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Institutions should inform the Agencies about significant changes to their institutional policy for research involving humans and may be required to submit their revised institutional policy for review. Examples of “significant changes” include the following cases:
Institutions should contact the Agencies in case of doubt.
The requirement for a two-stage process for release of funds in Schedule 13 is consistent with the two-stage process already included in Schedule 2 (Ethics Review of Research Involving Humans) and Schedule 3 (Ethical Review of Research Involving Animals). For biohazards, this is a new requirement, and institutions have until January 1, 2009, to implement this process. The approach for the two-stage process for human ethics, animal care and biohazard certification approval is the same. Therefore, in developing the process for biohazards, IBCs may wish to consult with Research Ethics Boards and Animal Care Committees about the two-stage process already in place for those functions.
When Agency funding is provided for research that involves biohazards, and the research involving biohazards will not be undertaken immediately, the project is to be submitted to the IBC to determine at what point in the project review and approval by the IBC will be required. This is the first stage in the process. Funds may then be released on a prorated basis up to the projected date of the work involving biohazards.
It is the responsibility of the researcher to inform the IBC of the date on which the researcher anticipates that s/he will be ready to commence working with biohazards and to undertake to seek review and approval of the IBC prior to commencing that research. It is the responsibility of the institution to ensure that the researcher fulfills that undertaking. The institution’s administration decides on the release of funds when IBC approval has been obtained, and when any other conditions of the grant have been met.
A tracking process should be put in place to record when the research procedures involving biohazards will need to be reviewed and approved by the IBC. Funding of this component of the research can only be released following IBC approval. This is the second phase of the release of funds process. Continuing review and approval for the duration of the project could be considered a third stage of the process.
The two-stage process provides flexibility for the grantee or award holder to begin research activities that do not require immediate review and approval, and ensures that Agency funds can be released and used productively in a timely manner; it provides assurance to the institution and the Agencies that no funding is released for research requiring review and approval until approval has been obtained; and it provides a “heads-up” to the review committee, allowing it to track and plan its work accordingly. It may also provide an opportunity for the committee to flag any potential problem issues to the researcher early on in the process.
Examples include:
Tri-Agency interim measures related to human pluripotent stem cells research are available at Interim Tri-Agency Measures for Human Pluripotent Stem Cell Research. Only human pluripotent stem cells research that conforms to CIHR’s published guidelines found at www.cihr-irsc.gc.ca/e/42071.html is eligible for funding.
The Institutional REB refers to the Institution’s own REB or the REB that the institution has decided to use. An eligible institution can enter into an ethics review agreement with a non-eligible institution or organization that has adopted the TCPS or adheres to the eligible institution’s policy. The institution remains responsible for the ethics review and adherence to the TCPS.
No, the Primary Institution is not required to hold original receipts from the Secondary Institution. The Primary Institution is responsible for consolidating the financial statements (forms 300) from the Secondary Institutions into one Form 300 for each grant, to be submitted to the Agencies for each grant. Secondary Institutions are responsible for retaining receipts for their grant or award expenditures. Primary Institutions must be able to access receipts from non-eligible Secondary Institutions if requested by the Agencies.
Supporting documents must be kept for a period of seven years after each expenditure has occurred for both Primary and Secondary institutions.
The Agencies deal with the Primary Institutions and not with non-eligible Secondary Institutions. It is the responsibility of the Primary Institution to ensure that the letter of transfer of funds agreement clearly outlines the role and responsibilities of the non-eligible Secondary Institution with regard to monitoring and reporting expenses. It is also the responsibility of the Primary Institution to ensure that the monitoring and reporting of expenses by the non-eligible Secondary Institution is done in accordance with the Agencies’ guidelines. The letter of transfer of funds agreement does not discharge the Primary Institution of its responsibilities toward the Agencies.
Yes, the Primary Institution can and should provide the non-eligible Secondary Institution with access to its policies and processes. It should do so as it is a financial management responsibility of the Primary Institution to ensure research carried out under its auspices (i.e. for which it receives grants and awards funds from SSHRC or CIHR) complies with the ethics principles laid out in the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS), and the Canadian Council on Animal Care Guidelines (CCAC). It is recommended that the non-eligible Secondary Institution agrees in writing to: a) comply with the Primary Institution's ethics policies (where appropriate); b) have the Primary Institution do the ethical review of research; and c) submit regular reports to the Primary Institution on the monitoring of that ongoing research. Should research be conducted in another country, the Primary Institution should always perform the ethics review of the research and ensure it also be reviewed by an ethics committee (national, regional or local) in the host country. Provisions of the TCPS must be followed in all cases (please see the TCPS, especially Section 1.H., Review of Research in Other Jurisdictions or Countries, at: www.pre.ethics.gc.ca/english/policystatement/policystatement.cfm.
The letter of transfer of funds agreement must include a clause on the delegation of signing authority for the transferred funds because only the grant or award holder or his/her delegated authority can approve expenses to the grant account.
The Primary Institution is responsible for the appropriate use and monitoring of funds transferred to a Non-eligible Secondary Institution. Since the Agencies deal only with the Primary Institutions, there would be no consequence to the non-eligible Secondary Institution. A transfer of funds agreement without the clause on the delegation of signing authority would be considered non compliant with Agencies’ guidelines.
The provisions for Resolution of Issues of Non-Compliance apply to all second-order transfers (please see Schedule 8: Investigation and Resolution of Breaches of Agency Policies, at www.nserc-crsng.gc.ca/NSERC-CRSNG/Policies-Politiques/MOURoles-ProtocolRoles/8-Breaches-Inobservation_eng.asp).
Yes, this is a risk that a Primary Institution must assume when entering transferring funds to a Non-eligible Secondary Institution and underscores the importance of the transfer of funds agreement. The Primary Institution can minimize its own risk by requiring the Non-eligible Secondary Institution to use the Primary’s policies and processes for certification etc.
However, in the case of transfer of funds between eligible institutions, the responsibilities are shared between both the Primary and Secondary Institution since both have signed an MOU with the Agencies and agreed to follow the Agencies’ guidelines.
Allowing the transfer of funds to non-eligible Secondary Institutions through a transfer of funds agreement facilitates collaboration while ensuring that the appropriate controls are in place. The Primary and Non-eligible Secondary Institutions need to work together to maximize the benefits of their collaborations and minimize the risks. However, there must be an adequate level of accountability to the Agencies and that is achieved through the MOU between the eligible institutions and the Agencies. There is no such agreement between the Agencies and non-eligible institutions.
Yes, unused transferred funds can be carried forward for the period of the grant as long as the Primary Institution follows the requirements of the Agency and grant program. Any remaining funds after that period must be returned to the Primary Institution. This must be addressed in the letter of transfer of funds agreement.
This will help to increase awareness, at the Non-eligible Secondary Institution, of the purposes for making the grant or award and of any constraint on its use.
An accountable advance is considered to be a payment made under the terms of the original award. A specific amount of limited funding is transferred to a Secondary Institution for an explicit purpose, a specific time frame and with specific conditions. These details are outlined in an Accountable Advance Letter. The Secondary Institution must provide the Primary Institution with receipts and a completed Form 300.
All letters of agreement must adhere to Schedule 9 by January 1, 2009 at the latest. This may require amendments or addendums to current letters of agreement. Consult Part B for guidance.
Yes, the Agencies publish the steps to be taken when there is a change in a Researcher’s eligibility status. Specific requirements vary according to program:
The Agencies will commence termination procedures as outlined in these documents:
Note: “Research reports” in this FAQ refer to both progress and final reports.
Research activity reports (progress or final) are required for some grants. For more specific reporting requirements, consult the appropriate program literature:
CIHR | Grants and Awards Guide and program literature | |
NSERC | Program Guide for Professors – Overview and program literature | |
SSHRC | Using Your Funds |
Institutions are expected to support adherence to the relevant Agency’s reporting requirements by facilitating the provision of the required information and, by ensuring that grant holders have sufficient time to complete the required reports.
No, the Agencies will not cover these types of costs. The Indirect Cost Program provides funding for administrative support.
The Agencies support in principle the provision of final research reports to the Institutional research office. However this remains at the discretion of each Institution.
CIHR advises institutions in writing of late and unsatisfactory research reports from their researchers since both of these have an impact on the institution. In the case of unsatisfactory progress reports, CIHR will cancel all subsequent commitments and the grant holder will be requested to submit a complete renewal application at the next competition. For more information, consult the subsection titled "Progress Report for Long-Term Grant Holders (5 or more years)" in the CIHR Grants and Awards Guide www.cihr-irsc.gc.ca/e/22632.html#3-B8.
Researchers must submit a research report in order to re-apply to the SSHRC Standard Research Grants program. SSHRC advises institutions of late final research reports.
NSERC’s requirements for research reports vary by program. NSERC advises Institutions of any action it may take as a result of late or unsatisfactory reports. NSERC follows up with a letter to the researcher with a copy to the Research Grant Officer (RGO).
Facilities are research resources that include groupings of equipment and/or equipment-based specialized services.
Yes, institutions can put in place an agreement on the sharing of equipment with co-applicants if they believe it is required.
Equipment purchased with Agency funds is the property of the Institutions. Thus, requests for transfer of equipment should be evaluated and decided upon by the Institution, with the goal of maximizing the use of the equipment for research and for the benefit of Canada.
Please also refer to the Tri-Agency Financial Administration Guide under Administrative Matters; Ownership of Items Purchases or Collected With Agency Funds and Moving Equipment, Material or an Unexpended Equipment Grant (www.nserc-crsng.gc.ca/Professors-Professeurs/FinancialAdminGuide-GuideAdminFinancier/AdminMatters-QuestionAdmin_eng.asp).
The Agencies assume that general institutional insurance will cover some equipment or facilities. However, it is the responsibility of the institution to ensure that additional coverage is in place to safeguard the equipment or facilities that are not covered by the general institutional insurance policy.
The guide is available electronically at: www.phac-aspc.gc.ca/ols-bsl/lbg-ldmbl/index.html. Alternatively, paper copies may be requested by contacting the Public Health Agency at biosafety_biosecurite@phac-aspc.gc.ca. Note that CIHR, NSERC, and SSHRC do not provide paper or electronic copies of the Public Health Agency of Canada’s Laboratory Biosafety Guidelines.
Research must be conducted in accordance with any regional biosafety guidelines or regulations. If regional guidelines or regulations differ from those of the Public Health Agency of Canada, the more stringent prevail.
Research performed outside of Canada with funds from one or more of the Agencies must be conducted in accordance with the host country’s laboratory biosafety guidelines or regulations. However, if the host country does not have any in place or if their guidelines/regulations differ from Canada’s, the most stringent prevail.
If research conducted outside of Canada appears to be, or, is found to be in non-compliance with Agency policy under this Schedule, the Agency will follow the procedures described in Schedule 8: Investigation and Resolution of Breaches of Agency Policies (www.nserc-crsng.gc.ca//NSERC-CRSNG/Policies-Politiques/MOURoles-ProtocolRoles/8-Breaches-Inobservation_eng.asp).
The Schedule recognizes the different levels of risk and containment set out in the Public Health Agency of Canada’s Laboratory Biosafety Guidelines.
An effective Institutional COI Policy may contain the following elements:
The relevant schedules are the following:
Schedule 2: Ethics Review of Research Involving Humans
Schedule 3: Ethical Review of Research Involving Animals
Schedule 4: Integrity in Research and Scholarship
Schedule 14: Conflicts of Interest in Research
Although these schedules are related, they are sufficiently different and individually important enough to warrant a schedule on each topic. Schedules 2 and 3 address the specific certification policies and requirements for research involving humans and animals, respectively. Schedule 2 is related to the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans. Schedule 3 refers the policies of the Canadian Council on Animal Care (CCAC).
Schedule 4 deals only with the Tri-Council Policy Statement: Integrity in Research and Scholarship which addresses very specific instances of scientific misconduct involving falsification and fabrication of data, plagiarism and conflict of interest. Schedule 14 addresses the need for Institutional policies on conflict of interest in research.
These schedules are all related given that they all outline the roles and responsibilities of both the Institutions and the Agencies in ensuring that research meets the highest scientific and ethical standards. They are further supported by Schedule 8: Investigation and Resolution of Breaches of Compliance, which sets out the procedure for dealing with circumstances of non-compliance with Agency policy. A single case of misconduct could involve the breach of more than one schedule.
Agencies will work on both the focus and timing of all funding announcements in collaboration with Institutions and, when warranted, the relevant Minister’s office, in order to maximize media interest and thereby ensure the highest possible public profile.
Both Agencies and Institutions acknowledge that announcements require the active participation of the funded researcher(s) to help attract support for Agencies, Institutions and the Government's investment in research.
In planning events for large-scale funding announcements, Agencies and Institutions will work together to develop a strategy for the announcement that takes into consideration the requests and circumstances of all parties.
Agencies and Institutions will work collaboratively to promote government-funded research and will recognize, in their public announcements, each others’ efforts and contributions.
Agencies and Institutions recognize the cost of organizing and hosting an event that profiles federally-funded research. Therefore, the Agencies and Institutions involved should discuss cost-sharing early in the planning stages of any such event.
The Agencies have specific guidelines for Grant and Award Holders regarding public communication and acknowledgement. Institutions can play an important role in helping to implement these guidelines. Below are links to the respective Agencies’ guidelines:
CIHR – Grants and Awards Guide ( www.cihr-irsc.gc.ca/e/805.html)
CIHR – Communicating the Value of Health Research: CIHR Guidelines on Public Communication ( www.cihr-irsc.gc.ca/e/30789.html)
NSERC – General Guidelines for the Public Announcement of Major NSERC Awards (www.nserc-crsng.gc.ca/_doc/NSERC-CRSNG/announce-annonce_eng.pdf)
SSHRC – Grant Holders Guide ( www.sshrc.ca/web/using/using_e.asp)
All publications, documents, and events intended for the general public, media or parliamentarians that announce Agency research grants, scholarships, fellowships and prizes, or the results of research or activities supported by Agency grants and awards, require acknowledgement of Agency support.
Any publication, document, item or event that recognizes an Agency grant or award, or the results of the grant or award, must include the Agency’s logo. The Agencies must be notified in advance so that the Agencies and Institutions can work together to ensure the appropriate use of logos.
SSHRC’s logo and guidelines for usage are available at www.sshrc-crsh.gc.ca/web/logo/. Placement of the logo must be approved by SSHRC’s Communications division.
Please contact CIHR Media Relations at 613-941-4563 or mediarelations@cihr-irsc.gc.ca to obtain a copy of the logo and placement guidelines.
NSERC’s Logo and guidelines for usage are available at:
http://www.nserc-crsng.gc.ca/NSERC-CRSNG/VisualIdentity-IdentiteVisuelle_eng.asp.
When research results are accepted for publication, Institutions and Agencies determine together whether there is likely to be sufficient public interest to disseminate the results to the media, the general public, and parliamentarians.
Research results are usually communicated through a news release or a web posting by Institutions and/or Agencies.
CIHR
CIHR Media Relations
Tel: 613-941-4563
E-mail: mediarelations@cihr-irsc.gc.ca
SSHRC
SSHRC Communications
613-992-0691
E-mail: communications@sshrc.ca
NSERC
NSERC Public Affairs
613-996-7238
E-mail: comm@nserc-crsng.gc.ca