Regulatory and Ethical Compliance
- Adherence to all terms and conditions outlined in the NIH Grants Policy Statement.
- Compliance with 2 CFR Part 200, 'Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards'.
- Compliance with all applicable nondiscrimination laws, including submitting an 'Assurance of Compliance (HHS-690)'.
- Institutional Review Board (IRB) or Independent Ethics Committee (IEC) approval required for human subjects protocols, and NIH must receive copies of major changes.
- Mandatory disclosure of violations of federal criminal law involving fraud, bribery, or gratuity potentially affecting the federal award.
Data Management and Security
- Compliance with the 2023 NIH Policy for Data Management and Sharing; a Data Management and Sharing Plan must be implemented.
- If applicable, health IT used must meet standards in 45 CFR part 170, Subpart B, or be ONC Health IT Certified.
- Plans and procedures modeled after the NIST Cybersecurity framework are required for recipients/subrecipients with ongoing access to HHS information/operational technology systems or PII/PHI obtained from HHS.
Intellectual Property (IP) and Regulatory Considerations
- A preliminary IP and regulatory strategy is a mandatory application component. Applications without this attachment are considered incomplete and will not be peer-reviewed.
- The strategy should address how known IP constraints will be managed and should reflect consultation with institutional technology transfer officials.
- For projects repurposing currently marketed or under-development therapies, a letter of support from the manufacturer for the new indication is required at the time of application or as post-submission material.
Special Programmatic Requirements
- Accelerator Partner Requirement: Applicants must secure and include a letter of support from an 'Accelerator Partner'. This partner provides essential expertise and mentoring in areas like product development, commercialization, market analysis, regulatory submissions, IP protection, and reimbursement strategy. This partner can contribute to the required matching funds but is not obligated to.
- Cost Matching Expectation: A minimum of a 0.25:1 non-Federal cash match of the Federal direct costs requested is expected. Institutions must document actual contributions.
- Project Management: Applicants are expected to utilize formal project management processes and identify a team member responsible for this function. The Catalyze Coordinating Center offers resources and support for project management.
- Milestone-Driven Progress: Proposed activities must be organized with specific, measurable, achievable, relevant, and time-bound (SMART) milestones. Progress will be rigorously monitored against these milestones, influencing annual non-competing award decisions.
- Clinical Trial Exclusion: This NOFO explicitly states 'Clinical Trial Not Allowed', meaning projects proposing clinical trials will be considered non-responsive.
Unique Aspects
- The grant encourages strategic alignment by requiring a strong biological rationale and preliminary data, coupled with a focus on novel targets and significant improvements over existing therapies.
- Emphasizes the translation of basic science discoveries into treatments for HLBS diseases, bridging the gap between early research and preclinical development.