Following on from Kristin Lund’s recent RAF presentation, I am excited to share a number of updates related to OCGA Outgoing Subawards:
- The Outgoing Subawards section of the OCGA website has been reformatted and updated to provide a life cycle overview of outgoing subawards, from proposal submission to requesting, managing, and closing out subawards and MCAs.
- Outgoing subawards forms have been consolidated and streamlined.
- The electronic EPASS system has been updated to include a new Subawards page to support easier organization and upload of subaward information. More information on the changes to the Electronic EPASS can be found here.
- Lastly, shortly after Kristin discussed new NIH procedural requirements for foreign subrecipients at RAF, NIH issued updated guidance. We are still awaiting clarifying FAQs from NIH but in summary:
- The implementation date was pushed from October 1st, 2023 to January 1st, 2024.
- Rather than being required every six months, subrecipient data will be required annually, to coincide with RPPR due dates.
- Rather than the PI being required to obtain from foreign subrecipients copies of all lab notebooks, all data and all documentation that supports the research outcomes, the requirement has been updated that access be provided to all data, and the access can be electronic.
We will provide additional updates of UCLA’s implementation of the new NIH foreign subrecipient requirements at a future RAF.