Federal awarding agencies (like the National Institutes of Health) are authorized to require non-federal entities (like CSU) to submit certifications and representations. Certifications (Certs) and Representations (Reps) are written guarantees made by entities to sponsoring agencies to comply with various requirements and are required for the conduct of business with the federal government.
Most Federal assistance awards (grants and cooperative agreements) include four basic certifications:
- Certification Regarding Lobbying– Certifies no federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of the federal agency or a Member, officer or employee of Congress, in connection with the award.
- Debarment and Suspension– Certifies that the institution is not presently debarred, suspended, proposed for disbarment, ineligible, or voluntarily excluded from transactions with a federal department/agency.
- Drug-free Workplace– Certifies that the applicant is and will continue to provide a drug-free workplace.
- Certification Regarding Civil Rights Compliance- Certifies programs will be offered to all eligible persons without regard to race, color, national origin, sex, disability, age, political beliefs, religion, marital status, or familial status.
Some agencies and programs might require additional certifications, such as:
- NASA Restrictions on Funding Activities with China
- Certification Regarding Unpaid Federal Tax Liability
- Certification Regarding Criminal Convictions
- Etc.
It is important to understand that when we submit a proposal, we are agreeing to comply with these rules in advance of receiving an award. Additionally, agency certifications and representations are always in a state of flux: being added to, eliminated or modified. Therefore, it is important to carefully review all certifications and representations prior to sign off/submission of a proposal.
For Federal contracts, Colorado State University and other non-federal agencies, maintain FAR (Federal Acquisition Regulations) certifications in the System for Award Management (SAM). When requested to complete contract-related Certs and Reps, SAM is a good place to begin.
For non-Federal sponsors, such as companies, foundations or state agencies, many will request we complete their Certs and Reps, along with additional information about the University (such as year founded, articles of incorporation, etc.). Again, it is important to carefully review material requested to ensure it is congruent with CSU’s ability to comply as a non-profit state institution of higher education.
Bottom Line: When asked to complete, review, or sign Certs and Reps, review information reported by CSU in SAM; carefully review agency/project-specific Certs and Reps, ensure an Authorized Representative has reviewed and signed, and expect this information to change.
Blog post by David Doty, Associate Director, Office of Sponsored Programs, Colorado State University