Instructions for U.S. Department of Education 

Supplemental Information for the SF-424 Application for Federal Assistance

1. Project Director and Applicable Entity Identification Numbers. Name, address, telephone and fax numbers, and e-mail and alternate 

email addresses of the Project Director to be contacted on matters involving this application. Enter Project Director’s level of effort (the 

percentage of time devoted to the grant). Items marked with an asterisk (*) are mandatory. If applicable, you must enter any of the following 

identification numbers that apply: Office of Postsecondary Education Identification (OPE ID(s)); National Center for Education Statistics 

Schools Identification (NCES School ID(s)); National Center for Education Statistics Local Education Agency/School District Identification 

(NCES LEA/School District ID(s)). Provide the relevant number or numbers that are applicable for the institution(s), LEA(s), and school(s) that 

will be served by the proposed project. If you are providing multiple numbers, enter them separated by commas or semicolons. If you are 

applying on behalf of the entire LEA/School District, you do not need to provide the NCES School ID for each school within the LEA/School 

District. Search for the OPE ID code at: College Navigator - National Center for Education Statistics at https://nces.ed.gov/collegenavigator/; 

the NCES School ID at: https://nces.ed.gov/globallocator/; and the NCES LEA/School District ID at: https://nces.ed.gov/ccd/districtsearch/. If 

not applicable, enter “n/a” in the relevant field(s).

2. New Potential Grantee or Novice Applicant. Select N/A if this item is not applicable because the program competition’s notice inviting 

applications (NIA) does not include a definition of either “New Potential Grantee” or “Novice Applicant.” This item is not applicable when the 

program competition’s NIA does not include either definition. If this item is applicable, for (a), check “Yes” if you meet the definition for new 

potential grantees or novice applicants specified in the program competition’s NIA and included on the attached page entitled “Definitions for 

U.S. Department of Education Supplemental Information for the SF-424”. By checking “Yes” the applicant certifies that it meets the new 

potential grantee or novice applicant requirements. Check “No” if you do not meet the definition for new potential grantees or novice 

applicants. For (b), if the program competition NIA is giving competitive preference points for new potential grantees or novice applicants, 

indicate how many points you are claiming for your application. The NIA will indicate how many are available depending on the design of the 

competition. Some competitions may provide more than one category of new potential grantees with differing levels of points.

3. Human Subjects Research. (See I. A. “Definitions” in attached page entitled “Definitions for U.S. Department of Education Supplemental 

Information for the SF-424 form.”)

3a. If Not Human Subjects Research. Check “No” if research activities involving human subjects are not planned at any time during the 

proposed project period. The remaining parts of Item 3 are then not applicable.

3a. If Human Subjects Research. Check “Yes” if research activities involving human subjects are planned at any time during the proposed 

project period, either at the applicant organization or at any other performance site or collaborating institution. Check “Yes” even if the 

research is exempt from the regulations for the protection of human subjects. (See I. B. “Exemptions” in attached page entitled “Definitions for 

U.S. Department of Education Supplemental Information for the SF-424 Application for Federal Assistance.”) 

3b. If Human Subjects Research is Exempt from the Human Subjects Regulations. Check “Yes” if all the research activities proposed are 

designated to be exempt from the regulations. Check the exemption number(s) corresponding to one or more of the eight exemption categories

(Regulation revised in 2018 and became effective in 2019) listed in I. B. “Exemptions.” In addition, follow the instructions in II. A. “Exempt 

Research Narrative” in the attached page entitled “Definitions for U.S. Department of Education Supplemental Information for the SF-424

Application for Federal Assistance.” 

3b. If Human Subjects Research is Not Exempt from Human Subjects Regulations. Check “No” if some or all of the planned research 

activities are covered (not exempt). In addition, follow the instructions in II. B. “Nonexempt Research Narrative” in the attached page entitled 

“Definitions for U.S. Department of Education Supplemental Information for the SF-424 Application for Federal Assistance.”

3b. Federal Wide Assurance Number. If the applicant has an approved Federal Wide Assurance (FWA) on file with the Office for Human 

Research Protections (OHRP), U.S. Department of Health and Human Services, that covers the specific activity, insert the number in the space 

provided. (A list of current FWAs is available at: http://ohrp.cit.nih.gov/search/search.aspx?styp=bsc.) If the applicant does not have an 

approved assurance on file with OHRP, enter “None.” In this case, the applicant, by signature on the SF-424, is declaring that it will comply 

with 34 CFR part 97 and proceed to obtain the human subjects assurance upon request by the designated ED official. If the application is 

recommended/selected for funding, the designated ED official will request that the applicant obtain the assurance within 30 days after the 

specific formal request.

3c. If applicable, please attach your “Exempt Research” or “Nonexempt Research” narrative to your submission of the U.S. Department of 

Education Supplemental Information for the SF-424 form as instructed in item II, “Instructions for Exempt and Nonexempt Human Subjects 

Research Narratives” in the attached page entitled “Definitions for U.S. Department of Education Supplemental Information for the SF-424

Application for Federal Assistance.” 

Note about Institutional Review Board Approval. ED does not require certification of Institutional Review Board approval with the 

application. However, if an application that involves non-exempt human subjects research is recommended/selected for funding, the designated 

ED official will request that the applicant obtain and send the certification to ED within 30 days after the formal request.

No covered human subjects research can be conducted until the study has ED clearance for protection of human subjects in research.

4.Infrastructure Programs. In accordance with section 70914 of the Infrastructure Investment and Jobs Act, the Build America Buy America 

Act (BABAA) requires that grantees funded under the U.S. Department of Education programs that allow funds to be used for infrastructure 
projects, i.e., construction, remodeling, and broadband infrastructure, may not use their grant funds for these infrastructure projects or activities 

unless they comply with the following BABAA domestic sourcing requirements:

 

1.All iron and steel used in the infrastructure project or activity are produced in the United States.

2.All manufactured products used in the infrastructure project or activity are produced in the United States.

3.All construction materials are manufactured in the United States.

If the NIA in section III. 4. “Other” reflects that the program under which an application is submitted is subject to the BABAA domestic 

sourcing requirements, select the item that applies.

Note: The BABAA domestic sourcing requirements only apply to those activities in each application grant proposal related to infrastructure

(specifically, only construction, remodeling, or broadband infrastructure activities). No other projects or costs associated with other proposed 

grant activities are subject to the BABAA domestic sourcing requirements.

For applications with proposed infrastructure projects and activities that are subject to the BABAA domestic sourcing requirements, select the 

type of infrastructure activity (i.e., construction, remodeling, and/or broadband infrastructure), and identify the page numbers from within the 

application narrative where the infrastructure projects or activities are addressed. 

Public Burden Statement:

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless such collection 

displays a valid OMB control number. Public reporting burden for this collection of information is estimated to average 20 minutes per 

response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing 

and reviewing the collection of information. The obligation to respond to this collection is required to obtain or retain benefit (20 USC 3474 

General Education Provisions Act). Send comments regarding the burden estimate or any other aspect of this collection of information, 

including suggestions for reducing this burden, to the U.S. Department of Education, 400 Maryland Ave., SW, Washington, DC 20210-4537 or 

email ICDocketMgr@ed.gov and reference the OMB Control Number 1894-0007. Note: Please do not return the completed ED SF 424 

Supplemental Form to this address.
Definitions for U.S. Department of Education 

Supplemental Information for the SF-424 Application for Federal Assistance

Definitions:

NEW POTENTIAL GRANTEE OR NOVICE APPLICANT

New Potential Grantee: The definition of New Potential Grantee 

is set in the program competition’s Notice Inviting Applications

(NIA). The New Potential Grantee priority is from the 

Department’s Administrative Priorities for Discretionary Grant 

Programs published in the Federal Register March 9, 2020 (85 

FR 13640).

 

Novice Applicant: For discretionary grant programs, novice 

applicant means any applicant for a grant from ED that— 

• Has never received a grant or subgrant under the program 

from which it seeks funding;

• Has never been a member of a group application, submitted 

in accordance with 34 CFR 75.127-75.129, that received a 

grant under the program from which it seeks funding; and

• Has not had an active discretionary grant from the Federal 

government in the five years before the deadline date for 

applications under the program. For the purposes of this 

requirement, a grant is active until the end of the grant’s 

project or funding period, including any extensions of those 

periods that extend the grantee’s authority to obligate funds.

In the case of a group application submitted in accordance with 

34 CFR 75.127-75.129, a group includes only parties that meet 

the requirements listed above. The Novice Applicant priority is 

from 34 CFR 75.225, and it must be included in the program 

competition NIA to be claimed on the form. 

PROTECTION OF HUMAN SUBJECTS IN RESEARCH

I. Definitions and Exemptions

A. Definitions.

A research activity involves human subjects if the activity is 

research, as defined in the Department’s regulations, and the 

research activity will involve use of human subjects, as defined 

in the regulations.

—Research

The ED Regulations for the Protection of Human Subjects, Title 

34, Code of Federal Regulations, Part 97, define research as “a 

systematic investigation, including research development, 

testing and evaluation, designed to develop or contribute to 

generalizable knowledge. Activities which meet this definition 

constitute research whether or not they are conducted or 

supported under a program that is considered research for other 

purposes. For example, some demonstration and service 

programs may include research activities.” 

—Human Subject

The regulations define human subject as “a living individual 

about whom an investigator (whether professional or student) 

conducting research obtains (i) information or biospecimens 

through intervention or interaction with the individual and uses, 

studies, or analyzes the information or biospecimens, or (ii ) 

obtains, uses, studies, analyzes, or generate identifiable private 

information or identifiable biospecimens.” 

If an activity involves obtaining information about a living 

person by manipulating that person or that person’s 

environment, as might occur when a new instructional technique 

is tested, or by communicating or interacting with the 

individual, as occurs with surveys and interviews, the definition 

of human subject is met. If an activity involves obtaining private 

information about a living person in such a way that the 

information can be directly or indirectly linked to that 

individual, the definition of human subject is met. 

Private information includes information about behavior that 

occurs in a context in which an individual can reasonably expect 

that no observation or recording is taking place, and information 

which has been provided for specific purposes by an individual 

and which the individual can reasonably expect will not be 

made public (for example, a school health record).

B. Exemptions.

Research activities in which the only involvement of human 

subjects will be in one or more of the following eight categories 

of exemptions are not covered by the regulations:

(1) Research conducted in established or commonly accepted 

educational settings, that specifically involves normal 

educational practices that are not likely to adversely impact 

students’ opportunity to learn required educational content or 

the assessment of educators who provide instruction. This 

includes most research on regular and special education 

instructional strategies, and research on the effectiveness of or 

the comparison among instructional techniques, curricula, or 

classroom management methods. If an educational practice is 

being introduced to the site and is not widely used for similar 

populations, it is not covered by this exemption.

(2) Research that only includes interactions involving 

educational tests (cognitive, diagnostic, aptitude, achievement), 

survey procedures, interview procedures or observation of 

public behavior (including visual or auditory recordings) if at 

least one of the following criteria is met: (i) the information 

obtained is recorded by the investigator in such a manner that 

the identity of the human subjects cannot readily be ascertained, 

directly or through identifiers linked to the subjects; (ii) Any 

disclosure of the human subjects’ responses outside the research 

would not reasonably place the subjects at risk of criminal or 

civil liability or be damaging to the subjects’ financial standing, 

employability, educational advancement or reputation; or (iii) 

the information obtained is recorded by the investigator in such 
a manner that the identity of the human subjects can readily be 

ascertained, directly or through identifiers linked to the subjects, 

and an Institutional Review Board (IRB) conducts a “limited 

IRB review” to make the determinations required by 34 CFR 

97.111(a)(7). 

If the subjects are children, exemption 2 applies only to 

research involving educational tests and observations of public 

behavior when the investigator(s) do not participate in the 

activities being observed. 

Exemption 2 does not apply if children are surveyed or 

interviewed or if the research involves observation of public 

behavior and the investigator(s) participate in the activities 

being observed. Children are defined as persons who have not 

attained the legal age for consent to treatments or procedures 

involved in the research, under the applicable law or jurisdiction 

in which the research will be conducted.

(3) Research involving benign behavioral interventions in 

conjunction with the collection of information from an adult 

subject through verbal or written responses (including data 

entry) or audiovisual recording if the subject prospectively 

agrees to the intervention and information collection and at least 

one of the following criteria is met: (A) The information 

obtained is recorded by the investigator in such a manner that 

the identity of the human subjects cannot readily be ascertained 

directly or through identifiers linked to the subjects; (B) Any 

disclosure of the human subjects’ responses outside the research 

would not reasonably place the subjects at risk of criminal or 

civil liability or be damaging to the subject’ financial standing, 

employability, educational advancement or reputation; or (C) 

The information obtained is recorded by the investigator in such 

a manner that the identity of the human subjects can readily be 

ascertained, directly or through identifiers linked to the subjects, 

and an IRB conducts a limited IRB review to make the 

determination required by 34 CFR 97.111(a)(7).

For the purpose of this provision, benign behavioral 

interventions are brief in duration, harmless, painless, not 

physically invasive, not likely to have a significant adverse 

lasting impact on the subjects, and the investigator has no reason 

to think the subjects will find the interventions offensive or 

embarrassing. Provided all such criteria are met, examples of 

such benign behavioral interventions would include having the 

subject play an online game, having them solve puzzles under 

various noise conditions, or having them decide how to allocate 

a nominal amount of received cash between themselves and 

someone else.

If the research involves deceiving the subjects regarding the 

nature or purposes of the research, this exemption is not 

applicable unless the subject authorizes the deception through a 

prospective agreement to participate in research in 

circumstances in which the subject is informed that he or she 

will be unaware of or misled regarding the nature or purposes of 

the research. 

(4) Secondary Research for which Consent is not required. 

Secondary research uses of identifiable private information or 

identifiable biospecimens, if at least one of the following criteria 

is men: (i) The identifiable private information or identifiable 

biospecimens are publicly available; (ii) Information, which 

may include information about biospecimens, is recorded by the 

investigator in such a manner that the identity of the human 

subjects cannot readily be ascertained directly or through 

identifiers linked to the subjects, the investigator does not 

contact the subjects, and the investigator will not re-identify 

subjects; (iii) the research involves only information collection 

and analysis involving the investigators’ use of identifiable 

health information when that use is regulated under 45 CFR 

parts 160 and 164, subparts A and E, for the purposes of “health 

care operations” or “research” as those terms are defined at 45 

CFR 164.501 or for “public health activities and purposes” as 

described under 45 CFR 164.512 (b); or (iv) The research is 

conducted by, or on behalf of, a Federal department or agency 

using government-generated or government-collected 

information obtained for nonresearch activities, if the research 

generates identifiable private information that is or will be 

maintained on information technology that is subject to and in 

compliance with section 208(b) of the E-Government Act of 

2002, 44 USC 3501 note, if all of the identifiable private 

information collected, used or generated as part of the activity 

will be maintained in systems of records subject to the Privacy

Act of 1974, 5 USC 552a, and, if applicable, the information 

used in the research was collected subject to the Paperwork 

Reduction Act of 1995, 44 USC 3501 et seq.

(5) Research and demonstration projects that are conducted or 

supported by a Federal department or agency, or otherwise 

subject to the approval of department or agency heads (or the 

approval of the heads of bureaus or other subordinate agencies 

that have been delegated authority to conduct the research and 

demonstration projects), and that are designed to study, 

evaluate, improve, or otherwise examine public benefit or 

service programs, including procedures for obtaining benefits or 

services under those programs, possible changes in or 

alternative to those programs or procedures, or possible changes 

in methods or levels of payment for benefits or services under 

those programs. Such projects include, but are not limited to, 

internal studies by Federal employees, and studies under 

contracts or consulting arrangements, cooperative agreements, 

or grants. Exempt projects also include waivers of otherwise 

mandatory requirements using authorities such as sections 1115 

and 1115A of the Social Security Act as amended.

Each Federal department or agency conducting or supporting 

the research and demonstration projects must establish, on a 

publicly accessible Federal website or in such other manner as 

the department or agency head may determine, a list of the 

research and demonstration projects that the Federal department 

or agency conducts or supports under this provision. The 

research or demonstration project must be published on this list 

prior to commencing the research involving human subjects.

(6) Taste and food quality evaluation and consumer acceptance 

studies, (a) if wholesome foods without additives are consumed 

or (b) if a food is consumed that contains a food ingredient at or 

below the level and for a use found to be safe, or agricultural 

chemical or environmental contaminant at or below the level 

found to be safe, by the Food and Drug Administration or 

approved by the Environmental Protection Agency or the Food 
Safety and Inspection Service of the U.S. Department of 

Agriculture.

(7) Storage or Maintenance for Secondary Research for which 

Broad Consent is required. Storage or maintenance of 

identifiable private information or identifiable biospecimens for 

potential secondary research use if an IRB conducts a limited 

IRB review and makes the determinations requires by 34 CFR 

97.111(a)(8).

(8) Secondary Research for which Broad Consent is Required. 

Research involving the use of identifiable private information or 

identifiable biospecimens for secondary research use if the 

following criteria are met: (i) Broad Consent for the storage, 

maintenance and secondary research use of the identifiable 

private information or identifiable biospecimens was obtained in 

accordance with 34 CFR 97.116(a) (1)-(4), (a) (6) and (d); (ii) 

Documentation of informed consent or waiver of documentation 

of consent was obtained in accordance with 34 CFR 97.117. 

(iii) an IRB conducts a limited IRB review and makes the 

determination that the research to be conducted is within the 

scope of the broad consent referenced in paragraph (d)(8)(i) of 

this section; and (iv) The investigator does not prevent an 

investigator from abiding by any legal requirements to return

individual research results.

II. Instructions for Exempt and Nonexempt Human 

Subjects Research Narratives

If the applicant marked “Yes” for Item 3.b. of the U.S. 

Department of Education Supplemental Information for the SF424 form, the applicant must attach a human subjects “exempt 

research” or “nonexempt research” narrative to the U.S. 

Department of Education Supplemental Information for the SF424 form. If you have multiple projects, include information 

about each, labeling the responses as to the project they address. 

For applications that include multiple research projects this can 

be done in a single narrative or in more than one narrative as 

appropriate. 

A. Exempt Research Narrative.

If you marked “Yes” for item 3.b. and designated exemption 

numbers(s), attach the “exempt research” narrative to the U.S. 

Department of Education Supplemental Information for the SF424 form. The narrative must contain sufficient information 

about the involvement of human subjects in the proposed 

research to allow a determination by ED that the designated 

exemption(s) are appropriate. The narrative must be succinct.

B. Nonexempt Research Narrative.

If you marked “No” for item 3.b. you must attach the 

“nonexempt research” narrative to the U.S. Department of 

Education Supplemental Information for the SF-424 form. The 

narrative must address the following seven points. Although no 

specific page limitation applies to this section of the application,

be succinct.

(1) Human Subjects Involvement and Characteristics: 

Provide a detailed description of the proposed involvement of 

human subjects. Describe the characteristics of the subject 

population, including their anticipated number, age range, and 

health status. Identify the criteria for inclusion or exclusion of 

any subpopulation. Explain the rationale for the involvement of 

special classes of subjects, such as children, children with 

disabilities, adults with disabilities, persons with mental 

disabilities, pregnant women, prisoners, institutionalized 

individuals, or others who are likely to be vulnerable

(2) Sources of Materials: Identify the sources of research 

material obtained from individually identifiable living human 

subjects in the form of specimens, records, or data. Indicate 

whether the material or data will be obtained specifically for 

research purposes or whether use will be made of existing 

specimens, records, or data.

(3) Recruitment and Informed Consent: Describe plans for 

the recruitment of subjects and the consent procedures to be 

followed. Include the circumstances under which consent will 

be sought and obtained, who will seek it, the nature of the 

information to be provided to prospective subjects, and the 

method of documenting consent. State if the IRB has authorized 

a modification or waiver of the elements of consent or the 

requirement for documentation of consent.

(4) Potential Risks: Describe potential risks (physical, 

psychological, social, legal, or other) and assess their likelihood 

and seriousness. Where appropriate, describe alternative 

treatments and procedures that might be advantageous to the 

subjects.

(5) Protection Against Risk: Describe the procedures for 

protecting against or minimizing potential risks, including risks 

to confidentiality, and assess their likely effectiveness. Where 

appropriate, discuss provisions for ensuring necessary medical 

or professional intervention in the event of adverse effects to the 

subjects. Also, where appropriate, describe the provisions for 

monitoring the data collected to ensure the safety of the 

subjects.

(6) Importance of the Knowledge to be Gained: Discuss the 

importance of the knowledge gained or to be gained as a result 

of the proposed research. Discuss why the risks to subjects are 

reasonable in relation to the anticipated benefits to subjects and 

in relation to the importance of the knowledge that may 

reasonably be expected to result.

(7) Collaborating Site(s): If research involving human subjects 

will take place at collaborating site(s) or other performance 

site(s), name the sites and briefly describe their involvement or 

role in the research.

Copies of the Department of Education’s Regulations for the 

Protection of Human Subjects, 34 CFR part 97 and other 

pertinent materials on the protection of human subjects in 

research are available from the Office of the Chief Financial 

Officer, U.S. Department of Education, Washington, D.C. 

20202-4331, telephone: (202) 245-8090, and on the U.S. 

Department of Education’s Protection of Human Subjects in 

Research Web Site: 

https://www2.ed.gov/about/offices/list/ocfo/humansub.html 
NOTE: The State Applicant Identifier on the SF-424 form is 

for State Use only. Please complete it on the SF-424 form in the 

upper right corner of the form (if applicable).