By May 1, 2025, the Compliance Questions section of the SpartaGrants Funding Proposal will include:
- A new Foreign Component question;
- A new section of questions regarding Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP); and
- Revisions to the Export Control questions.
Foreign Component Question
The SpartaGrants Compliance Questions will now ask: Does this project have a foreign component? If yes, list the country/countries?
A foreign component is defined as the performance of any significant element or segment of a project outside the United States, either by the grantee or by a researcher employed by a foreign institution, regardless of whether grant funds are expended. Activities that meet this definition can include:
- Subcontract to a foreign institution;
- Collaborations with investigators at a foreign site that result in co-authorship;
- Use of facilities or instrumentation at a foreign site;
- Receipt of financial support or resources from a foreign entity;
- Extensive foreign travel by grantee project staff for data collection, surveying, sampling, and similar activities (note that foreign travel for consultation is not considered a foreign component);
- The involvement of human subjects or vertebrate animals at a foreign site;
- Extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling and similar activities; or
- Any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.
DURC/PEPP Questions
The new policy for DURC/PEPP has expanded to include two categories of research. The questions added to SpartaGrants summarize the types of agents that are included in the scope of Category 1 and Category 2 research.
- Are select agents or toxins (any quantity), or any risk group 4 agent, or a non-exempt risk group 3 agent involved in this project?
- If you answer yes, you’ll be given the next question: Based on the PI Self-Assessment form, are any of the experimental outcomes defined in the USG DURC/PEPP Policy expected or possible?
- Is a pathogen with pandemic potential (PPP), or any pathogen that will be modified in such a way that is reasonably anticipated to result in a PPP involved in this project?
- If you answer yes, you’ll be given the next question: Based on the PI Self-Assessment form, are any of the experimental outcomes defined in the USG DURC/PEPP Policy expected or possible?