Why is IRAP putting holds on my grants?
"Regs" they are a'changing
Due to recent changes in federal regulations, there are more stringent requirements to monitor potential conflicts of interest in federally funded research. Along with the implementation of IRAP, several policies have been put into place to ensure UAB’s compliance with the “Financial Conflict of Interest Final Rule” for all extramurally sponsored projects.
As a result, in order to submit a proposal, the status of your proposal must be updated to “OK to submit” in IRAP prior to submission. In order for OSP to release an award, the status must be updated to “OK to award” in IRAP.
What does “OK to submit” mean?
“OK to submit” means that all key or responsible personnel on the project have completed their annual disclosure of financial interests. A proposal cannot be submitted until all of these individuals complete the annual disclosure.
What does “OK to award” mean?
“OK to award” means that all key or responsible personnel have completed their annual disclosure of financial interest, completed the mandatory FCOI training and any potential financial conflict of interests have either been mitigated or eliminated. If a proposal is “OK to submit”, but it is not “OK to award”, it is usually because one or more key or responsible personnel have not completed their FCOI training or will need to undergo a transactional review prior to the processing of the award.
What do I do to fix it?
Fortunately, the Center for Nursing Research and the UAB School of Nursing have put into place several policies and procedures within the SON to help expedite this process. Please visit the CNR Policies and Procedures SharePoint Site to see more details on how to avoid or minimize potential holds and delays.
If you want additional information about IRAP and project statuses, please visit the UAB IRAP Training Page that can be accessed from the IRAP Login Screen. For more information about UAB’s FCOI policies, please visit the UAB CIRB Website.
If you have any questions or need additional information, please contact Kevin Keane, CNR Program Manager, at firstname.lastname@example.org or Frank Wiser, Director of SON Grant & Contract Administration at email@example.com.