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Supporting Statement A

ICR 202605-0925-003 · OMB 0925-0777 · Object 170080800.

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File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement A
SubjectSupporting Statement A
AuthorLopez, Maria (NIH/NICHD) [E]
Last Modified ByWriter
File Modified2026-06-17
File Created2026-06-19
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Supporting Statement A for
                    
NIH Extramural Harassment Web Form (OD/OER)
OMB #0925-0777, exp., date 03/31/2026
               
Date: April 21, 2026
Submission Type: Reinstatement without change 
Federal Government Employee Information:
Patricia Valdez, PhD
Office of Extramural Research
National Institutes of Health
6705 Rockledge Dr, Room 705-C
Bethesda, MD 20892 
Telephone: 301-451-2160
Email: [email protected]



Table of contents
A.	ABSTRACT	
A.1	Circumstances Making the Collection of Information Necessary	
A.2.	Purpose and Use of the Information COLLECTION	
A.3	Use of Information Technology and Burden Reduction	
A.4	Efforts to Identify Duplication and Use of Similar Information	
A.5	Impact on Small Businesses or Other Small Entities	
A.6	Consequences of Collecting the Information Less Frequently	
A.7	Special Circumstances Relating to the Guidelines of 5 CFR 1320.5	
A.8	Comments in Response to the Federal Register Notice and Efforts to Consult Outside Agency	
A.9	Explanation of Any Payment of Gift to Respondents	
A.10	Assurance of Confidentiality Provided to Respondents	
A.11	Justification for Sensitive Questions	
A.12	Estimates of Hour Burden Including Annualized Hourly Costs	
A.13	Estimate of Other Total Annual Cost Burden to Respondents or Record  keepers	
A.14	Annualized Cost to the Federal Government	
A.15	Explanation for Program Changes or Adjustments	
A.16	Plans for Tabulation and Publication and Project Time Schedule	
A.17	Reason(s) Display of OMB Expiration Date is Inappropriate	
A.18	Exceptions to Certification for Paperwork Reduction Act Submissions	
Attachments (save file names to match what is being referenced: (ex: x.baseline; y.screener)



ATTACHMENTS

    1. Extramural Harassment Web Form 
    2. PIA for eRA


A. Justification (Abstract)
This is a reinstatement request without changes to continue collecting information about possible concerns regarding harassment, bullying, retaliation or hostile working conditions. The NIH Grants Policy Statement Section 4 outlines that NIH recipient institutions are expected to provide safe and healthful working conditions for their employees and foster work environments conducive to high-quality research, regardless of the recipient institution. The Consolidated Appropriations Act, 2022 (Public Law 117-103), Division H, Title II, Section 239 requires that, “[t]he Director of the National Institutes of Health shall hereafter require institutions that receive funds through a grant or cooperative agreement during fiscal year 2022 and in future years to notify the Director when individuals identified as a Program Director or Principal Investigator (PD/PI) or as Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions.” Therefore, NIH recipient institutions are required to notify NIH when individuals identified as PD/PI or other Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined by the recipient institution due to concerns about harassment, bullying, retaliation or hostile working conditions. The secure Harassment Web Form will be used to collect notifications from institutional Authorized Organization Representatives (AORs) which must include, at a minimum, the name of the AOR submitting the notification, the name of the individual of concern, a description of the concerns, the action(s) taken, and any anticipated impact on the NIH-funded award(s). 
A.1	Circumstances Making the Collection of Information Necessary
NIH supports safe and respectful work environments that are free from harassment, including sexual harassment, discrimination, or other forms of inappropriate conduct that can result in a hostile work environment. The Consolidated Appropriations Act, 2022 (Public Law 117-103), Division H, Title II, Section 239 requires that, “[t]he Director of the National Institutes of Health shall hereafter require institutions that receive funds through a grant or cooperative agreement during fiscal year 2022 and in future years to notify the Director when individuals identified as a PD/PI  or as Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions.” A dedicated web form will protect the sensitive information submitted to NIH by institutions and will allow NIH to take appropriate action to protect the research and research funds while working with the recipient to ensure that work is being conducted in a safe and healthful environment. 
A.2    Purpose and Use of the Information Collection
The Harassment Web Form will continue to be used to collect the required notifications from recipient institutions when individuals identified as PD/PI  or as Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions. Information in these notifications will be used by a limited number of staff in the NIH Office of Extramural Research (OER) to work with recipient institutions to ensure  …to inform NIH institutes and centers in a confidential manner when recipients plan to request grant actions and to work with institutions to gain a better understanding about whether concerns shared with NIH will impact the PD/PI or Senior/Key  personnel's ability to continue as the scientific lead of the project, NIH will require prior approval for a replacement PD/PI or Senior/Key personnel. The Harassment Web Form will allow institutions to report to NIH in a secure and confidential manner and only the relevant details will be shared with those who have a need to know, which may include grants management staff at the funding institute who need to approve and process requests to change the PD/PI or Senior/Key personnel on grants or take other grant actions. For the past three years, we have used the webform as planned. The pros are the ease in use and rapid communication with NIH staff; while the cons are that only one respondent may be named during the initial submission. We intend to continue to use the webform as planned.  
A.3     Use of Information Technology and Burden Reduction
Notifications by recipient institutions about individuals identified as PD/PI or as Key/Senior personnel in an NIH notice of award removed from their position or are otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions will be submitted electronically into a secure Web Form that is part of the Electronic Research Administration (eRA) system and the associated eRA NIH Privacy Impact Assessment (PIA): P-9218201-570012 (see attachment 2). Use of the online Harassment Web Form will reduce the time and burden for institutional officials to notify NIH in comparison to using a paper-based collection.
A.4	Efforts to Identify Duplication and Use of Similar Information
Use of the Harassment Web Form to contact NIH will avoid the duplication in effort that would arise when recipient institutions would be required to notify multiple NIH funding institutes or centers (ICs) of removal or disciplinary action involving PD/PIs or other Senior/Key Personnel. The Harassment Web Form will collect information in a confidential manner and OER staff will share details of the notification with NIH IC staff on a strict need-to-know basis. For example, if the notification provided by the recipient institution includes details of an investigation and indicates that prior approval will be requested from the funding IC to change the PD/PI, OER staff will communicate specific information in a confidential manner to the funding IC indicating that the recipient institution has notified OER of removal or disciplinary action involving PD/PIs or other Senior/Key Personnel and will contact the funding IC for any required prior approvals or requests. This process will protect sensitive information shared by the recipient institution. There is no similar resource that could be modified at the NIH that would be able to collect the appropriate sensitive information from extramural institutions. 
A.5	Impact on Small Businesses or Other Small Entities
The Harassment Web Form collection method will not cause an additional impact on small businesses or other small entities. Grant recipients must comply with the law, and the Harassment Web Form will reduce burden.

A.6	Consequences of Collecting the Information Less Frequently
As stated in the NIH Notice, NOT-OD-22-129, “recipient institutions are required to notify NIH when individuals identified as PD/PI or other Senior/Key personnel in an NIH notice of award are removed from their position or are otherwise disciplined by the recipient institution due to concerns about harassment, bullying, retaliation or hostile working conditions. Notification must be provided by the Authorized Organization Representative within 30 days of the removal or disciplinary action and must be submitted to NIH through a dedicated web form.” The Harassment Web Form will allow recipient institutions to comply with the law in a timely manner and allow NIH to move quickly when notified of the above situations which may require grant actions to protect the research, funds, and the work environment.
A.7	Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
Due to the need for recipients and NIH to act quickly when a PD/PI or other Senior/Key personnel is removed from their position or otherwise disciplined, notifications to NIH must occur on a regular basis, more often that quarterly. Recipients must notify NIH within 30 days of the removal or disciplinary action. 

A.8.1	Comments in Response to the Federal Register Notice 

This proposed information collection was previously published in the Federal Register on March 12, 2026 vol. 91, No. 48, Notices 12203   No public comments were received.  
A.8.2	Efforts to Consult Outside Agency

N/A
A.9	Explanation of Any Payment of Gift to Respondents
Respondents will not receive payments or gifts.
A.10	Assurance of Confidentiality Provided to Respondents
Notifications from respondents (grant recipients) must include, at a minimum, the name of the Authorized Organization Representative (AOR) submitting the notification, the name of the individual of concern, a description of the concerns, the action(s) taken, and any anticipated impact on the NIH-funded award(s). The information will also include the name of the institution where the AOR and individual of concern are employed, and contact information for the AOR, including institutional email address and phone number. This information will be used by OER to confirm the identity of the reporting AOR. NIH treats sensitive information as confidential information in accordance with the  NIH Grants Policy Statement (NIH GPS) Section 2.3.11.2.  Such information is subject to the Privacy Act; therefore, the reports will not be made public and will be maintained in our records.

A.11	Justification for Sensitive Questions

No sensitive questions are being asked.


A.12.1	Estimates of Hour Burden Including Annualized Hourly Costs
 Estimates of the number of responders is based on past experience of the number of notifications OER has received from grant recipients over the past year (2025). We estimate that the number of notifications from recipient institutions will increase with the requirements of the new law.

Table 12-1 Estimated Annualized Burden Hours
				                         

	









A.12-2   Annual Cost to respondent

    	

Type of Respondents
Total Annual Burden Hours
Hourly Respondent Wage Rate*
Respondent Cost

Private Sector 
60
$32.66
$1,959.60




TOTAL


$1,959.60
*Bureau of Labor Statistics: All occupations rates were obtained from thehttps://data.bls.gov/oes/#/industry/000000 



A.13	Estimate of Other Total Annual Cost Burden to Respondents or Record Keepers
Not applicable.
A.14	Annualized Cost to the Federal Government  

 Cost Descriptions

Grade/Step
Salary**
% of Effort
Fringe (if applicable)
Total Cost to Gov’t
Federal Oversight





Web Form development 
GS-14/4
$ 158,306
10

$15,831
Web Form maintenance 
GS-14/4
$ 158,306
5

$7,915 
Intake and review
GS-14/9
$ 182,295
50

$91,148
Privacy Lead
T42
$228,000
5

$11,400
Contractor Cost











Travel 





Other Cost











Total




$125,844
**the Salary in table above is cited from https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2026/DCB.pdf 

A.15	Explanation for Program Changes or Adjustments
There are no program changes or adjustments.  This is being submitted as a reinstatement without changes
A.16	Plans for Tabulation and Publication and Project Time Schedule
Not applicable.
A.17	Reason(s) Display of OMB Expiration Date is Inappropriate
The OMB control number will be displayed (expiration date).
A.18	Exceptions to Certification for Paperwork Reduction Act Submissions
 None