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You may need to disclose in M-Inform
In order to complete the “Sign PAF” activity, investigators will need to have a current outside interest disclosure on file in the M-Inform system (within the past 365 days)
View the Webinar on the "Sign PAF" Requirement for Investigators & "Other Support" Review.
The Sign PAF and Sign Award Record activities in the eResearch Proposal Management (eRPM) system will be updated on September 14, 2020, to require all investigators to sign. Gathering these signatures from all participating U-M investigators, and not just the Principal Investigator, will help the University ensure its full compliance with our funding agencies’ disclosure requirements, especially with regard to the accurate and complete disclosure of international engagements and collaborations.
What changes will be made to the “Sign PAF/Sign Award Record” activity?
The “Sign PAF/Sign Award Record” activity will be updated to include:
- All investigators listed on a PAF must complete the “Sign PAF/Sign Award Record” activity (see following section)
- Questions regarding investigator outside interest disclosure as it relates to the proposal.
- Questions regarding investigator international engagements (e.g., appointments, resources).
- Attestation of investigator role and responsibilities.
Who must complete the “Sign PAF/Sign Award Record” activity?
All investigators listed on a PAF, including the following roles:
- U-M Principal Investigator (PI)
- U-M Sponsor PI
- Participating Investigator with Specified Effort
- Participating Investigator without Specified Effort
- Non-faculty Investigator
When must the “Sign PAF/Sign Award Record” activity be completed?
Investigators are expected to sign the PAF prior to proposal submission. The proposal will still be submitted even if the PAF lacks all required signatures, but:
- Investigators who have not signed at the time of proposal submission will receive email reminders to complete this activity.
- After 30 days, the proposal will be at risk of withdrawal.
- All signatures must be completed prior to award acceptance.
Investigators added at Award set-up will be required to complete a new “Sign Award Record” activity in eRPM.
- The "Sign Award Record" activity contains the same components and information as the “Sign PAF” activity.
Investigators added after Award activation will provide the required information via the PACR process.
What happens to PAFs already in progress on September 14?
PAFs routed for Unit approval prior to September 14 that have the necessary (PI only) signatures to meet the current requirement will continue to be routed, reviewed, and submitted, without the need for other investigators on the PAF to complete the “Sign PAF” activity in eRPM.
PAFs that have not been routed for Unit approval prior to September 14, or have been routed without the required PI signatures in place, will fall under the new requirement, and all investigators on the PAF will need to complete the “Sign PAF” activity within 30 days of submission to the sponsor.
Beginning September 14, a Revised PAF will continue to require Unit approvals, but the U-M PI(s) will no longer be required to re-sign the PAF. Note that any new investigators added to a PAF will be required to perform the Sign PAF activity and must do so prior to the creation of an award record (AWD). (See SOP 300.01 - Revised PAFs).
Restored PAFs will require all investigators to complete the "Sign PAF" activity. (See SOP 300.04 - Restored PAFs)
How will Investigators' Answers to the "Sign PAF" Questions be Used?
Staff in ORSP and the Conflict of Interest (COI) offices are conducting a pilot project to use the information provided by investigators in the eRPM "Sign PAF" activity to complete a congruence review with sponsor-required documentation such as "Other Support" and "Current & Pending Resources."
What can I do to prepare?
- Ensure all investigators on your project team to update their M-Inform outside interest disclosures.
- Review a webinar on this topic.
- Stay tuned to future communications, including RAPid announcements, for more details about this change, including impacts to current proposals and awards.
- Details of the new "Sign PAF/Sign Award Record" activity can be seen here. Note: The red "Warning" message at the top of the page only displays if the investigator running the activity does not have an up-to-date M-Inform disclosure on record, or is lacking an M-Inform disclosure altogether.
It depends. If the investigator has never disclosed in M-Inform and the PAF is the reason they need to disclose, they would not receive an email notification. However, if the investigator is supposed to be disclosing annually in M-Inform but hasn’t, they would receive an email on the first of every month asking them to go to M-Inform to disclose
Immediately after disclosing in M-Inform, the investigator is able to complete the “Sign PAF” activity.
Investigators, including the PI, can sign the PAF in any order.
Yes. Investigators can sign the PAF as soon as they have been added to it.
During the pilot phase, staff in ORSP and the COI offices will conduct a congruence review of sponsor-required documents (e.g., Other Support, Current & Pending Support) only for federally sponsored proposals where an investigator has answered "yes" to one of the International Engagement questions on the "Sign PAF" or "Sign Award Record" activity (i.e., questions 2a-d).
Resources are NOT specifically related to the project proposed. Per NIH, “Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value” and regardless of their source. When answering question 2d in the "Sign PAF" activity, U-M Investigators do not need to include non-monetary resources arranged through U-M as Unfunded Agreements (e.g., material transfer agreements, data use agreements) or resources acquired through U-M Procurement processes (e.g., purchase order).
For the pilot, Other Support review will be conducted only for federally funded projects where an investigator has answered “yes” to one of the International Engagement questions on the “Sign PAF” activity. However, the “Sign PAF” activity is required for all PAFs, regardless of funding type.
No. The underlying purpose of the Other Support review is to ensure that the information the University is providing to sponsors is accurate and complete. If the sponsor does not require Other Support documentation (or similar) for those personnel, you would not need to provide it. Remember, too, that during the pilot phase the Other Support review applies only to federally funded projects.
ORSP will not require submission of Other Support documentation earlier than what the sponsor requires. For example, NIH requires it at Just In Time; NSF and DoD require it at time of proposal submission.
Research Administrators do not need to notify the investigators. The day after a proposal is submitted to the sponsor, a system-generated email will be sent to any investigators on the PAF who have not yet signed. Follow-up system-generated emails will be sent 10, 20, and 25 days after proposal submission to the sponsor.
The PI and PAF Primary Research Administrator will be copied on all the messages, sent 1, 10, 20, and 25 days after proposal submission to the sponsor. The 20- and 25-day messages will also copy the Department and Unit-level Research Administrators.
Not at this time. However, we are working with ITS to get the data related to “PAF Sign” activity added to the Data Warehouse. We will share more information as reporting options become available.
No. There is not anything built into the eRPM system that will automatically trigger the withdrawal of the proposal after 30 days if any investigators have failed to complete the “Sign PAF” activity.