RAIN Notes – March 2022

NSF 2-Month Rule

NSF policy references a 2-month cap on salary for senior personnel paid from NSF grants. This is general guidance, so at time of submission, salary in excess of two months can be requested if disclosed in the proposal budget and budget justification. For a project that has already been awarded, ECU has internal budgeting authority to increase person months devoted to a project beyond the two-month salary policy. No prior approval from NSF is needed if there is no change to project objectives and scope.​

This issue was recently discussed at a RAIN meeting. For more information, see that slide presentation.


Foreign Influence on Research

The US Government has implemented procedures designed to detect undue foreign involvement in federally funded research. While federal actions in this area are evolving (see next item), some agencies have taken specific actions worth reviewing.

Investigators pursuing federal funding are required to disclose a broader range of collaboration with foreign entities – beyond what has previously been required in Biosketches and Current and Pending Support. In some circumstances, failure to disclose may involve civil and/or criminal penalties for the investigator. There is also new guidance on budget preparation and related proposal elements.

Additional info on this issue is available at https://rede.ecu.edu/cmsi/index/strategic-initiatives/foreigninfluence/


Evolving Federal Approach to Foreign Influence

Even as federal agencies are adopting specific policies, the overall federal approach to foreign influence on research is changing. A recent article in Science explores the issue.

See – https://www.science.org/content/article/controversial-u-s-china-initiative-gets-new-name-tighter-focus-industrial-espionage


OIG Audit Report

Federal audit processes drive a lot of compliance decisions at universities – it is important to know what auditors are looking for and finding. This article is a concise summary of common recent findings.

See – https://www.jdsupra.com/legalnews/and-now-for-some-positive-news-oig-7177679/


NCURA Webinars (Free) – Federal Updates – 17 March

On 17 March, NCURA will host webinars with updates from the Office of Management and Budget (OMB), National Science Foundation (NSF), and National Institutes of Health (NIH). If you work with one of these agencies, this is a “can’t miss” webinar!

  • OMB – 11:00 – 12:15 – Presented by Gilbert Tran
  • NSF – 2:00 – 3:15 – Presented by Jean Feldman
  • NIH – 3:45 – 4:45 – Presented by Michelle Bulls

E-mail cmsi@ecu.edu for your free login!


March RAIN Meeting – 23 March

RAIN meetings take place on the 4th Wednesday of the month. This meeting may already be on your calendar. If not, contact CMSI to be added.


The Research Administrator’s Information Network (RAIN) is an open forum for ECU personnel interested in research administration issues. There are monthly RAIN meetings, a Microsoft Team, Grant Alerts, and these monthly issues e-mail. If you would like to be included in RAIN meetings and receive additional RAIN information, click here.