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FAQ

Subrecipients

How will SFI disclosures be handled for projects which have “consultants” who are not Ůfaculty members? Does the PI need to obtain a temporary ŮNetID for training and disclosures?

Most likely, consultants will not be considered investigators and will therefore not be affected.  If consultants, who are not Ůemployees, are investigators on a Ůproject, they will likely be contracted through their academic institution, rather than personally. The subawardee, whether through purchasing or a subcontract, will be required to have a compliant policy in order to get federal funding. To meet the mandatory training requirement, an investigator who is not Ůpersonnel could take our training, via a .

Are investigators responsible for reporting the SFI of subcontractors?

In general, no.  Subrecipient institutions that meet the compliance requirements of the regulations will have their own reporting process; however, the subrecipient will need to provide the Ůwith the appropriate assurances as part of the subaward agreement. In the rare case where the Ůmight decide to manage a subrecipient’s SFI disclosures, the Ůwould be responsible for reporting the subrecipient’s disclosures to the sponsor.