We’re having a discussion with our compliance unit about processing awards and subs when the animal or human subject approvals might be incomplete.  We never process the the prime award if our PI doesn’t have his appovals in place, but we are running into more unusual situations and are trying to nail down the best approach.  I’m seeking out information on how other institutions handle these situations.

 

If you receive an award as a lead institution and the Lead PI is NOT using animals/humans, but the the subawardee is and you don’t have their protocol approvals, do you release the award to your PI?

 

How does your institution manage compliance approvals for subawardee institutions?  Do you issue the sub, but hold up its execution until the subawardee submits their approvals?  What if the subawardee isn’t using animals/humans until future years of the project? 

 

Do you actually obtain the hard copy approvals or is the subawardee’s execution of the sub which includes compliance regs and language sufficient?  If you collect hard copies from the subawardee, who is responsible for obtaining the approvals, your grants office or the compliance office?

 

Thank you in advance for your feedback on this matter.

 

Maryellen O'Brien

Assistant Director

Office of Research and

  Sponsored Programs

Rutgers, The State University

ASB III, 3 Rutgers Plaza

New Brunswick, NJ  08901

 

Voice:  732-932-0150 x2111

Fax:     732-932-0162
email:  xxxxxx@orsp.rutgers.edu

web:   http://orsp.rutgers.edu