Reporting Requirements Matrix by Agency/Entity
It should be assumed that reporting requirements apply when our sponsor is a pass-through entity (PTE) and prime funding is coming from any of the sources above.
In general, reporting related to harassment must be completed within several business days following any administrative actions, the start of an investigation, and/or a finding. On behalf of the University, the Director of the Office of Sponsored Projects, as the Authorized Organizational Representative (AOR), is responsible for reporting directly to sponsors. OSP coordinates with appropriate entities such as the Office of Equal Opportunity (OEO/AA), the Office of Research Integrity and Compliance (ORIC), the Office of General Cousel (OGC), and the department, when a respondent is involved in research.
Although the definitions and processes are similar, the specific timing and requirements
differ between each agency. Additional requirements may be in place if UU personnel
go to a federal government facility.1
1 The National Oceanic and Atmospheric Administration (NOAA) Sexual Assault and Sexual Harassment Prevention and Response Policy is applicable to financial awards involving NOAA-operated facilities. Other agencies
may have similar policies.
| Key Items | NSF | NIH | NASA | Simons Foundation | Howard Hughes Medical Institute | Research Corporation for Science Advancement |
| Roles reporting requirements apply to | PIs and Co-PIs | PD/PI and other named senior/key personnel | PIs and Co-PIs | PIs and all other members of the research team | All personnel or participants in grant-funded programs, attendees at HHMI events, or indivduals performing work on behalf of HHMI. | PIs and Co-PIs |
| What must be reported | Any findings/determinations of sexual harassment, other forms of harassment, or sexual assault regarding an NSF funded Principal Investigator (PI) or co-PI, or of the placement of the PI or co-PI on administrative leave, or the imposition of any administrative action relating to harassment or sexual assault finding or investigation | NIH must be notified when individuals identified as PD/PI or other Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined by the recipient institution due to concerns about harassment, bullying, retaliation or hostile working conditions; Changes in a principal investigator or other senior key person's status during an investigation of alleged sexual misconduct; If it is determined that the concerns shared with NIH will impact the PD/PI or senior key personnel's ability to continue as the scientific lead of the project, NIH will require prior approval for a replacement PD/PI or senior key official | Any findings/determinations of sexual harassment, other forms of harassment, or sexual assault regarding a NASA funded PI or Co-I; if the PI or Co-I is placed on administrative leave or if the recipient has imposed any administrative action on the PI or Co-I, or any determination or an investigation of an alleged violation of the recipient's policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault | Any Determination or Administrative Action involving Personnel relating to Prohibited Conduct; includes violation of University policy and professional codes of conduct. | HHMI must be notified of the initiation of a formal investigation of misconduct relating to violations of law or institution policy regarding harassment, discrimination, retaliation, or sexual misconduct. After the investigation has concluded, the findings of the investigation must be reported. | Institution determination that a PI or Co-PI has violated the Institution’s policies or any applicable laws regarding sexual harassment, other forms of harassment, or sexual assault under the Institution’s financial or workplace conduct policies (e.g., harassment). |
| Awards subject to the requirements | After October 22, 2018, new awards and funding amendments to existing awards are subject to the new notification requirement | For awards (competing, non-competing and supplements) issued after June 11, 2020, prior approval requests for change in PI or Senior/Key Personnel named in the NoA, or changes in recipient institution must disclose whether these requests are related to concerns about safety and/or work environment (e.g., due to concerns about harassment, bullying, retaliation, or hostile working conditions) | After 4/9/2020, all new NASA awards and funding amendments to existing awards made on or after the effective date will be subject to the new term and condition | All awards | All grant-funded programs. | Awards issued 2/1/23 and going forward. |
| Timeframe for submitting reports to agency | Within ten business days from the date of the finding/determination, or the date of the placement of a PI or co-PI by the awardee on administrative leave or the imposition of an administrative action, whichever is sooner | Notification must be provided by the Authorized Organization Representative within 30 days of the removal or disciplinary action; The request for prior approval must be submitted promptly, and NIH must be proactively notified of any change of status of the PI or senior key person. | Within ten business days from the date of the finding/determination, or the date of the placement of a PI or Co-I by the recipient on administrative leave or the imposition of an administrative action | Within ten business days of any determination or administrative action involving personnel related to prohibited conduct, except as prohibited by law | Notification must be made within five business days of the initiation of the investigation. Findings must be reported within five business days after the investigation has concluded. | Promptly upon determination of violation. |
| Methods of submitting reports | Notification must be submitted by the Director of the Office of Sponsored Projects via the NSF's Organizational Notification of Harassment Form | Notification must be submitted by the Director of the Office of Sponsored Projects
via the Grantee harassment webform https://public.era.nih.gov/ shape/public/notificationForm.era. Contact the NIH grants management specialist of the awarding NIH Institute or Center. In cases of sexual harassment, please also copy GranteeHarassment@od.nih.gov. |
Reports must be submitted by the Director of the Office of Sponsored Projects to NASA's Office of Diversity and Equal Opportunity. More information on how to submit a report is available at https://missionstem.nasa.gov/filing-a-complaint.html | The Notice should be submitted by the Director of the Office of Sponsored Projects through the Simons Foundation’s secure portal: https://www.simonsfoundation.org/funding-opportunities/policies-and-procedures/institution-notification-form/ | Notification and reports should be submitted by the Director of the Office of Sponsored Projects to the Vice President for Science Education or an Institute designee. | Notice should be submitted by the Director of the Office of Sponsored Projects. See RCSA contact in applicable Notice of Award. |
| Reporting requirements for subrecipients | If a co-PI is affiliated with a subawardee organization, the Authorized Organizational Representative of the subawardee must provide the requisite information directly to NSF | Not differentially identified | If a co-I is affiliated with a subrecipient organization, the AOR of the subrecipient must provide the requisite information directly to NASA and to the recipient | Not differentially identified | The grantee institution must provide notification of a Partner Institution's initiation of an investigation of alleged misconduct and the findings of the Partner Institution's investigation using the same timeline specified above. | Not differentially identified |
| Additional requirements for conference grants |
For any grant that provides support for an NSF-sponsored conference, the grantee is required to have a policy or code-of-conduct that addresses sexual harassment, other forms of harassment, and sexual assault, and that includes clear and accessible means of reporting violations of the policy or code-of-conduct. The policy or code-of-conduct must be disseminated to conference participants prior to attendance at the conference as well as made available at the conference itself. For more information, see OSP's NSF Supported Conferences, Workshops, and Symposia guidance. |
Effective for R13/U13 applications submitted for the April 12, 2022 application due date and thereafter, all applicants recommended for funding must provide to NIH as part of Just-In-Time materials:
For more information, see OSP's NIH Supported Conferences and Meetings Safety Plans. |
Not differentially identified | Not differentially identified | Not differentially identified | Not differentially identified |