How will SFI disclosures be handled for projects which have “consultants” who are not 91 faculty members? Does the PI need to obtain a temporary 91 NetID for training and disclosures?
Most likely, consultants will not be considered investigators and will therefore not be affected. If consultants, who are not 91 employees, are investigators on a 91 project, they will likely be contracted through their academic institution, rather than personally. The subawardee, whether through purchasing or a subcontract, will be required to have a compliant policy in order to get federal funding. To meet the mandatory training requirement, an investigator who is not 91 personnel could take our training, via a .