NSF Sexual Harassment Reporting - Guidelines for NSF Grant Recipients


It is National Science Foundation (NSF) policy that “all personnel supported by NSF awards must comport themselves in a responsible and accountable manner during the award performance period at awardee institutions, field sites, facilities, conferences, workshops, online and everywhere NSF-funded science and education is conducted.” All personnel supported by an NSF award must remain in full compliance with Willamette University policies, including those on Sexual Misconduct and Discrimination, Harassment, and Hate- or Bias-Motivated Conduct.

The following guidelines have been developed to supplement these institutional policies, and comply with NSF requirements regarding the requirement for the University to report findings of sexual harassment, other forms of harassment, and/or sexual assault. This applies for new NSF awards or funding amendments received on or after the October 21, 2018 date of implementation as well as conduct by those PIs or co-PIs that may have occurred prior to them receiving those awards.


Principal Investigator (PI) - The primary individual responsible for the preparation, conduct, and administration of a sponsored project or program.

Co-Principal Investigator (co-PI) – Key personnel who have responsibilities similar to that of a PI on a sponsored project or program.

Policy Guidelines

In accordance with NSF requirements:

  1. The Office of Grants and Strategic Initiatives will notify NSF if any PI or co-PI is placed on administrative leave or if Willamette University has imposed any administrative action on the PI or any co-PI relating to any finding/determination or an investigation of an alleged violation of awardee policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault. This notification will be submitted to NSF within 10 business days from the date of the finding/determination, or the date of the placement of a PI or co-PI on administrative leave or the imposition of an administrative action, whichever is sooner.
  2. Willamette University will include relevant language in subaward agreements requiring NSF subrecipient organizations to promptly disclose the requisite information to Willamette University, so that the Office of Grants and Strategic Initiatives may report to NSF as required.


  1. The Office of Grants and Strategic Initiatives will provide a list of named PIs and co-PIs on NSF grants to Human Resources, and will update as information changes. Human Resources will add this information to an employee’s record in Workday.
  2. Human Resources will notify the Office of Grants and Strategic Initiatives and the University’s Deputy General Counsel of any finding/determination that a NSF PI or co-PI committed harassment, or was placed on administrative leave, or a relevant administrative action was imposed, within five (5) business days. The following information will be provided.
    1. Type of Notification(finding/determination or administrative leave)
    2. Explanation/Description of Events
  3. Within three (3) business days of receiving notification from Human Resources, the Office of Grants and Strategic Initiatives/Authorized Organizational Representative will submit the required information to NSF’s Office of Diversity and Inclusion via the secure, web-based Organizational Notification Form. The record of submission will be maintained with the grant records, and a copy sent to Human Resources and the Deputy General Counsel.
  4. NSF will contact the SRO/AOR upon receipt and review of the information provided. The AOR will refer NSF to the University’s Deputy General Counsel for further information about the finding/determination or administrative action.
  5. Based on the results of NSF’s review and consultation with the University’s Deputy General Counsel, NSF may elect to impose restrictions or even terminate the award. The Deputy General Counsel will work with the Office of Grants and Strategic Initiatives and Dean of the relevant school to determine management of the relevant grant award.


Status: This policy was approved in 2019
Effective Date: 7/1/2019
Last Review Date: 7/1/2019
Next Anticipated Review: 7/1/2020
Responsible University Administrator: Director of Faculty Research and Resources
Responsible University Office: Office of Grants and Strategic Initiatives

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