Dear Colleagues,
In recent days we have become aware that some federal agencies or specific programs within agencies have begun asserting that grant proposal submission, reporting, and other processes constitute agreement to additional terms and conditions. I write to remind you that while PIs at UWM are responsible for initiating and drafting proposals in response to funding opportunities and for providing regular reports, researchers are not authorized to negotiate or sign agreements on behalf of the university. At UWM, execution of research agreements is completed by Authorized Organizational Representatives (AOR) in the Office of Sponsored Programs (OSP) to ensure appropriate oversight and awareness of any potential issues.
Given the manner in which new terms are being imposed, and in compliance with new guidance from the Universities of Wisconsin, the Office of Research is requiring, effective immediately and until further notice, that researchers send any documentation that will be submitted to federal agencies to OSP for vetting prior to submission. This includes but is not limited to certifications and technical reports. We recognize that is an additional burden for you at a challenging time and appreciate your patience as we work through these issues.
At UWM, it has always been the case that only an AOR may sign or otherwise agree to sponsored research agreements (contracts, grants, and cooperative agreements), as well as certain non-sponsored agreements, such as data use agreements, material transfer agreements, nondisclosure agreements, and memoranda of understanding. In cases where the PI submits materials that do not require AOR signature authority, such submissions should not suggest or imply acceptance of any terms or conditions by UWM.
Also consistent with guidance from Universities of Wisconsin, please be advised that as OSP monitors submissions for updated federal terms and conditions, additional legal review may be required before submission approval. Contact OSP well in advance of submission deadlines to facilitate such reviews.
— Kristian O’Connor, Interim Vice Provost for Research & Graduate School Dean