PAF budget justification documents sent to all sponsors will be required to include a specific paragraph approved by OGC and ORSP leadership. Effective Nov. 1, 2025, the following language must be included on any PAF budget justification document sent to all sponsors:
“University of Michigan certifications of compliance are based on reasonable knowledge of programs authorized and supervised by the University of Michigan as of the date of signing. University policy is to operate federally supported research and programs in compliance with all applicable grant terms and conditions, consistent with current laws, regulations, and related court decisions. The University regularly examines programs, policies, and activities for compliance with university policy and federal and state law. The University’s ongoing compliance processes include monitoring, audits, a compliance hotline, and training. The University takes prompt corrective action when it has direct knowledge of non-compliance with policy or applicable law.”
A PAF will be returned for a “Required Change” if the above language is not in the budget justification document.
Sponsor-specific guidance
- For DOE projects (direct or prime) requiring a budget justification workbook, the language should be included on the “Instructions and Summary” tab in the “Additional Explanations” section.
- For NIH budgets or solicitations that require only specific budget categories (e.g., modular, R35), include the paragraph in the "Facilities" document.
- For NASA (or other sponsor) solicitations that require an anonymized or redacted budget justification that does not identify the proposing entity, use the following alternate paragraph:
“Certifications of compliance are based on reasonable knowledge of programs authorized and supervised as of the date of signing. Our policy is to operate federally supported research and programs in compliance with all applicable grant terms and conditions, consistent with current laws, regulations, and related court decisions. Programs, policies, and activities are regularly examined for compliance with internal policy and federal and state law. Ongoing compliance processes include monitoring, audits, a compliance hotline, and training. Prompt corrective action is taken when there is direct knowledge of non-compliance with policy or applicable law.”
If a budget justification document is not being sent to the sponsor (some foundations do not require one), the paragraph does not need to be included in the proposal.
Questions?
- Prior to a PAF for a proposal arriving at ORSP, direct questions to: [email protected].
- Once an officer is listed in the Project Representative field on the PAF, contact them directly.