Institutional Requirements for General Federal Assurances, Certifications, and Regulatory Compliance

 I. Purpose and Scope

Central accepts federal research and sponsored program funding subject to strict statutory and regulatory conditions. This document outlines the universal institutional assurances, standard certifications, and compliance mandates required by all federal awarding agencies. It applies to all university employees, including principal investigators (PIs), co-investigators, senior/key personnel, subrecipients, independent contractors, and students supported by or participating in externally funded federal projects.

II. Government-Wide Debarment, Suspension, and Institutional Exclusions

A. Strict Prohibition on Covered Transactions

In accordance with Executive Orders 12549 and 12689, OMB Guidelines (2 CFR Part 180), and respective agency implementations (e.g., 2 CFR Part 376 for HHS and 2 CFR Part 2520 for NSF), Central is strictly prohibited from entering into any "covered transaction" with an individual or entity that is debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from receiving federal funds.

Covered transactions include:

• Employment or appointment as Senior/Key Personnel, Principal Investigator, or Co-Investigator on any federally funded project.
• Receipt of salaries, wages, stipends, or fellowships directly or indirectly charged to federal grants.
• Issuance of subawards, subcontracts, or procurement contracts exceeding standard purchasing thresholds.

B. Mandatory Employee Disclosure

Mandatory Self-Certification: Every investigator and key personnel member must certify on the internal Central Institutional Routing Sheet, prior to proposal submission, that they are not currently debarred, suspended, or excluded by any federal agency.

C. Consequence of Enforcement

Upon confirmation that an active employee or student has been excluded, suspended, or debarred by a federal agency:

• All charges to federal awards for that individual (including salary and travel) will be suspended immediately and permanently.
• The individual will be removed from all associated federal projects.
• The university may pursue internal administrative or disciplinary actions, up to and including termination of employment, subject to the CSU-AAUP or CSU-AFSCME collective bargaining agreements.

III. Statutory Certifications and Assurances

By authorizing the submission of a federal grant proposal, the university's Authorized Organizational Representative (AOR) makes several explicit, legally binding certifications on behalf of the institution. Faculty investigators are legally bound to uphold these assertions:

A. Certification Regarding Lobbying (31 U.S.C. 1352)

The university certifies that no federally appropriated funds have been paid, or will be paid, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, or an employee of a Member of Congress in connection with the awarding of any federal grant or contract.

B. Certification Regarding Drug-Free Workplace (41 U.S.C. 8103)

The university certifies that it maintains a drug-free workplace in absolute compliance with the Drug-Free Workplace Act. This requires clear notification to employees regarding the prohibition of controlled substances in the workplace and established institutional assistance programs.

C. Nondiscrimination Assurances

The university certifies absolute compliance with all federal statutes relating to nondiscrimination, including but not limited to Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, and the Age Discrimination Act of 1975.

D. Certification Regarding False, Fictitious, or Fraudulent Statements

The university notes that any willfully false, fictitious, or fraudulent statements or claims submitted within a grant proposal, progress report, or compliance disclosure may subject the investigator and the institution to criminal, civil, or administrative penalties under the False Claims Act (31 U.S.C. 3729-3733) and the Program Fraud Civil Remedies Act (31 U.S.C. 3801-3812).

Please note that there may  be additional Certifications and Assurances requirements specific to certain grants.

IV. Research Security Training Requirements (CHIPS and Science Act)

In compliance with Section 10634 of the federal CHIPS and Science Act of 2022, Central requires all Senior/Key Personnel (defined as "covered individuals" by federal sponsors) to complete specialized Research Security Training (RST).

• Requirement: Covered individuals must certify that they have successfully completed an approved research security training module within the 12 months immediately preceding the submission of any new or renewal federal grant proposal.
• Frequency: Training must be completed annually to maintain a valid certification status for active or pending proposal cycles.
• Core Topics Covered: The training modules provide essential guidance on identifying and mitigating risks regarding cybersecurity, international travel and collaboration, foreign interference, conflicts of interest/commitment, and federal disclosure and transparency requirements.

How to Access and Complete the Training

Central researchers can fulfill this requirement free of charge through the federally backed SECURE Center Consolidated Training Module (CTM 1.0). This course takes approximately 1 hour to complete and is recognized as compliant across major federal agencies, including the NSF, NIH, DOE, NASA, and USDA

1. Go to the National Science Foundation Research Security Training Page to access the official modules.
2. Complete the SECURE Center Consolidated Module.
3. Download and save your Completion Certificate.
4. Submit your certificate to the Grants & Funded Research (GFR) Office at CCSUGrants@ccsu.edu

Failure to complete this training within the required 12-month window prior to the due date may delay or disqualify your institutional grant submission.

V. Post-Award Institutional Reporting and Disclosure Mandates

A. Disciplinary and Harassment Notifications

To ensure safe, collaborative research environments, federal sponsors (specifically NIH and NSF) require institutions to report significant administrative actions. Central must notify the respective federal funding agency within 30 days if any investigator or key personnel member on a federal award is placed on administrative leave, or if the university imposes any disciplinary action or sanction resulting from determinations of sexual harassment, bullying, or gender discrimination.

B. Research Security and Foreign Influence (NSPM-33 Compliance)

Per uniform federal research security guidelines, all senior/key personnel must fully and accurately disclose all sources of current and pending support, foreign components, and foreign organizational affiliations.

Failure to disclose foreign financial support, foreign talent recruitment program participation, or laboratory affiliations on federal disclosures violates institutional regulations and federal law. It triggers an immediate retrospective review and mandatory self-reporting to the federal funding agency.