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  5. When is Research Congruency Review Required?

Compliance

Dr. Laura Gutierrez
Senior Compliance Specialist
lgutierrez@uh.edu
713-743-1897

When is Research Congruency Review Required?

Congruency review is required for:

  • Public Health Service (PHS) agencies and other federal sponsors. Congruency review is required for PHS agencies and other federal sponsors, such as, the National Science Foundation, Department of Veterans’ Affairs, and Department of Defense.
  • Department of Defense requires a side-by-side match of its awards, UH protocols, and DoD ACUROs. In order to assist the investigators with the DoD’s side-by-side review, the DOR RIO congruency confirmation of DoD awards will be less flexible than for other awards. Please note: DoD agencies require that their ACURO approve UH’s protocol before the work can begin. ACURO approval is the final requirement prior to DOD funding activities taking place.
  • Subawards to UH from an Applicant or Grantee Institution (a.k.a. Recipient or Prime Awardee). If the grantee institution plans to issue a subaward to UH which includes the performance of live vertebrate animal work or human subjects research funded by a federal sponsor, a congruency review will be performed between the scope of work included in UH’s subaward application to the grantee institution and the UH protocol(s).
    • In order to perform a congruency review, a copy of the FULL proposal and/or Scope of Work from the grantee institution’s grant application may be necessary. RIO will work with the UH PI to obtain this information.
    • The grantee Institution may request UH’s assurance of congruency for UH’s scope of work.
    • The grantee Institution may request the UH IRB or IACUC protocol covering the proposed human subjects or animal work, the date of IRB or IACUC protocol approval, the protocol approval letter.

Congruency review is NOT required for:

  • Training Grants. Congruency reviews are not required for fellowships or training grant applications that have budgets containing only stipend support (funds for human subjects or animal research are not included).
  • Internal (University) funds used to support human subjects or animal research are not subjected to a congruency review. Internal funds include unrestricted departmental accounts or a PI’s start-up package.
  • Subawards issued by UH to a Subrecipient Institution (a.k.a. Consortium or Collaborating Institution). UH relies on the subrecipient institution to conduct a congruency review using its own protocol(s) and the scope of work submitted to UH as part of the subrecipient’s subaward application to UH. If the subrecipient is not a participant in the FDP Pilot (FDP Expanded Clearinghouse website), they will complete a Subrecipient Information and Compliance (SIC) form, which OSP and OARS will review.