sophisticated foreign parties. At the same time, everyone in the MU delegation found that interacting with and hearing from the diverse attendees at the conference enriched their experience. The conference included many global participants who gave insight on issues like how to work with international sponsors and the problems that Brexit is causing for university research in the U.K.

There were also a number of helpful updates from major federal sponsors. The National Science Foundation (NSF) reminds investigators and research administrators that conference proposals must include codes of conduct with clear means of reporting violations of the policy before and during the conference. Our university’s Sponsored Programs Procedure Guide that covers this topic can be found here. In addition, unless otherwise stated in the guidelines, conference costs should not be listed as participant support, but rather under other direct costs in grant budgets.

Investigators and staff should become more familiar with online tools and portals like Research.gov, SciENcv, and ORCID IDs. While there is no firm date on when FastLane will be phased out, current solicitations that allow for submission through Research.gov should be done through that portal. Similarly, NSF encourages investigators to begin using the SciENcv template for biographical information on all proposals, even if it is not yet required.

On the other hand, many NIH award categories are now requiring ORCID IDs for awards received on or after 01/25/2020. Also from the NIH: the sponsor is working to expand request options for their automated “Prior Approval” process in eRA Commons. This would supplement their successful approach to approvals for No Cost Extension Requests and Change of PD/PI.

The keynote address at the conference was delivered by Freeman A. Hrabowski, III, President of University of Maryland, Baltimore County. Dr. Hrabowski, who in 2012 was selected to chair President Obama’s Advisory Commission on Educational Excellence for African Americans, spoke of the many challenges faced by minorities in university education and research. Growing up in Birmingham, Alabama in the 1950s and 60s, he saw hatred and racism everyday, and he pointed out how far our nation has come since then. But he challenged conference attendees to see the work done at UMBC over the years as an example of how integrating a commitment to diversity and inclusion can actually drive research forward. He left attendees with the following observation: "Your thoughts, become your words, your words become actions, your actions become habits, these habits build your character, and your character leads you to your destiny."