“Do’s, Don’ts and Some

Suggestions for Managing your Grant Sponsored Research

November 16 & 17, 2011 Gordon Cannon

“In the conduct of research and other sponsored programs, all faculty members have the right to academic freedom as outlined by the University Faculty Handbook. Faculty members have the right to conduct research and scholarly activities and to disseminate the results of their work without suppression or modification by external sponsors.

Along with these freedoms come corresponding Along with these freedoms come corresponding responsibilitiesresponsibilities.

It is important to adhere to both the spirit and the letter of Research Policies”

Paraphrased from Seton Hall PI Handbook

• Start early!!!

• Request For Proposals (RFP)

• Meet with Sponsored Program Administration (SPA)• Make sure they have RFP• Get them the best guess for a budget early as possible

I suggest in a month or so before

• Budget Justification - Give this much thought - Even if not required I suggest you prepare one

Project & Proposal Development

Human subjects - IRB

Animal welfare - IACUC

Biological hazard - IBC

Radiological Control - IRC

Export Control – Lynn Landrum (I’ve called to speak to you about your torpedo)

FCOI Disclosure

Check list items

Reduce your stress get it moving early--- It takes time at each step Always assume something will go wrong - i.e.

signature authority not available

Approved IAF and budget must be at SPA 5 working days before deadline

Feel free to tinker with narrative as close to deadline as you need – But budgets and approvals must be at SPA 5 days prior to deadline

Approval Chain

Things to consider that often delay the IAF:

1.Academic Release time negotiation with Chair and Dean.

Office of VPR does not recommend 100% release

2.Facilities and Administrative Costs (F&A Costs) issues AKA indirects or overhead. On campus 46.5% MTDC Off Campus 28% 3.Unless disallowed by the granting agency full F&A is expected: Waiver or reduction requires approval of VPR in consultation with Chair, Director and Dean of Unit. So IAF chain is a little different

Only in exceptional circumstances will F&A be reduced or waived

1.Institutional Matching-If matching required clear with VPR well in advance of deadline

•Sub-awardee budget and institutional approval

Paper based - Consider mailing time, number of copies, etc.

Most all are now submitted electronically - Grants.gov or NSF Fastlane

Its up to you to get the components all up loaded.

Then your SPA grants administrator presses the final button.

Keep SPA - GA in the loop for final submission.

Cannon’s corollary to Murphy’s Law: The likelihood that network or fastlane difficulties will occurThe likelihood that network or fastlane difficulties will occur

increases asymptotically as deadline approachesincreases asymptotically as deadline approaches.

The submission process

“The Program Manager Call” Intends to recommend funding but ……

Budget and scope change - you usually have a small window for negotiation make the best of it.

Make the change in consultation with SPA GA.Provide all the extras program manager needs. then wait…..

Can you start work??? Need an award letter!! Sometime have pre-award spending period but need strong assurance from agency that award will be made.

So the proposal is reviewed positively

GR account number is setup.

You and any qualified persons you designate will be granted signature authority.

Set up your own simple spreadsheet (Excel or Quicken) so that you can track expenditures.

Soarfin works but for most things I find having directly accessible sheet helpful.

Finally the Award Letter arrives

Summer Salary for PI’s:

If budgeted & to the degree allowable by agency

Up to you to get PAF setup for Summer Pay

If work will not be finished by the end of the work period you can request a no-cost extension which has to be approved by granting agency.

(Should not be solely because you have residual funds. Willingness to extend varies by agency.)

Post work period budget revisions is the number one red flag for OMB that triggers a general audit.

Spending must be between the dates of the award

Budget category switching - since it’s research some latitude in making changes BUT if exceeds a certain percentage which varies by agency - requires agency approval.

USM has a robust system for monitoring category changes - Its a necessary and actually helpful tool for tracking changes.

If within limits set by the agency you fill out an internal budget modification form.

Spending must be for items budgeted

To purchase, contact appropriate vendors and USM Purchasing Department.

State purchasing policies must be followed in all instances.

Equipment over $5000 must be bought on bid unless there is a sole source of supply.

Equipment bought on grants is the property of the State and University.

The PI should cooperate with USM Property Accounting and their Home Department to ensure that all inventory procedures are followed.

Equipment is not to be removed from campus without proper permissions being granted and documented usually by department chair or college dean.

The University is regularly audited by the state and PI’s are responsible for presenting the equipment to the auditors when requested .

Equipment Purchases

Likely to be related so there is some overlap in services and goods purchased: but be careful!!!

No need to buy two bottles of NaCl for two funded projects, but only if they both really need it.

How about travel by assistant to Ireland to study court records for one funded historical study and then continue travel to France for Research for another unfunded study????? Gets dicey.

Best advice is to always be upfront and ask agency contact-before making expenditure.

“It’s better to ask forgiveness than permission” – is not true in the world of funded research.

Multiple projects-Multiple grants

Students and assistants: How to manage?

Example: Grant ends Graduate student not ready to graduate. Can you just switch to another project? Maybe. How related will the students efforts truly be to the second

project?

I suggest keeping a brief justification for when changes are made.

I have encountered attitude : “Well no one has the expertise to call me on this”.

Might be true in Dept. or at USM but when OMB comes a ‘calling they have the resources to obtain expert evaluation of your actions.

Central Florida Case

Multiple projects-Multiple grants

Normally described in budget justification of proposal.

Most agencies have some of system of rules .

Must conform to University and State travel regulations.

Just because its grant funded does not exempt you from State travel regulations

Travel

Accounting rules that govern federal government funding of university research.

For example: Why we can’t hire a secretary from my NSF grant. Why we can’t buy a computer on my grant for the office

secretary . Why we must file monthly time and effort reports.

Not an accountant – but need to work with the University accountants to ensure compliance.

Avonelle – never said it but I’m sure she thought – “Its not my A-21”.

A-21 Task force.

OMB Circulars A-21 and A-110

With the current emphasis on multidisciplinary projects it is common that grant will have multiple PI’s.

Make certain everyone’s roles and responsibilities are spelled out before grant starts (in proposal if practical).

Have a documented plan as to how budgeting and spending will be handled.

Multi PI Grants

HHS broadly defines COI : “When outside activities interfere with scholar’s university duties”

Conflict of Commitment – outside employment

Financial conflict of interest

Conflict of Interests

Conflict of Commitment

Permission for outside employment HR Approved by the president As a rule of thumb about 8 hours

a week is allowed

Note books or other forms of Data Archives must be maintained meticulously using best practices of the appropriate field.

First thing that comes to mind is Intellectual property protection–but with new “first to file” patent regulations the note book is less of a factor there.

However proper notes and data recording is the basis for knowledge advancement and as a practical matter should your work be questioned by others sometime down the line (happens more and more often) good documentation is essential.

Unintentional misinterpretation of data happens as part of advancing scholarship. Intentional misinterpretation or sloppy data documentation could lead to misconduct .

Data Management

Both NSF and NIH have issued directives requiring that a plan for Data Management be described in the proposal and followed.

NIH requirements still quite controversial and developing.

Who owns Data? Note books or other data archives?

How does faculty proceed to develop Intellectual Property rights?Noetic Technologies is currently the commercialization arm of the University.

Data Management-Cont.

All agencies require some sort of progress and final reports.Usually two types Technical and Financial.Frequency of progress report depends on agency.

Technical report is written and submitted by the PI – Copies of the final report to SPA. Importance of these and their timely submission cannot be overstated.

NSF blocks submission of new grants by all PI’s on a grant if reports are late.

Financial reports are assembled and submitted by USM Office of Contracts and Grants Accounting (OCGA) (some universities recommend PI review).

Other deliverables - Software, Maps, Databases, etc. etc.

Reports & Reporting Periods

Heading into challenging times but…Sun will still rise and agencies will still make

grants. We just need to make sure we do the right things to ensure we are getting support for

our scholarly efforts !!!!SMTTT!!