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NIH Actions and Oversight

Learn what actions NIH can take to address sexual harassment pre- and post-award.

Pre-Award Actions 

When an organization submits an application to NIH, their Authorized Organization Representative certifies that the organization will comply with all applicable policies, assurances and/or certifications referenced in the application.  Some of these requirements involve the submission of a separate document to the appropriate federal office, including the civil rights assurance that must be submitted to the HHS Office for Civil Rights (OCR). False certification that the required assurance is on file may render an applicant ineligible for award. If a grant is awarded on the basis of false or misrepresented information, or if a recipient does not comply with the terms and conditions of award including those related to the assurances and certifications, NIH may take any necessary and appropriate actions for noncompliance, which may affect the recipient’s future funding. 

NIH conducts a pre-award risk assessment for every applicant organizations by checking multiple federal-wide systems used for management and oversight of federal funding recipients. This includes checking the federal System for Award Management, among other resources, to determine if a recipient is eligible to receive an NIH award.  NIH also queries the Federal Awardee Performance and Integrity Information System and the National External Audit Review Center to determine if the applicant organization is eligible and qualified to receive an NIH grant award. NIH reports all information on non-compliance into these systems, including violations of the NIH Grants Policy Statement, that incorporates obligations to comply with federal laws and regulations, such as civil rights protections.

Post-Award Actions

The grantee institution is obligated to notify NIH if it takes an administrative action, such as imposing leave or terminating employment, that affects the ability of senior/key personnel to continue on an NIH grant award, or otherwise constitutes a change in their status. 

If NIH learns of an allegation of sexual harassment, we alert the relevant recipient/applicant institution to verify issues and take appropriate actions. If an institution, which is responsible for senior/key personnel on an NIH-funded grant, is not in compliance with applicable laws, regulations, and policies, NIH can take several actions that could include or result in a change in senior personnel, or remedies for noncompliance, such as suspension or termination of the grant award.

Generally, NIH takes into consideration all individuals involved in the circumstances, such as patients, employees, trainees, and in some cases, those affected by harassment supported by NIH funding.
While NIH does not intervene in personnel matters at other organizations, we take all allegations of sexual harassment very seriously and require that grantee institutions foster work environments conducive to high-quality research, a term and condition of NIH award. We urge people to report allegations to the appropriate authorities. (See Find Help.)

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