Chapter 1 - General Information

Sponsored projects are research, instructional, or public service activities that align with the mission of the University and funded by external entities. Sponsors may include federal government agencies, pass-through entities, nonprofit organizations, foundations, and for-profit businesses. The award terms and conditions of a sponsored project are legally binding, and the University is obligated to comply with all sponsor requirements. Although awards are made to the University, the Principal Investigator (PI) named in the award is responsible for the successful execution of the project and for managing all funds in accordance with sponsor guidelines.

The Constitution of the State of Colorado establishes the University of Colorado. The University of Colorado is governed by an elected Board of Regents, which is responsible for the supervision of the university system. The Regents also appoint the President of the University, who oversees the central administrative office.

 The University of Colorado comprises four campuses:

• CU Anschutz Medical Campus
• CU Boulder
• CU Colorado Springs
• CU Denver

CU Anschutz Medical Campus and CU Denver operate as a consolidated campus, with specific central administrative offices serving both locations.

When managing and administering sponsored projects, employees must comply with all University policies and procedures, sponsor requirements, and applicable federal and state laws.

The policy framework at the University of Colorado includes:

• Administrative Policy Statements (APS) applicable to all campuses and employees within the University system
• PSC Travel Statement and Procurement Rules
• Campus Policies and Guidelines applicable to CU Anschutz Medical Campus and CU Denver
• Administrative Unit policies and procedures applicable to employees within a specific administrative unit

The award terms and conditions for a sponsored project outline both general sponsor requirements and specific award provisions. It is the responsibility of the PI and all employees working on a sponsored project to ensure compliance with all applicable sponsor requirements.

For federal awards—whether made directly by a federal agency or indirectly through a pass-through entity—sponsor requirements typically include:

• Award terms and conditions, which incorporate the proposal and the funding opportunity announcement
• Sponsor guidelines and regulations

Most federal grant awards are governed by 2 CFR 200 (Uniform Guidance), or by an agency-specific implementation of 2 CFR 200, as indicated in the award’s terms and conditions. Some agencies have adopted additional guidance that supersedes 2 CFR 200 or the implementation by their parent department.

Example of agency-specific guidance documents include:

• NIH awards must comply with the NIH Grants Policy Statement (NIH GPS) and all Notice of NIH Policy Changes
• NSF award must comply with the NSF Proposal & Award Policies & Procedures Guide (PAPPG).
• The Department of Defense (DOD) Research and Development (R&D) General Terms and Conditions apply to most DOD awards

These agency-specific documents may, in turn, be superseded by program-specific or award-specific terms and conditions. It is always the responsibility of the PI and their administrative unit to ensure full compliance with all award terms and sponsor requirements.

For non-federal awards, applicable requirements are outlined in the award terms and conditions and in any guidance documents provided by the sponsor. As with federal awards, it is the responsibility of the PI and their administrative unit to comply with all sponsor policies and requirements.

The management and administration of sponsored projects at the University are shared responsibilities between the Office of Grants and Contracts (OGC) and the PI and their respective administrative units. Additional University offices also support the fiscal and regulatory compliance of sponsored projects and provide services to facilitate project activities.

 All University employees must comply with the University of Colorado’s Fiscal Roles and Responsibilities policy. This policy defines the fiscal duties of University employees and applies to all University funds, including those associated with sponsored projects.

1.5.1 Principal Investigators (PI)

The lead University employee on each sponsored project is known as the Principal Investigator (PI) or Program Director, as designated in the award notice. The PI and their respective administrative unit (i.e., a school, department, division, center, institutional section, or large program) are responsible for the day-to-day management of sponsored projects. The PI holds ultimate responsibility for the oversight of all programmatic and financial aspects of the sponsored projects under their name. PI designees and administrative staff assist with managing the work and project funds, but the PI retains accountability.

 PIs are responsible for:

1. Developing and submitting proposals in accordance with sponsor requirements, University policies, and the Sponsored Project Handbook;
2. Ensuring compliance with award terms and conditions, applicable federal laws and regulations, University policies, and the Sponsored Project Handbook;
3. Verifying that the award has been correctly set up in the financial system;
4. Managing the financial aspects of the award and complying with all applicable sponsor requirements, University financial policies, and the Sponsored Project Handbook;
5. Monitoring subrecipients and documenting monitoring activities in accordance with sponsor requirements, University policies, and the Sponsored Project Handbook; and
6. Successfully completing all programmatic tasks identified in the sponsored project’s scope of work.

PI Eligibility

Each school or college within the University is responsible for establishing its own requirements for PI eligibility. Information regarding proposal development for prospective University employees is available on the OGC website.

Proposal Development

PIs, their designees, and administrative units are responsible for preparing applications and proposals to sponsors and obtaining all necessary assurances and internal approvals for University submission in accordance with the Sponsored Project Handbook.

Administrative, Programmatic, and Financial Management of a Sponsored Project

PIs, their designees, and administrative units are responsible for ensuring compliance with all administrative, programmatic, and financial requirements for each sponsored project, in accordance with sponsor requirements, University policies, and the Sponsored Project Handbook.  This includes, but is not limited to:

• Financial Management, including:
  • Cost Share and matching requirements
  • Effort allocation
  • Program Income
  • Charging costs to the award
  • Accounting and financial reconciliation
  • Cash management
  • Rebudgeting
  • Cost Transfers
• Completing all programmatic aspects of the project, including adherence to the scope of work and compliance with sponsor requirements for revising the scope of work
• Property Management
• Procurement of goods and services
• Meeting all reporting requirements
• Subrecipient monitoring and management
• Record Retention
• Award closeout and post-closeout responsibilities

Enforcement

PIs who consistently fail to meet the responsibilities outlined in University policy or the Sponsored Project Handbook—as determined by the Office of Grants and Contracts—may be subject to University sanctions. These may include, but are not limited to, loss of privileges to apply for external funding, as outlined in the Handbook.

1.5.2 Role of the Research Administrator

Administrative units employ research administrators to assist PIs throughout the award lifecycle. Research administrators provide support and guidance to reduce the administrative burden on PIs. While research administrators play a key support role, ultimate responsibility for all aspects of a sponsored project rests with the PI.

The specific duties of research administrators may vary among administrative units. In general, research administrators assist PIs with:

• Developing and submitting proposals
• Responding to sponsor inquiries
• Verifying that sponsored projects are correctly set up in the financial system
• Managing administrative and reporting requirements for sponsored projects
• Effort reporting and the use of the electronic Personnel Effort Reporting (ePER) system
• Supporting financial management activities
• Assisting with compliance across all aspects of the project

1.5.3 Office of Grants and Contracts (OGC)

OGC is responsible for the following functions related to the administration of sponsored projects:

• Reviewing applications and proposals and providing institutional approval
• Reviewing award documents
• Negotiating award terms and conditions with sponsors
• Executing award agreements with sponsors on behalf of the University
• Serving as the primary administrative contact for all sponsors
• Acting as the University’s Authorized Organization Representative (AOR)
• Assisting with the transfer of PI awards from other institutions
• Maintaining administrative and costing information necessary for the proper preparation of applications and proposals for external funding
• Establishing sponsored projects in the financial system
• Drafting and negotiating subagreements
• Coordinating all audit matters related to sponsored projects
• Preparing and submitting financial reports to sponsors
• Managing billing and collection activities (unless designated to administrative units)
• Ensuring administrative unit compliance with sponsor award terms and conditions, as well as University policies and procedures
• Providing assistance to PIs and administrative units in accordance with University policy and the Sponsored Project Handbook.

The following table identifies some of the commonly used OGC email accounts:

1.5.4 OGC Resources

The OGC website offers a wide range of resources for University employees managing sponsored projects. These resources include:

• Award Lifecycle – Offers links and guidance documents for specific actions throughout the grant lifecycle
• A to Z Resources – Provides an alphabetical listing of guidance documents and forms
• Forms Library – Provides links to required forms for completing specific sponsored project actions
• Frequently Asked Questions (FAQs) – Provides answers to common questions about sponsored projects
• Grants and Contracts Updates Mailing List – Allows users to register for the monthly OGC newsletter
• New and Team Talks – Contains an archive of past OGC newsletters and Team Talk presentations

1.5.5 Other University Offices

Additional University offices are responsible for fiscal and regulatory compliance of sponsored projects and for providing support services for sponsored projects and other University activities. These offices include:

• Advancement offices - Accept gifts and ensure compliance with gift requirements
  • Office of Advancement for CU Anschutz Medical Campus
  • Office of Advancement for CU Denver
• Clinical Research Administration Office (CRAO)  – Responsible for reviewing agreements related to human subject research, including industry clinical trial agreements, non-disclosure agreements and confidentiality agreements, material transfer agreements, and data use agreements
• CU Foundation – Responsible for receiving gift funds
• Finance Office – Manages equipment disposal for exempt property associated with sponsored projects
• Fiscal Compliance – Responsible for:
  • Assisting with the interpretation of policies and regulations
  • Providing sponsored project training
  • Approving gift card use
  • Serving as an audit liaison
  • Managing leasing agreements
  • Monitoring high-risk financial areas
• Legal Counsel – Protects and defends the University’s legal interests; may assist PIs with due process for award terminations and provide guidance on FOIA requests
• Office of Laboratory Animal Resources (OLAR) – Manages and ensures the care of animal research subjects
• Office of Regulatory Compliance – Oversees:
  • Environmental health and safety
  • Human subject research
  • Colorado Multiple Institutional Review Board (COMIRB)
  • Conflict of interest reporting
  • Export control compliance
  • HIPAA compliance
  • Research integrity
• Offices of Research Committee Support – Provides administrative support for:
  • Institutional Biosafety Committee (IBC)
  • Institutional Animal Care and Use Committee (IACUC)
  • Radioactive Drug Research Committee (RDRC)
  • Committee on Ionizing Radiation (CIR)
  • Committee on Ionizing Radiation for Human Use (HUCIR)
• Office of Research Development and Strategy (ORDS) – Assists CU Anschutz Medical Campus faculty in finding funding opportunities and building collaborations. ORDS is also responsible for overseeing limited submission opportunities and managing internal funding programs for both campuses.
• Office of Research Services – Supports faculty development and CU Denver’s research efforts, including training programs for PIs through the Faculty Grants Academy
• Office of University Controller – Establishes financial practices and policies for the University
• Procurement Services Center – Develops and administers the University’s procurement and travel policies
• Research Informatic Office – Supports data-related needs, including ORCID integration and data management plans
• Technology Transfer Offices –Assists PIs in commercializing technology, developing ventures, and building business partnerships.
  • CU Innovations supports the CU Anschutz Medical Campus and provides support for medical device innovations for the CU Denver
  • Venture Partners at CU Boulder supports the CU Denver campus for non-medical device innovations
• University of Colorado Internal Audit  - Conducts audits of University programs and activities
• University of Colorado Office of Policy and Efficiency – Oversees University-wide policies that apply to all campuses
• University Libraries
  • Auraria Library
  • Strauss Health Sciences Library located on CU Anschutz Medical Campus

Additional information about each office is provided throughout the Handbook.

The award lifecycle of a sponsored project has two major phases: pre-award and post award. The duration of an award varies depending on the sponsor and the nature of the project.

The pre-award phase includes:

• Locating funding opportunities
• Proposal development
• Internal routing and approvals
• Proposal submission
• Responding to sponsor inquiries
• Just-in-time requests
• Award negotiation
• Award acceptance

 The post award phase includes:

• Award set-up
• Pre-award spending
• Award Administration
• Project closeout
• Post-closeout activities

The requirements for each aspect of the award lifecycle are discussed throughout the Handbook.

Throughout the award lifecycle, the University is often required to provide institutional information to sponsors. Commonly requested data elements and other institutional details are available on the University’s FDP Clearinghouse profile and the OGC Admin Info website.

Sponsors use a variety of award instruments, with grants and contracts being the two most common types.

1.8.1 Grants

Grants are a form of financial assistance awarded to the University to conduct projects that fulfill a public purpose. Grants typically have the following characteristics:

• No substantial involvement is anticipated between the sponsor and the University during project performance
• The award includes terms, conditions, and other contractual requirements that must be met
• Budgetary restrictions apply and must be followed
• Financial and progress reports are typically required
• Expenditures must be documented
• The project has a defined start and end date

Fixed amount, or fixed price, are a type of grant in which payment is based on achieving specific milestones identified in the scope of work. Federal fixed amount subagreements are governed by 2 CFR 200.201. While the University may receive fixed amount awards or subagreements, University policy prohibits the issuing of fixed amount subagreements to subrecipients.

Cooperative Agreements are a type of grant characterized by substantial sponsor involvement in the project, as defined in the award terms and conditions. Substantial involvement may include:

• Participating in the project design, data collection, or data analysis
• Co-authoring papers
• Assisting in selecting contractors or hiring project staff
• Review of proposed publications or presentations

1.8.2 Contracts

Contracts are award instruments in which the University provides goods or services to the sponsor. Contracts specify clear obligations for both the sponsor and the University, with an expectation that specific deliverables will be provided within a defined timeframe. Compared to grants, contracts generally allow less flexibility to modify the project during the post-award phase. Federal contracts are governed by the Federal Acquisition Regulation (FAR) rather than 2 CFR 200.

 There are two primary types of federal contracts:

• Cost Reimbursable Contracts
• Fixed Price Contracts
  

Cost reimbursable contracts are the University’s preferred contract type. These contracts provide payment for actual incurred costs and carry less financial risk for the University.

Fixed price contracts provide a total or lump-sum payment upon completion of specific tasks or deliverables within an agreed timeframe. This contract type involves more risk, as any cost overruns become the responsibility of the Principal Investigator (PI) and their respective administrative unit.

 1.8.3 Clinical Trials

A clinical trial is defined as controlled clinical testing in human subjects of investigational new drugs, devices, treatments, or diagnostics—or comparisons of approved drugs, devices, treatments, or diagnostics—to assess their safety, efficacy, benefits, costs, adverse reactions, and/or outcomes. Such studies may be conducted under either an industry-developed protocol or an investigator-developed protocol.

Clinical trial agreements are reviewed and approved following the same procedures as other sponsored projects. Principal Investigators (PIs) and University employees must comply with the terms of the sponsor’s clinical trial agreement.

1.8.4 Other Award Instruments

Sponsors may award the University agreement types other than grants and contracts. These other award instruments include:

• Material Transfer Agreement (MTA) – An agreement to transfer tangible research materials (e.g., cells, animals, or other scientific materials) from one institution to another.
• Revenue/Fee-for-Service – Agreements related to revenue-generating activities such as consulting, professional services, lab or facility use, or revenue agreements for on-campus service centers.
• Equipment Loan Agreements – Agreements that involve the temporary loan of equipment from one institution to another.
• Confidential Disclosure Agreement (CDA) and Non-Disclosure Agreements (NDA) – Agreements that prevent the unauthorized use or disclosure of protected or proprietary information.
• License Agreements – Agreements between the University and a commercial entity granting rights to develop, produce, or sell products based on the University’s intellectual property.
• Data Use Agreement (DUA)/Business Associate Agreement (BAA) – Agreements related to the transfer, use, or protection of data,
• Member Practice Consulting Agreement – Agreements related to consulting services provided through CU Medicine.
• Other Transactional Agreements (OTAs) – Federal award instruments that are not subject to the standard requirements of grants or contracts and offer more flexibility in structure and negotiation.

 Additional information regarding the processing and requirements for these agreements can be found on the University Contracting Menu guidance.

1.8.5 NIH Activity Codes

NIH uses three-character activity codes to distinguish between the wide variety of research-related programs it funds. Award requirements and cost allowability vary by activity code. A full description of each NIH activity code can be found on the NIH Activity Codes website.

1.8.6 SBIR and STTR Awards

Several federal agencies provide grant funding to for-profit small businesses through Small Business Innovation Research (SBIR) or Small Business Technology Transfer (STTR) awards. SBIR awards encourage subagreements with research institutions, while STTR awards require such subagreements. University resources may only be used for activities conducted under an SBIR or STTR subagreement awarded to the University.

 Federal law imposes strict requirements on time and effort reporting for Principal Investigators (PIs) involved in SBIR or STTR projects. Additionally, each award type presents potential conflicts of interest that must be addressed. A University employee may not serve as both the PI of the overall SBIR or STTR award and the PI of the University’s subagreement. For more details, refer to the University’s Faculty Entrepreneurial Activity & SBIR/STTR Collaboration Policy.

 1.8.7 Gift Agreements

A gift is any item of value given by a donor who does not expect anything of significant value in return, other than recognition and the use of the gift in accordance with the donor’s stated intent. While a gift may include restrictions on its use, it does not impose contractual obligations.

Gifts are not considered sponsored projects and are not subject to the same terms or requirements. Gifts are irrevocable and do not have a specified period of performance. In most cases, gift agreements are made to the CU Foundation rather than directly to the campus.

Sponsored projects are awarded to the University, and the PI named in the award notice is responsible for managing the project in accordance with sponsor terms and conditions. Award funds may only be used in compliance with sponsor requirements and University policies.

University employees have a fiduciary responsibility to report any suspected fraud, waste, or abuse on sponsored projects. Concerns may be reported to a manager or administrative unit leadership, through CU EthicsLine, or to Internal Audit.

Under 2 CFR 200.113 Mandatory Disclosures, the University is required to promptly disclose to the federal sponsor and any pass-through entity when credible evidence exists of a violation of federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations. When this requirement is triggered, PIs and their administrative units must notify Fiscal Compliance, which will coordinate submission of the necessary disclosure to the sponsor or pass-through entity following review by Legal Counsel.

Federal law provides whistleblower protections to employees and prohibits the University from retaliating against any employee who reports waste, fraud, or abuse on federal awards or subagreements. Additional information on these protections is found in 2 CFR 200.217. This section of the Handbook also fulfills the University’s obligation to inform employees of their rights and protections under 41 U.S.C. 4712, as required by 2 CFR 200.

The University utilizes a variety of applications and systems to manage sponsored projects. Each employee is responsible for completing any required training before gaining access to these systems and for using them in accordance with University policies and procedures.

 Key University management systems include:

• InfoEd eRA (InfoEd) - Used during the pre-award phase to develop and route proposals, initiate contracts for negotiation, manage conflict of interest (COI) disclosures, track human subjects reporting, and store award-related documents.
• CU Data – the University’s financial reporting system portal, which contains m-Fin and other grant reports
• CU Marketplace - the University’s eProcurement system
• Concur Travel and Expense - The University’s system for managing travel arrangements and commercial card transactions.
• Human Capital Management (HCM) - The University’s human resource management system, that contains job codes, employee classifications, benefits information, and compensation/payroll data.
• OnCore - The University’s clinical trial management system.
• PeopleSoft Finance and Grants Administration Module – Provides access to the University’s financial system and includes journal entries, invoicing, grants administration, and financial reports for sponsored projects.

An Authorized Organizational Representative (AOR) is a University employee who has been granted legal authority by the Board of Regents to sign legal documents on behalf of the University. All AORs are employees of OGC. PIs and administrative units are not permitted to perform any function that requires AOR approval, submission, or signature.

Actions that require AOR approval may include:

• Proposal submission
• Submitting a Just-in-Time request
• Requesting prior approval
• Submission of financial reports
• Accepting or signing an award document
• Executing an award agreement

A list of OGC signing officials is available on the OGC Admin Info website.

The University uses PeopleSoft Finance System to manage institutional financial information. Within this system, Funds are used to identify the source of money.

For sponsored projects, the University uses the following Funds:

• Fund 30 – Sponsored projects from federal and non-federal entities
• Fund 31 – Sponsored projects from the State of Colorado or local government within Colorado

For cost share obligations, the University may use the following funds:

• Fund 22 – Cost Share Auxiliary Enterprises, used when cost share is provided from administrative unit funds
• Fund 32 – Cost Share Sponsored Projects, used when cost share is met using a gift or Academic Enrichment Funds (AEF)
• Fund 72 – Renewal and replacement funds, used for construction grants

Each sponsored project is assigned a project number, which will have at least one associated speedtype. A speedtype is an internal term referring to a chartfield within the finance system. It is a unique 8-digit identifier that indicates the campus and the corresponding fund.

Employees may use either the project number or speedtype in the finance system to generate an m-Fin report, which provides detailed financial information. Budgeted and expended funds are tracked using account codes. To assist with financial management and reconciliation, the University provides an Account Quick Reference Card.

Faculty at the CU Denver campus may be hired on a 9-month contract for the academic year. As a result, academic-year and summer-month compensation must be budgeted separately, since the summer period is not covered by the standard academic contract. A separate 3-month contract must be negotiated for each calendar year to cover summer effort.

The monthly summer salary may not exceed 1/9th of the faculty member’s 9-month academic salary, excluding administrative stipends or awards. Faculty may budget up to three full summer months of compensation per calendar year, but this must account for any administrative stipends paid during that period. Per CU Denver policy 1006, summer compensation must reflect actual effort provided during the summer and may not be used to compensate for effort during the academic year.

With permission from their dean, and in accordance with school/college and department policies, faculty may reduce their University-paid academic-year salary in exchange for an equivalent amount of compensation from research grants and contracts, consistent with the level of effort provided.

Faculty may also budget effort during the academic year toward a course buy-out, which relieves them of teaching responsibilities and allows more time for research. The required level of effort needed to cover a course buy-out varies by college, school, and department.

Two online courses are available through Skillsoft Percipio to assist PIs and other University employees in managing sponsored projects:

• CU: Direct Charging to Sponsored Projects (u00059)
• CU: ePER – electronic Personnel Effort Reporting System (u00055)

While the University does not require these courses, individual administrative units may mandate them for their employees, including PIs.

In addition, Fiscal Compliance offers a variety of training courses related to sponsored project management. These courses are available to all University employees. Additional information about available training opportunities can be found on the Fiscal Compliance website.

All documents submitted to federal sponsors must be in English and provide financial information in U.S. dollars. The only exception to this requirement is when the federal funding opportunity announcement or the award terms and conditions provide otherwise. Regardless of federal requirements, all documents submitted to OGC must be in English and use U.S. dollars.

It is the responsibility of the PI and their administrative units to translate documents into English and convert financial information into U.S. dollars before submission to OGC or to a federal sponsor. All currency conversions must be computed using the conversion rate on the day the costs are incurred. The Office of International Affairs may assist administrative units in locating translation services.

The University of Colorado is a state institution, and documents associated with sponsored projects, including electronic communications such as e-mail, are subject to the Colorado Open Records Act (CORA).

Additional information about CORA is found on the University of Colorado’s Open Records Requests website.

2 CFR 180 prohibits federal funds from being provided to any individual or entity that has been suspended or debarred from federal activities. The PSC is responsible for ensuring compliance with procurement agreements and OGC Subcontracts is responsible for ensuring compliance with subagreements.

Federal law prohibits recipients and subrecipients of federal awards from obligating or expending federal loan or grant funds to procure certain telecommunication products. The PSC is responsible for ensuring the University of Colorado is in compliance for procurement agreements. PIs and their respective administrative units are responsible for ensuring subrecipient compliance.

Additional information is found at 2 CFR 200.216.

The University is a close partner and affiliate of Children's Hospital Colorado (CHCO). The affiliation agreement between the two entities states that, in general:

• The University is the direct recipient of any non-industry (federal, state, non-profit) funding for research that takes place at CHCO, and the University is the only party to the contract with the sponsor.
• CHCO is the direct recipient of the funding for any industry-sponsored clinical trials where the site is CHCO, and both entities will enter into a tri-party agreement with the sponsor.
• The University is the direct recipient for industry-funded investigator-initiated trials, and both entities will enter into a tri-party agreement with the sponsor.

There are some rare exceptions to this rule, so please work closely with the OGC if you have any questions about which entity should be the recipient of funding for a particular project.

An Interpersonal Agreement (IPA) is used when a University employee is temporarily assigned to a federal government entity, such as a Veterans Affairs hospital or a federal research laboratory. A Joint Personnel Agreement (JPA) is used when a University employee is temporarily assigned to a non-government entity, such as the Denver Research Institute.

Information regarding IPAs and JPAs is found on the OGC website.

University employees with a dual appointment with the Department of Veterans Affairs must maintain a valid and current memorandum of understanding (MOU) identifying the relationship with both entities.

Information regarding VA Dual Appointments is found on the OGC website.

Regent Law recognizes and supports the principles of academic freedom, and the University will not accept restrictions on research involvement or publications absent compelling reasons. The University’s Restricted, Proprietary, and Classified Research policy identifies and clarifies situations in which the University may accept such restrictions. This policy specifically applies to CU Anschutz Medical Campus.

In the absence of a campus-specific policy for CU Denver, this policy is inherently applied to CU Denver until further notice. The Chancellor for CU Denver may approve exceptions to the policy.

Since January 2025, the federal government has made significant changes to award terms and conditions. These changes are often imposed with immediate effect. Information regarding federal updates can be found on the following websites:

• University of Colorado Federal Transition Updates
• CU Anschutz Federal Updates
• CU Denver Campus Communications

Due to ongoing changes at the federal level, the Handbook may not always reflect the most recent updates from federal agencies or judicial rulings. It is the responsibility of all University employees to remain informed of evolving government requirements and to ensure compliance with federal policies affecting federal awards.

Effective Fiscal Year 2026, the CHIPS and Science Act of 2022 (Section 10634) mandates that Principal Investigators (PIs) and senior/key personnel on federal research grants complete annual research security training as a condition for receiving new federal awards. Implementation of this requirement varies by federal agency.

For the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Energy (DOE), and Department of Defense (DoD), this requirement may be fulfilled by completing the NSF’s SECURE Center consolidated training module. The module takes approximately one hour to complete. Upon completion, individuals must download or print the certificate of completion and be prepared to provide it to the Office of Grants and Contracts (OGC) and/or the relevant federal awarding agency.

It is the responsibility of PIs and other personnel to ensure compliance with all applicable agency-specific requirements prior to proposal submission. OGC Pre-Award will be unable to submit any application to a federal agency or pass-through entity unless all required training has been completed. For questions regarding agency-specific requirements, please contact OGC Pre-Award.

 

 1.24.1 National Institutes of Health (NIH)

As of October 1, 2025, NIH has not finalized final research training requirements and stated future guidance will be announced “in the coming months.” (NOT-OD-25-161Update: Recission Notice re: Implementation of NIH Research Security Policies).

Additional information and University-specific resources are available on the Office of Regulatory Compliance’s NIH Training Requirements website.

 

 1.24.2 National Science Foundation (NSF)

In July 2025, NSF issued Important Notice No. 149: Updates to NSF Research Security Policies, outlining its training and certification requirements.

Under this policy, PIs, co-investigators, and other senior/key personnel must complete research security training within 12 months prior to the submission of a grant application. These individuals are also required to certify completion of the training on their Current & Pending (Other) Support documentation.