Regulatory and Legal Compliance
- Federal Regulations: Compliance with 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) and 42 CFR Part 52.
- NIH Grants Policy Statement: Adherence to all terms and conditions outlined in the NIH Grants Policy Statement.
- Non-discrimination Laws: Recipients must comply with all applicable non-discrimination laws, as agreed upon during SAM.gov registration, and submit an Assurance of Compliance (HHS-690).
- Mandatory Disclosure: Recipients must disclose any violations of federal criminal law involving fraud, bribery, or gratuity potentially affecting the federal award.
Data Management and Security
- Data Management and Sharing Plan (DMS Plan): Required for all applications planning research that generates scientific data, consistent with the 2023 NIH Policy.
- Health IT Standards: If acquiring or upgrading health IT, it must meet standards and implementation specifications adopted in 45 CFR part 170, Subpart B.
- Certified Health IT: For eligible clinicians in ambulatory settings or hospitals, use health IT certified under the ONC Health IT Certification Program.
- Cybersecurity: Recipients with ongoing access to HHS information systems or who handle Personally Identifiable Information (PII) or Personal Health Information (PHI) obtained from HHS must develop plans and procedures modeled after the NIST Cybersecurity framework.
Research and Ethical Standards
- Human Subjects Protection: Strict adherence to protections for human subjects. Institutional Review Board (IRB) or Independent Ethics Committee (IEC) approval is required for all protocols.
- Data and Safety Monitoring: Required for all NIH-funded human biomedical and behavioral intervention studies (clinical trials) to ensure participant safety and data integrity.
- Investigational Products: Clinical research involving investigational therapeutics, vaccines, or devices must be performed under an FDA investigational new drug (IND) or investigational device exemption (IDE), if applicable.
Unique Aspects and Strategic Considerations
- Planning Grant (R34): This mechanism is specifically for obtaining information necessary and sufficient to plan a future clinical trial, not to conduct the full trial itself. The R34 research must directly inform the final development of a clinical trial.
- Clinical Trials Optional: Applicants can propose projects that do or do not include clinical trials; however, the R34 specifically focuses on planning for a future trial.
- Focus on High-Risk Groups: Strong encouragement for research targeting specific high-risk groups for alcohol-related HIV/AIDS acquisition/transmission (e.g., MSM of color, commercial sex workers, HIV-serodiscordant couples, pregnant women living with HIV, victims of trauma/violence, individuals newly-released from incarceration).
- Syndemic Approach: Encourages addressing the role of critical health disparities by incorporating co-occurring disorders and contributory conditions like intimate partner violence, sexual assault, homelessness, discrimination, and stigma.
- Community-Based Participatory Research: Embraces a partnership approach involving community members, organizational representatives, and researchers.
- Innovation: Encourages innovative measurement, analytic approaches, communication strategies, and technological approaches (e.g., mHealth).
- Risk Tolerance: While focused on planning, the grant acknowledges and expects risk management in human subjects research and data handling.
- Geographic Priority: Encourages research congruent with the 'Ending the Epidemic' (EHE) strategic plan, particularly in US HIV/AIDS 'hot spots' like the US South.