**Revised Guidance** NIH Training Grant Applications – Institutional Commitment Letter Regarding Harassment and Discrimination Protections

Dear Colleagues:

NIH has recently issued a new notice of clarification (NOT-OD-19-056) regarding the Institutional Commitment Letter required for Training (T) grant applications for due dates on or after 1/25/19. 

With this new clarification, here’s our revised guidance:

A separate letter is no longer needed. Thus, the letter that we disseminated from UCOP below should not be used. However, as part of the Letter of Support or Institutional Commitment Letter that is usually signed by the Dean and/or Chair we need to include a description of the institutional commitment to the following areas:  

(i)    ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices; 

(ii)   responding appropriately to allegations of discriminatory practices, including any required notifications to OCR (see NOT-OD-15-152); and

(iii)  adopting and following institutional procedure for requesting NIH prior approval of a change in the status of the Program Director/Principal Investigator (PD/PI) or other senior/key personnel if administrative or disciplinary action is taken that impacts the ability of the PD/PI or other key personnel to continue his/her role on the NIH award described in the training grant application (also see NOT-OD-18-172 re policy on change in PD/PI status).

In order to comply with these requirements, please include the text below from the UCOP letter in the Letter of Support or Institutional Support letter:

“This letter confirms the commitment of the University of California to ensure that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices.  The University has on file with the HHS Office for Civil Rights (OCR) Form HHS-690, a one-time Assurance of Compliance (https://www.ucop.edu/research-policy-analysis-coordination/_files/assurances.pdf). This assurance is also affirmed by Authorized Organization Representatives (AOR) submitting grant proposals to NIH. Systemwide Employee Relations in Office of the President (https://www.ucop.edu/human-resources/staff/employee-relations-staff/eeo-affwmative-action.html) supports systemwide compliance with federal requirements for the provision of equal opportunity and affirmative action as it relates to race, color, creed, religion, national origin, citizenship, sex, age, marital status, sexual orientation, gender identity or expression, disability, or status as a disabled veteran or Vietnam-era veteran, or other protected veterans. In addition, each UC location employs Equal Employment Opportunity/Affirmative Action Diversity Administrators (https://ucnet.universityofcalifornia.edu/contacts/eeo-aa-da-contact-list.html) to ensure University compliance with its obligations under federal statutes and regulations.

 

A systemwide Title IX office provides direction and support for Title IX offices at the ten UC campuses, the Lawrence Berkeley National Laboratory (LBNL), and the UC Office of the President. This office assists in implementing systemwide initiatives and best practices in harassment prevention and response. It also provides investigative support and development, and delivery of education and training to Title IX offices and other university partners involved in preventing and responding to sexual harassment and sexual violence. Each UC campus and location also has a Title IX officer who oversees compliance with the UC Policy on Sexual Violence and Sexual Harassment and other Title IX-related policies. UC’s Sexual Violence Prevention and Response website (http://sexualviolence.universityofcalifornia.edu/) provides important guidance, including how to file a report of complaint, and each campus and location has a website.

 

University of California AORs have formal delegations of authority to solicit, negotiate, and/or accept extramural awards. As a condition of this delegated authority, and in accordance with NIH policy, AORs follow institutional procedures for requesting prior approval from NIH (or any agency) for a change in the status of the Program Director/Principal Investigator (PD/PI) or other senior/key personnel when such a change would affect the P1’s ability to conduct the work; this includes administrative or disciplinary actions. Additionally, Sponsored Projects Offices provide training and guidance to Pl/PDs and to school and departmental administrators to ensure that they are aware of sponsor policies and expectations, as well as the University’s obligations. Sponsored Projects Offices communicate changes and updates to extramural policies and procedures to the research community.”

Please contact your federal officer if you have any questions regarding this requirement. 

Thank you,

Paul

Paul Lekutai

Interim Assistant Director

Sponsored Projects Administration

University of California, Irvine

141 Innovation, Suite 250

Irvine, CA 92697-7600

plekutai@uci.edu

949-824-4781

cid:<a href=ED4554CB-4A52-4AD8-996F-2AEAF872AF9E@rgs.uci.edu”>

http://www.research.uci.edu/

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From: CG-News [mailto:cg-news-bounces@maillists.uci.edu] On Behalf Of Contract and Grant News
Sent: Thursday, December 20, 2018 11:22 AM
To: cg-news@uci.edu
Subject: [Contract and Grant News] NIH Training Grant Applications – Institutional Commitment Letter Regarding Harassment and Discrimination Protections

Dear Colleagues:

On November 7, 2018, NIH issued NOT-OD-19-029, Harassment and Discrimination Protections in NIH Training Grant Applications, that requires applicants to submit a letter signed by a key institutional leader that describes the institution’s commitment to ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and practices in all institutional training grant applications (T series). This requirement is applicable to applications submitted to NIH on or after January 25, 2019.

The Research Policy Analysis and Coordination office at UCOP secured a letter from UC Provost Michael Brown for our use in meeting this requirement. The letter is posted here: https://www.ucop.edu/research-policy-analysis-coordination/_files/nih-training-provost-letter.pdf

Please include this letter in all institutional training grant applications to NIH in accordance with the instructions in the funding opportunity announcement.

If you should have any question regarding this requirement, please contact your Contract and Grant Officer.

Nancy

Nancy Lewis

Executive Director, Sponsored Projects

 

Sponsored Projects Administration

UCI Office of Research

141 Innovation, Suite 250

Irvine, CA  92697-7600

PH:  (949) 824-2897

Fax: (949) 824-2094

E-mail:

http://www.research.uci.edu/

Please contact OR Operations @ (949) 824-7295 or to coordinate meeting requests.

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The Office of Research will be closed for the UCI winter administrative recess from December 24, 2018 through January 1, 2019.  For guidance regarding funding opportunities with submission deadlines during the break, contact your Contract and Grant Officer.

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