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Harassment Reporting Requirements by Agency/Entity in Brief

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Key Items Identified Sponsors Generally Require NSF NIH NASA Simons Foundation HHMI RCSA
What roles do the reporting requirements apply to? Principal investigators and others PIs and Co-PIs PD/PI and other named senior/key personnel PIs and Co-Is PIs and all other members of the research team All personnel or participants in grant-funded programs, attendees at HHMI events, or indivduals performing work on behalf of HHMI. PI or Co-PI
What must be reported? Findings/determinations and administrative actions Any findings/determinations of sexual harassment, other forms of harassment, or sexual assault regarding an NSF funded Principal Investigator (PI) or co-PI, or of the placement of the PI or co-PI on administrative leave, or the imposition of any administrative action relating to harassment or sexual assault finding or investigation NIH must be notified when individuals identified as PD/PI or other Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined by the recipient institution due to concerns about harassment, bullying, retaliation or hostile working conditions; Changes in a principal investigator or other senior key person's status during an investigation of alleged sexual misconduct; If it is determined that the concerns shared with NIH will impact the PD/PI or senior key personnel's ability to continue as the scientific lead of the project, NIH will require prior approval for a replacement PD/PI or senior key official Any findings/determinations of sexual harassment, other forms of harassment, or sexual assault regarding a NASA funded PI or Co-I; if the PI or Co-I is placed on administrative leave or if the recipient has imposed any administrative action on the PI or Co-I, or any determination or an investigation of an alleged violation of the recipient's policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault Any Determination or Administrative Action involving Personnel relating to Prohibited Conduct; includes violation of MSU policy and professional codes of conduct. HHMI must be notified of the initiation of a formal investigation of misconduct relating to  violations of law or institution policy regarding harassment, discrimination, retaliation, or sexual misconduct.  After the investigation has concluded, the findings of the investigation must be reported. Institution determination that a PI or Co-PI has violated the Institution’s policies or any applicable laws regarding sexual harassment, other forms of harassment, or sexual assault under the Institution’s financial or workplace conduct policies (e.g., harassment).
Implementation Date for reporting requirements Agency specific 10/22/2018 6/11/2020 4/9/2020 4/6/2020 Not specified 2/1/2023
What awards are subject to the requirements? Agency specific and varies between all awards or as new or modified awards After October 22, 2018, new awards and funding amendments to existing awards will subject to the new notification requirement For awards (competing, non-competing and supplements) issued after June 11, 2020, prior approval requests for change in PI or Senior/Key Personnel named in the NoA, or changes in recipient institution must disclose whether these requests are related to concerns about safety and/or work environment (e.g., due to concerns about harassment, bullying, retaliation, or hostile working conditions) After 4/9/2020, all new NASA awards and funding amendments to existing awards made on or after the effective date will be subject to the new term and condition All awards All grant-funded programs. Awards issued 2/1/23 and going forward.
Timeframe for submitting reports to agency Within 10 business days Within ten business days from the date of the finding/determination, or the date of the placement of a PI or co-PI by the awardee on administrative leave or the imposition of an administrative action, whichever is sooner Notification must be provided by the Authorized Organization Representative within 30 days of the removal or disciplinary action; The request for prior approval must be submitted promptly, and NIH must be proactively notified of any change of status of the PI or senior key person.  Within ten business days from the date of the finding/determination, or the date of the placement of a PI or Co-I by the recipient on administrative leave or the imposition of an administrative action Within ten business days of any determination or administrative action involving personnel related to prohibited conduct, except as prohibited by law Notification must be made within five business days of the initiation of the investigation. Findings must be reported within five business days after the investigation has concluded. Promptly upon determination of violation.
Reporting requirements for subrecipients Direct to applicable federal agency If a co-PI is affiliated with a subawardee organization, the Authorized Organizational Representative of the subawardee must provide the requisite information directly to NSF Not differentially identified If a co-I is affiliated with a subrecipient organization, the AOR of the subrecipient must provide the requisite information directly to NASA and to the recipient Not differentially identified The grantee institution must provide notification of a Partner Institution's initiation of an investigation of alleged misconduct and the  findings of the Partner Institution's investigation using the same timeline specified above.  Not differentially identified
Additional requirements for conference grants Agency specific for those that normally award conference grants For any grant that provides support for an NSF-sponsored conference, the grantee is required to have a policy or code-of-conduct that addresses sexual harassment, other forms of harassment, and sexual assault, and that includes clear and accessible means of reporting violations of the policy or code-of-conduct. The policy or code-of-conduct must be disseminated to conference participants prior to attendance at the conference as well as made available at the conference itself.

Effective for R13/U13 applications submitted for the April 12, 2022 application due date and thereafter, all applicants recommended for funding must provide to NIH as part of Just-In-Time materials: 

  • The “safety plan” that will be communicated to all conference/meeting attendees. “Safety plans” are required to include certain elements, as described in Notice Number NOT-OD-22-074. 
  • A description of the strategy that will be used to communicate the Safety Plan to conference attendees
  • A plan to document allegations and resulting actions.
  • Information on the steps the organizers will take to ensure a safe and respectful environment for all attendees, free from discrimination and harassment

For more information, please see our NIH Conference Safety Requirements webpage.

 Not differentially identified Not differentially identified Not differentially identified. Not differentially identified
Reporting addresses or methods of submitting reports Authorized Organizational Representative (AOR) to agency/entity specific Notification must be submitted via the NSF's Organizational Notification of Harassment Form Grantee harassment webform https://public.era.nih.gov/
shape/public/notificationForm.era. Contact the NIH grants management specialist of the awarding NIH Institute or Center. In cases of sexual harassment, please also copy GranteeHarassment@od.nih.gov.		 Reports must be submitted NASA's Office of Diversity and Equal Opportunity.  More information on how to submit a report is available at https://missionstem.nasa.gov/filing-a-complaint.html The Notice should be submitted through the Simons Foundation’s secure portal: https://www.simonsfoundation.org/
funding-opportunities/policies-and-procedures/
institution-notification-form/		 Notification and reports should be submitted to the Vice President for Science Education or an Institute designee. See RCSA contact in applicable Notice of Award.

Note:  Additional requirements may be in place if MSU personnel go to a federal government facility1.

Description URL
NSF Important Notice No. 144 https://www.nsf.gov/pubs/issuances/in144.jsp
NSF Term & Condition:  Sexual Harassment, Other Forms of Harassment, or Sexual Assault https://www.nsf.gov/od/oecr/awardee_civil_rights/term_and_condition.jsp
Federal Register:  Notification Requirements Regarding Findings of Sexual Harassment, Other Forms of Harassment, or Sexual Assault (NSF) https://www.federalregister.gov/documents/2018/09/21/2018-20574/notification-requirements-regarding-findings-of-sexual-harassment-other-forms-of-harassment-or
NIH Expectations, Policies, and Requirements https://grants.nih.gov/grants/policy/harassment/policy-requirement.htm
Reporting Requirements Regarding Findings of Harassment, Sexual Harassment, Other Forms of Harassment, or Sexual Assault (NASA) https://www.federalregister.gov/documents/2020/03/10/2020-04815/reporting-requirements-regarding-findings-of-harassment-sexual-harassment-other-forms-of-harassment
Simons Foundation Policies & Procedures https://www.simonsfoundation.org/funding-opportunities/policies-and-procedures/
Clarification of NIH's Policy Regarding a Change in Program Director's/Principal Investigator's Status https://grants.nih.gov/grants/guide/notice-files/NOT-OD-18-172.html
Update on NIH's efforts to address sexual harassment in science https://www.nih.gov/about-nih/who-we-are/nih-director/statements/update-nihs-efforts-address-sexual-harassment-science
NIH Guidance Regarding Change in Status, Including Absence of PD/PI and Other Key Personnel Named in the Notice of Award (NOT-OD-20-124) https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-124.html
NSF Special Terms and Conditions for Administration of NSF Conference or Travel Grants (Effective 1/28/2019) https://www.nsf.gov/bfa/dias/policy/fl26/fl26_119.pdf
Updated Requirements for NIH Notification of Removal or Disciplinary Action Involving Program Directors/Principal Investigators or other Senior/Key Personnel (NOT-OD-22-129)

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-22-129.html
Plans to Promote Safe Environments at Conferences Supported by NIH Grants and Cooperative Agreements (NOT-OD-22-074)

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-22-074.html
1.  NOAA Sexual Assault and Sexual Harassment Prevention and Response Policy (NAO 202-1106) https://www.noaa.gov/organization/administration/nao-202-1106-noaa-sexual-assault-and-sexual-harassment-prevention-and
HHMI Workplace Behavior Policy Workplace Behavior Policy (windows.net)

 

 

 

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