The prime recipient has an essential obligation to oversee the work of subrecipients (both foreign and domestic) and as part of that oversight they need access to data/documentation that supports the performance outcomes, reported by subrecipients, to confirm that they are accurate, complete and properly reflect programmatic goals, as stated in the RPPR (NIH GPS 2.3.7.6). If requested by NIH or auditors, recipients are expected to provide access to such data (NIH GPS 8.4.2).
By checking the PI Assurances in eProposal, PIs attest that the information submitted within the application is true, complete and accurate to the best of the PI’s knowledge (NIH GPS 2.3.7.6).
Commencing with NIH Research Performance Progress Reports (RPPRs) due January 2, 2024 and forward, Principal Investigators will be asked an additional compliance question:
“Did the PI access subrecipient’s data/documentation that supports the research outcomes described in the Progress Report/RPPR to confirm that the performance outcomes reported are accurate and complete?”
The question may be answered either:
- “Yes, the PI accessed data/documents,” or,
- “No relevant data/documents to access.”
If left unanswered, an error will prevent routing for approvals.
If there are concerns/questions regarding accessing data/documents, please visit the Research Security Program webpage. If there are concerns specifically related to restrictions imposed by foreign government laws, regulations, or policies, please write to the International Research Support Office (IRSO) as soon as possible.
Please direct inquiries to [email protected].