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Pre-Award Fundamentals of
Research Administration
NCURA Region I Annual Spring Meeting
May 7th, 2006
Portland, Maine
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FACULTY• Sara Clabby
Contract Administrator, Office of Sponsored Programs, Brown University
• Bethanne GiehlAssistant Director, Research Funding
Services
University of Massachusetts Medical School
• Celia GravelyProject Manager
Huron Consulting Services
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Frequently Asked Questions that will NOT be Answered…
• Why do faculty always wait until the last minute?
• Why does the government only add regulations, but never takes any away?
• Is it too late to find another line of work?
• Is there a profession with more acronyms than Research Administration?
• Why is this meeting room so hot?
• And…..
• Why is this room so cold?
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PreAward Fundamentals
• Rules & Requirements
Federal Guidelines
Sponsor Guidelines
Institution Policies• Sponsored Projects Administration
What we do
Who we are
Central and De-central• Why?
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Lifecycle of a Proposal/Award
Pre-Award Post-AwardDevelopment
Agency
Review
(6-9 mos)
Project Period
1stBudgetPeriod
2ndBudgetPeriod
3rdBudgetPeriod
NoCost
Extension
Revised Budget
Submit Renewal /
Competing-Contin
uation
Closeout
Final Reports
Submit Proposal
Pre-Award CostsAward
Award
Apply
Find/ExploreAdminister/Monitor(Post-Award Office)
Perform(Principal Investigator)
Technical Close(Principal Investigator)
Financial Close(Post-Award Office)
6“Research and development! My goodness!”
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The Rules and Who Makes ThemA Structure Based on:• Overarching Federal Regulations• Parties to the relationship
– Sponsors and Performers– Sponsors announce opportunities
• The formal Agreement between the parties– Grant; Contract; Cooperative
Agreement• Agreements contain a set of rules,
terms, and conditions– Statutes; regulations; standard
terms; specific conditions
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Who are our Sponsors?
• Federal Government
– Departments
• Agencies
– Independent Agencies
• State Government
• Foundations and Non-Profit Organizations
• Industry
– Large Entities (over 500 Employees)
– Small Entities (under 500 Employees)
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Examples of our SponsorsAgencies or Sponsors
DHHS Department of Health and Human ServicesPHS Public Health ServiceNIH National Institutes of Health
NSF National Science Foundation
DOD Department of DefenseAFOSR Air Force Office of Scientific
ResearchARPA Advanced Research Projects
OfficeARO Army Research OfficeONR Office of Naval Research
DOC Department of CommerceNIST Nat. Inst. of Standards and
Technology AHAAHA American Heart AssociationJDRFJDRF Juvenile Diabetes Research FoundationWhitakerWhitaker Whitaker FoundationMonsanto Monsanto IndustriesHP Hewlett-PackardMASS-Ed Massachusetts Department of EducationFL-F&W Florida Department of Fish and Wildlife
Federal
Non-Non-ProfitProfit
Industry
State
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How Sponsors Announce Opportunities
PA Program Announcement (sponsor publication, Federal
Register, FedBizzOpps) (grants, cooperative agreements)
RFA Request for Applications (grants, cooperative agreements)
RFP Request for Proposals (contracts)
RFQ Request for Quotation (contracts)
RFB Request for Bid (contracts)
BAA Broad Agency Announcement (grant, cooperative agreement, contract)
Response to Announcement in Form of Proposal
Also called application; quotation; bid
Lays out general plan of work, personnel, budget to meet stated objectives
un
solic
ited
solic
ited
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Types of Agreements:
• Most Common Types of Formal Agreements With the Federal Government
• Types of Award Actions
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Formal Agreements
• Most Common Types Of Formal Agreements
– Grant
– Cooperative Agreement
– Contract
Assistance Mechanisms
Procurement
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Formal Agreements: Assistance Mechanisms
• Grant– Purpose is to transfer money, property, services,
or anything of value to recipient in order to accomplish a public purpose
– Idea originates with “performer”– No substantial involvement is anticipated between
sponsor and recipient during performance of activity
• Cooperative Agreement– Principal purpose is to transfer funds to recipient
to accomplish a public purpose– Idea may originate with “performer”– Substantial involvement is anticipated between
sponsor and recipient during performance of activity
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Formal Agreements: Procurement Mechanisms
• Contract– Often called a “procurement
mechanism”– Sponsor determines that
procurement contract is appropriate
– Principal purpose is to acquire property or services for direct benefit or use of the sponsor
– Idea originates with “sponsor”
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Contract Types
• Fixed Price Contract
• Cost-reimbursement Contract
• Time-and-Materials Contract
• Labor-hour Contract
• Plus variations and combinations of each of the above
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Fixed Price Contracts
• Procurement of supplies or services on the basis of reasonably definite functional or detailed specifications.
• When costs can be estimated reasonably accurately.
• Imposes on contractor maximum incentive to control costs, but with minimum administrative burden.
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Cost-Reimbursement Contracts
• Procurement of non-commercial items which cannot be based on reasonably definite functional or detailed specifications (i.e., R&D).
• There is no incentive for contractor to control costs, thus government imposes tighter controls.
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CR/FP - How Do I Tell?
• Cost-Reimbursement– “Total estimated
cost” or “not to exceed amount”
– Invoicing based on expenditures
– Listed FAR clauses.
• Fixed Price– “Total Price”
– Invoicing based on milestones
– Generally, POs are fixed-price
– Listed FAR clauses
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Time-and-Materials and Labor Hour Contracts
• Reimbursement of hours worked, not costs incurred.• Fixed hourly rate that incorporates salary, fringe
benefits, F&A, and fee.• Rates invoiced must match proposed rates, regardless
of actual cost incurred.• Audit?• What to do about them…
– Don’t accept unless your financial system can support it.
– Argue on the basis of cost accounting standards; or– Negotiate a range to the allowable invoicing rates
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Grant vs. Contract
Grant• project conceived by investigator• agency supports or
assists• performer defines
details and retains scientific
freedom• agency maintains
cognizance• unilateral
Contract• project conceived by
agency• agency procures
service• agency exercises
direction or control• agency closely
monitors• bilateral
Comparing the Basic Types Of Agreements
COOPERATIVEGRANT AGREEMENT CONTRACT
BASIC PURPOSE Provide assistance Provide assistance with substantial Procure tangible with few restrictions involvement between parties goods and services
SOLICITATION METHOD Application kit or Request for Application Request for Proposal or guidelines Quote
AWARD INSTRUMENT Short, may refer to Describes involvement, party Long, detailed specs, general conditions relationships clauses, regulations,
andexpected result
INVOLVEMENT Generally none Substantial involvement May be extensiveBY SPONSOR
REBUDGETING Flexible Usually flexible More restrictive
EQUIPMENT TITLE Grantee Varies Varies
PERFORMANCE PERIOD Specified in Grant Specified in Coop. Agreement Specified in Contract
PATENT RIGHTS Usually favor recipient May be involved Provision in contract
PUBLICATIONS May ask to be informed May ask to be informed May be prior review/approval
TECHNICAL Annual summary report No more than quarterly Detailed, maybe monthly
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Hierarchy of Federal Regulations
Sources:• Statutory requirements
(i.e., an Act of Congress, becoming Public Law)
• Presidential Executive Order
• Federal regulations
• Sponsor’s terms/conditions
NIH Salary cap appears as statutory language in the HHS
appropriations act
Affirmative Action
NSF regulations on Uniform Administrative Requirements
appear in 45 CFR 602
NSF grant terms and conditions appear in the NSF Grant Policy Manual & NSF
Grant General Conditions (CG-1)
Examples:Examples:
How Do Federal Regulations Happen?
ORIGIN PUBLIC LAW PRESIDENTIAL FEDERAL AGENCY(statutory requirement) EXECUTIVE ORDER REGULATIONUNITED STATES CODE (USC)
Grants ContractsEXECUTIVE OMB-CIRCULARS FAR Councils OMB CLEARANCE
Transmittal Memos - civilianCOMMON RULE - defense
AGENCY CODE OF FEDERAL REGS (CFR) FEDERAL REGISTER(Dept/agency Specific) (rulemaking; comment period)
IMPLEMENTATION AGENCY REGS FEDERAL REGISTER FEDERAL REGISTERFEDERAL ACQUISITION REGS AGENCY GRANT REGS AGENCY REGS(contracts only) (FAR) FAR & SUPPLEMENTS FAR & SUPPLEMENTSAGENCY FAR SUPPLEMENTS (contracts)
EXAMPLES CIVIL RIGHTS (USC) DEBARMENT & SUSPENSION RECOMBINANT DNA (NIH)FOIA (USC & CFR) (Common rule-CFR) MISCONDUCT (NSF)HUMAN SUBJECTS (Common Rule-FR) COORDINATED REVIEW CONFLICT OF INTEREST (NSF, NIH)DRUG-FREE WORKPLACE (USC) VIETNAM ERA VETERANS DRUG-FREE WORKFORCE (DOD)LOBBYING (USC & FR)MISCONDUCT (NIH)
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Types of Award Actions
• New Award/Competing Award• Continuation Award/Non-competing
Award • Supplemental Award• Modification (e.g., budgetary revision,
change of key personnel, administrative change, termination notice)
• No-Cost Extension• Amendments (usually associated with
contracts)• Subaward
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Typical Elements of an Award Notice
• Awarding entity and authority• Award number• Recipient (institution)• Name of PI or project director• Reference to proposal or project title• Funding (total, incremental?)• Cost basis (reimbursement, fixed?)• Dates (start, end)• Reports, deliverables• Terms and conditions
– Stated in text, attached, or incorporated by reference
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Excerpt from Award Letter Federal
The National Science Foundation hereby awards a grant of $70,411 to NAME OF UNIVERSITY for support of the project described in the proposal referenced above as modified by revised budget dated June 2, 2005. This project, entitled "Cyclic Processes Within Surface-exposed Fractures Affecting Evaporation and Salinization Mechanisms," is under the direction of PI “Smith”. This award is effective August 1 , 2005 and expires July 31, 2006. This is a continuing grant which has been approved on scientific / technical merit for approximately 4 years. Contingent on the availability of funds and the scientific progress of the project, NSF expects to continue support at approximately the following level: FY 2006 $123,118 FY 2007 $121,019 FY 2008 $35,192.
This grant is awarded pursuant to the authority of the National Science Foundation Act of 1950, as amended (42 U.S.C. 1861-75) and is subject to NSF Grant General Conditions (GC-1), dated 6/15/05 available at http://www.nsf.gov/publications/pub_summ.jsp?ods_key=gc1605.
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Office of Management and Budget Circulars
OMB Circulars for Cost Principles Applicable To All Awards
A-21 Cost Principles for Educational Institutions A-87 Cost Principles for State, Local and Indian Tribal Governments
A-122 Cost Principles for Non-Profit Organizations
Uniform Administrative Requirements
A-110 Grants and other Agreements with Institutions of Higher
Education, Hospitals, and other Non-Profit Organizations:
Uniform Administrative Requirements
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Office of Management and Budget Circulars
OMB Circulars for Uniform Administrative Requirements (contd.)
A-102 Uniform Administrative Requirements for Grants and Cooperative Agreements With State and Local
Governments
Regulations Applicable to Audits
A-133 Audits of States, Local Governments and Non-Profit Organizations
Regulations Applicable To Procurement Actions
FAR Federal Acquisition Regulations (first published, Federal Register, 9/19/83; on-going revisions)
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“Contemplating any business act, an employee should ask himself whether he would be willing to see it immediately described by an informed and critical reporter on the front page of his local paper, there to be read by his spouse, children, and friends.”
--- Warren E.Buffet
The Front Page of the Newspaper Test
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Responsible Conduct of ResearchCompliance Topics
•Responsible Conduct of Research•Research Misconduct•Financial Conflict of Interest•Human Subjects•Animal Care•Recombinant DNA•Hazardous Materials•Data Rights, Access, & Protection
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Responsible Conduct of Research
PHS requirement for trainees on K-30, T-32 and T-34 awards to complete instruction in the following: 1. Data acquisition, management, sharing, and ownership
2. Mentor/trainee responsibilities
3. Publication practices and responsible authorship
4. Peer review
5. Collaborative science
6. Human subjects
7. Research involving animals
8. Research misconduct
9. Conflict of interest and commitment
Institution determines content, length, format, and
who covered
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“About these experiments you’ve conducted for 12 years — no one remembers hiring you.”
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Research Misconduct
• Research misconduct defined
does not include honest error
or honest differences in interpretations or judgments of data.
• Government-wide policy issued by OSTP, December 2000• Designed to replace existing PHS and NSF rules and to be
adopted by all federal funding agencies • Changes adopted by NASA, NSF, VA, USDA, DOE, EPA,
DHHS and DOL
“fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.”
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Research Misconduct
• Institutions must develop policies and procedures to deal with allegations of misconduct to include:
– Definitions
– Written policy
– Description of inquiry and investigational phases
– Process for protection of whistleblowers
– Reporting to agency (process, timing)
– Retention of records
– Certification requirements
• DHHS requires Assurance Annual Report on Possible Misconduct
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Financial Conflict of Interest
• PHS Regulation and final NSF policy effective on October 1, 1995
• Regulation / policy similar in content• Major components of the regulations:
– Contractors / grantees must have adequate policies
– Disclosures of financial interests of faculty and family must be made by PIs and others having decision- making authority over conduct of work
– Financial interest defined as $10,000 annual income or 5% equity whichever is less
– Contractors/grantees have discretion over who reviews disclosures
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Financial Conflict of Interest• Specific criteria for review will be at
institution’s discretion
• Management of conflicting financial interests must be undertaken
• Applications must contain certifications
• Institutional records are subject to federal review
Bottom lineBottom line is that at a minimum, institutions must have written policies in compliance with federal
regulation/policy.
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Financial Conflict of Interest
• Investigator Conflict of Interest versus Institutional Conflict of Interest
• Institutional Conflict of Interest– Equity Interest in Company– Licensing Interest– Interest Held by Institutional Officers
• Human Subject Consideration– Informed Consent– May 2004 DHHS Guidance
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Confidentiality of Patient Records(meant to protect patients seeking drug and alcohol treatment)
Applicability:• All programs funded in whole or
in part by federal funds• Flow-down requirement to
subrecipients• Records cannot be used to
initiate or substantiate criminal charges
• Records can only be released with consent of patient except:– when identity withheld– when authorized by court
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Confidentiality of Patient Records: HIPAA
• Health Insurance Portability and Accountability Act of 1996 (HIPAA)– Congress failed to
pass legislation before 8/21/99, which resulted in authorization of DHHS to issue regulation
– Final Rule issued on August 14, 2002; Implementation by April 14, 2003
• http://aspe.hhs.gov/admnsimp/pvcfact1.htm
• 45 CFR Part 160
• Provisions:– Patient Education on
Privacy – Patient Guaranteed
Access to Medical Records– Patient Must Give Prior
Approval Before Release of Records
– Release of Minimum Necessary for Health Care Purposes Only
– Provide Recourse if Violated – Civil and Criminal Penalties Through the DHHS Office for Civil Rights
– Records for Research Purposes; Oversight by IRB or Privacy Board
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Functions and Organization of Sponsored Projects Administration
• Functions
• Organizational Participants
• Organizational Models
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May be handled by
different offices
Functions of Research Administration: Examples
• Policy and procedure development, implementation
• Funding opportunity development, promotion, advancement
• Interpretation of guidelines, preparation and review of proposals
• Stewardship and accountability• Financial and programmatic
oversight• Project performance and delivery• Subcontracts, purchase of goods
and services
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More Examples
• Training• Negotiation, dispute resolution• Reports
– Progress– Fiscal– Final
• Certification, compliance• Risk management• Transfer to public benefit,
economic development, communication of outcomes
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Organizational Participants
• Executive Administration
• Academic and Research Divisions
• Business Divisions
• Legal Office
• Other
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“Friend of the administration or
friend of research?”
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Organizational Models
• Unified
– Under one division at the institution
– May have other offices distributed (e.g., compliance)
• Separate
– Parallel
– Under academic and business divisions
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Organizational Models
• Organizational Models Depend on:– Tradition– Philosophy– Size and mission of
institution– Experience
• Key to success with any model:
COMMUNICATION
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Why Sponsored Projects?(The Institution’s Perspective)
• Increase Status/Prestige
• Attract New Faculty and Students
• Train Future Scientists/Teachers
• Upgrade Programs and Build Infrastructure
• Enhance Connections With Other Segments of Society
• Service to State/County
Often centered around institution’s standing and missionOften centered around institution’s standing and mission
Sponsored Projects
Sponsored Projects
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Expectations Made of Our Faculty
• Take a few minutes and consider the range of expectations and demands placed on our faculty.
What expectations can you identify?
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How DO Faculty Learn to Write
Proposals?
How DO Faculty Learn to Write
Proposals?
Quality of Quality of IdeaIdea
Match to SponsorMatch to Sponsor
Infrastructure Infrastructure SupportSupport
FacultyFacultyFacultyFacultyConducting Research
and Scholarship
Conducting Research
and Scholarship
Department/college
committee service
Department/college
committee service
Uni
vers
ity c
omm
ittee
serv
ice
Uni
vers
ity c
omm
ittee
serv
ice
Tea
chin
g/pr
epar
ing
lect
ure
s/gr
adin
g
Tea
chin
g/pr
epar
ing
lect
ure
s/gr
adin
g
Maintain currency withliterature
Maintain currency withliterature
Perso
nal/f
amily
life
Perso
nal/f
amily
life
Write proposals
Write proposals
Prepare/presen
t
professional papers
Prepare/presen
t
professional papers
Promotion and tenure
Promotion and tenure
Student advisingStudent advising
Professional service
Professional service
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Common Goals: Research Administrator and Investigator
• Increase Sponsored Program Activity and Publication of Results to Advance Knowledge
• Enhance Educational Opportunities for Students
• Expand Research and Public Service Activities
• Streamline and Improve the Research Environment
• Protect and Minimize Risk to Individuals and Institution
Sponsored Projects
Sponsored Projects
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The Research Administration Balancing Act
• Research administrators seek a balance of interests that respects the shared responsibilities throughout the institution.
• Research administrators balance facilitating the research, teaching, and public service activities of faculty, students and other investigators while accommodating the priorities and stewardship expectations of the institution, governmental entities, sponsors and the public.
Internal Stakeholders
Internal Stakeholders
External Stakeholders
External Stakeholders
Proposal Development
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Proposal Development• Gather Funding Information• Disseminate Funding Information• Help Develop Sponsor Contacts• Provide Proposal Assistance• Produce Workshops and Manuals
Proposal Preparation for Faculty
Departmental Administrators
Specific Sponsors
Electronic Proposal Submission
Budgets
• Administer In-House Grants Programs
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Types of Proposals
• Letter of Inquiry
• Letters of Intent
• Preliminary Proposals
• Concept Papers
• White Papers
• Formal Proposals
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Letter of Inquiry or Preliminary Proposal
• Letter ProposalUsed by private foundations for screening
to second stage
• Preliminary ProposalUsed by both federal and non-federal
sponsors
• Length:3 – 5 pages
• Formatcover letter and 3 – 4 page proposal, or All information in 3 – 5 page letter
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Letter of Inquiry orPreliminary Proposal
• Elements to be covered:
Areas of research/content of project (be rather specific)
Needs and purpose statement
Unique qualifications, abilities, and facilities
Benefits/anticipated results of the project
Estimate of cost (no detailed budget)
Offer to meet
Request for response
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Concept Paper/White Paper
• Concept Paper:Generally internal working document
or used for informal feedback
• White Paper:Concept paper sent unsolicited to a
sponsor
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Formal Proposal
• Put together according to guidelines established by sponsor
• Always use forms and format required by sponsor
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Formal Proposal (continued)
• The Usual Sections:
Title/Cover Page with appropriate signatures
Abstract (less than one page)
Statement of Work
Key Personnel CVs/Bio Sketch
Detailed budget with Justification
Facilities/Resources Statement
Appendices (as needed and
allowable by sponsor)
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Formal Proposals (continued)
• Parts:
• Scientific/Program Description
• Representations and Certifications
• Budget
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Formal Proposals (continued)
• The Science
A concise explanation of the project
the whatwhyhow
Usually must conform to a specified structure and page limitations
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Formal Proposal (continued)• Administrative Sections –
The Reps. & Certs.
Certifications may be incorporated into the proposal, i.e., the Checklist Page for NIH, the Cover Page for NSF
Or the certifications can be separate, i.e., “Certifications and Assurances for Assistance Agreements” for the Defense Agencies and Standard Form 424B for DED, EPA, etc.
May also need “Certification Regarding Lobbying” and “Disclosure of Lobbying Activities”
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Formal Proposal (continued)
• OMB Circular A-110
Uniform Administrative Requirementsfor Grants and Agreements withInstitutions of Higher Education andOther Non-profit Organizations
Subpart A – GeneralSubpart B – Pre-Award RequirementsSubpart C – Post-Award RequirementsSubpart D – After the Award RequirementsAppendix A – Contract Provisions
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Formal Proposal (continued)
• A-110 Subpart A – GeneralEffect of A-110 on Other Issuances
Awards subject to A-110, all other administrative requirements codified in program regulations, manuals, handbooks inconsistent with this circular are superseded, unless required by statute or authorized by the deviations provisions of this circular
DeviationsExceptions to A-110 are permitted in unusual circumstances by OMB
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Formal Proposal (continued)
• A-110 Subpart A (cont.)Subawards
A-110 should be flowed down to sub-recipients which fall under this circular
• A-110 Subpart B – Pre-AwardAgency Decides on Appropriate Award InstrumentGrant: Principal Purpose is to Provide Support to Accomplish a Public PurposeCooperative Agreement: Same as a Grant, Except Substantial Involvement is Expected by the Awarding Agency
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Formal Proposal (continued)
• A-110 Subpart B (cont.)Contract: Principal Purpose is Acquisition of Property or Services for Direct Benefit of GovernmentForms Used When Applying for Assistance:
Agencies must comply with 5CFR part 1320 – “Controlling Paperwork Burdens on the Public”Applicants shall use SF-424 series, or forms and instructions prescribed
by agency
Programs covered by E.O. 12372 “Intergovernmental Review of Federal Programs” – applicants must complete
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Formal Proposal (continued)
• A-110 Subpart B (cont.) appropriate sections of SF 424 and send a copy of proposal to the state coordinating office.Debarment and Suspension
Agencies and recipients must comply with the non-procurement common rule
Special Award ConditionsAdditional requirements may be imposed
by agencies if:
Recipient has history of poor performance
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Formal Proposal (continued)
• A-110 Subpart B (cont.)Recipient is not financially stable
Recipient has management system
that does not meet standards
Recipient has not conformed with
terms and conditions of previous
award
Recipient is not responsible
Recipient must be notified in writing
Special conditions removed once
corrections are made
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Formal Proposal (continued)
• Basically, the Agency is looking for us to certify compliance with all of their statutory requirements
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Budget Development
• Include both direct and F&A costs
• Should be detailed• Include only allowable costs• If required, include matching
or cost-sharing (if cost-sharing is proposed it should be proportional between direct and F&A)
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Budget Development (cont.)
• Direct Costs:Costs that can be identified specifically
with a particular sponsored project,
an instructional activity, or any other
institutional activity; or that can be
directly assigned to such activities
relatively easily with a high degree of
accuracy
Examples of Direct Costs:
Salary of Researcher (including FB)
Laboratory Supplies
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Budget Development (cont.)
• Facilities and Administrative(F&A) CostsCosts that are incurred for common or joint objectives, and, therefore, cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity
Examples of F&A Costs:Salary of Department AdministratorBuilding utility and maintenance
costsPurchasing, Controllers’ offices
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Budget Development (cont.)
• Composition of Total CostsA-21, section C.1.
The cost of a sponsored agreement is
comprised of the allocable direct
costs incident to its performance, plus
the allocable portion of the allowable
F&A costs of the institution…
Therefore, Federal sponsors reimburse
the institution for the allowable costs
of a project, including direct costs and
F&A costs….
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Budget Development (cont.)
• Elements of Direct CostsSalaries and Wages
Fringe Benefits (FB)
Equipment
Expendable Supplies and Materials
Travel
Subcontracts
Consultants
External
Interdepartmental
Other
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Budget Development (cont.)
• Salaries and WagesInstitutional Policy on Academic Year
Salary RecoverySummer SalaryPostdoctoral Research AssociatesUndergraduate & Graduate Students (salaries or stipends?)Technical and Clerical Support*
Use Percent of Effort, Not Hourly Wage
Include Increases for COLA and Merit- based AdjustmentsFollow institutional policies on FB
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Budget Development (cont.)
• EquipmentNote the differences between the sponsor’s equipment definitions/ thresholds and your institution’s
General purpose equipment is not allowable as a direct cost unless programmatically necessary and used exclusively/primarily for research
• Expendable Materials/SuppliesMust be programmatically necessary; general office supplies should be treated as an F&A cost – unless a major program.
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Budget Development (cont.)
• TravelAdhere to Institutional Policy and Agency GuidelinesDistinguish between Domestic and Foreign TravelForeign Travel may require prior approval from sponsor prior to trip (even if in original budget/proposal
• SubcontractsProposed costs should be Reasonable and Allowable (however, keep in the mind the sub-contractor may be under different cost principals)
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Budget Development (cont.)
• ConsultantsExternal: required expertise needed for the project which cannot be provided by faculty or staff at the institution; rate must be reasonable; in most instances, consultants’ level of effort and participation should not rise to the level of “key personnel” – that would imply substantive programmatic work
Interdepartmental: in some instances, a faculty or staff member may serve on a project as a consultant, but only if the expertise required is not part of this person appointment or job function
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Budget Development (cont.)
• Other Direct CostsCommunicationsPublicationsAnimal Care CostsHuman Subject CostsShop ChargesMaintenance/Service ContractsComputer CostsGraphic Arts/Photographic ServicesRental/Lease of FacilitiesConstruction/Renovation/Remodeling Costs
All of the above must be programmatically necessary!
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Budget Development (cont.)
• What Does “Allowable” Mean?An allowable cost must be:
REASONABLE: A prudent business
person would have purchased this item
and paid this price.
ALLOCABLE: It can be assigned to the
activity on some reasonable basis.
CONSISTENTLY TREATED: Like costs must
be treated the same in like circumstances,
as either direct or F&A costs.
If a cost cannot meet the above criteria, it is
unallowable, no matter what it is for.
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Budget Development (cont.)
• What Does “Allowable” Mean? (cont.)
An “allowable” cost is one that is eligible for
reimbursement by the federal government.
Contrast with:
PERMISSIBLE BY INSTITUTION: A cost is
permitted by institution, as outlined in its
various administrative policies or procedures.
ALLOWABLE BY AGENCY: A cost is permitted
by the policies of the sponsoring agency or
the terms of an award.
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Budget Development (cont.)
• Assessing Whether a Cost Is
Allowable or UnallowableA cost may be “expressly” unallowable,
i.e., it is always unallowable as either
a direct or indirect.
Unallowable activities: fund raising,
alumni relations, lobbying, etc.
Unallowable transactions: alcohol,
entertainment, fines, etc.
A cost may be allowable but only as an
indirect/F&A cost, not a direct charge,
e.g., proposal preparation
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Budget Development (cont.)
• Assessing Whether a Cost Is
Allowable or Unallowable (cont.)
Generally, it is not the type of cost that
determines allowability, it is the purpose
and circumstance of the expenditure. Many
categories of costs are allowable as a
direct or indirect, e.g. salaries, travel,
materials, etc.
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Budget Development (cont.)
• Third Party Agreements
Types of third party agreements:
Purchase Order
Subcontract/Subgrant/Subagreement
Consulting Agreement
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Budget Development (cont.)
• Purchase Order
A particular kind of agreement issued to enter into a legally-binding commitment with an outside vendor for the acquisition of goods and services. Normally the purchasing department is responsible for purchase orders, and for their negotiation or revision where necessary.
Vendor Subcontracts: used for the procurement of goods or services from
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Budget Development (cont.)
• Purchase Order (cont.) an organization which provides the
goods or services to many different
purchasers as part of its normal
business operations within a competitive
environment. These subcontracts (or
purchase orders) are not subject to
compliance requirements of the Federal
award (per A-133).
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Budget Development (cont.)
• Subawards/Subcontracts/Subgrants/SubagreementsWhatever you call them…
A written agreement with a third party for the acquisition of services or goods or for the conduct of prescribed activities or functions under an award.
Subrecipient Subawards: used to procure substantive programmatic work under a grant or contract. The sub-recipient has responsibility for programmatic
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Budget Development (cont.)
• Subawards (cont.) decision making and measurable
performance requirements related
directly to the award. Sub-recipients
must adhere to federal compliance
requirements.
• Subaward Process RequirementsLetter of Intent
Statement of Work
Period of Performance
Budget
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Budget Development (cont.)
• Process Requirements (cont.)Other Documentation
F&A Cost Agreement
Cost Justification
Statement of Work Approval
Certifications/Assurances (these
are usually part of the subaward
agreement)
94
Budget Development (cont.)
• Consulting AgreementA form of subcontractAn agreement issued for services too urgent, temporary, specialized, or highly technical to be provided by existing university personnel. Consulting agreements are not issued to procure “substantive programmatic work.”Consultants operate as independent contractors without detailed supervision, like subcontractors. Unlike subcontractors, they most often participate on a “work-for- hire” basis.
95
Budget Development (cont.)
• Consulting Agreements (cont.)Remember – a “consultant” is not an
“employee.”
If am employee is misclassified as an
“consultant,” the institution is subject to
fines and penalties.
Employer/employee relationships imply:
More discretion to direct or control the
contents of work and results to be
accomplished and means by which
accomplished
Continuing relationship whether full-
96
Budget Development (cont.)
• Consulting Agreements (cont.) time, part-time, seasonal, or short duration.Set HoursGuaranteed minimum pay and pay intervalsMutual right to terminate without liabilityFurnishing of facilities, supplies, and equipment needed to accomplish workTraining supplied
Some Possible Considerations For Consulting Agreements:
Prior Approval to Publish, Etc.Work-For-Hire
97
Budget Development (cont.)
• Consulting Agreements (cont.)Conflict of Interest
Indemnification
Flow-through Provisions from Prime
Rate Limitation
Sponsors May Set Allowable Rates
Consultants
Travel Is In Addition to Daily Rate
98
Budget Development (cont.)
• Cost-Sharing/Matching Costs
is the portion of the cost of a project not borne by the sponsoring agency
Types of cost sharing:
Mandatory
Voluntary
Voluntary Uncommitted
99
Budget Development (cont.)
• What Can be Used to MeetCost Sharing?
CashThird Party Contributions (however, federal funds cannot be used as cost sharing on federal funds)Unrecovered F&A costs (can be used if agency has approved)Establishing values for contributions of services and property (in accordance with applicable cost principles)Volunteer Services: if necessary and integral part of project
100
Budget Development (cont.)
• Cost Sharing (continue)Other employee services (valued at
regular rate of pay + fringe benefits)
Donated supplies (must be reasonable
and at fair market value)
• Cost Sharing ConsiderationsCash and third party in-kind
contributions must meet all of the
following criteria:
Are verifiable from the recipient’s records
101
Budget Development (cont.)
• Cost Sharing Considerations (continued)Cannot be used as cost sharing on other federal projectsAre necessary and reasonable for accomplishment of project objectivesAre allowable under the cost principlesAre not paid by the Federal government under another awardAre provided for in the approved budget when required by Federal agencyConform to other provisions of A-110, as applicable
102
Budget Development (cont.)
• Potential Problems Associated with Cost Sharing
Can we demonstrate to the funding
agency that the cost sharing
commitment has been fulfilled? Do
track cost sharing on a project-by-
project basis?
Are we treating cost sharing consistently
with other project costs, i.e., classify
it as organized research?
103
Budget Development (cont.)
• Potential Problems (cont.)Are we overstating our F&A rate by not capturing cost sharing?
Do effort reports capture cost shared effort (both mandatory and voluntarily committed)?
Are the same cost sharing funds used to meet the matching requirements on more than one project?
Do we recover cost sharing expenditures through our F&A rate?
104
Budget Development (cont.)
• Facilities and Administrative CostsPoints to Consider:F&A cost recovery is the reimbursement for actual costs incurred by the institution in support of sponsored projectsF&A costs are incurred on all institutional activities, not just sponsored researchF&A costs are REAL COSTS!A significant portion of F&A cost not recoveredWhen an external sponsor pays less than the full F&A rate, the unrecovered F&A costs must be absorbed by the institution (it’s an institutional decision)
105
Budget Development (cont.)
• Types of F&A Rate BasesTotal Direct Costs (TDC)
All direct costs of researchModified Total Direct Costs (MTDC)
All direct cost of research less:EquipmentSubcontracts in excess of $25,000Tuition RemissionPatient CareCapital ExpendituresRental CostsScholarships & Fellowships
Other items may be excluded where necessary to avoid a serious inequity in the distribution of F&A
106
Budget Development (cont.)
• F&A Rate Bases (cont.)Salaries and Wages (S&W)
Can only be used with the Simplified
Method
• Types of F&A Cost RatesProvisional – Estimated rate used when
parties cannot agree on an equitable
rate. May be replaced by fixed or
predetermined rate before the end of
the fiscal year.
Predetermined – Rate established for
107
Budget Development (cont.)
• F&A Cost Rates (cont.) for period, normally 2 to 4 years. No carry forward provision.
Fixed with Carryforward – Rate established for period. Over/under recovery is determined and an adjustment is applied to a subsequent rate negotiation.
• F&A Rate Versus F&A RecoveryF&A is often waived or reduced for cost sharingF&A rate calculation based on recoverable
108
Budget Development (cont.)
• Rate Versus Recovery (cont.) costs, i.e., all awards receive a full
allocation of F&A, not recovery
In reality, institutions subsidize a
significant portion of F&A costs
• On-Campus Research RateApplied to on-campus organized
research activities
Most frequently used rate; may be the
only rate negotiated
109
Budget Development (cont.)
• Off-Campus Research RateApplied to sponsored agreements at off-
campus facilities
Off-Campus is usually not a university-
owned facility
Recovers administrative costs associated
with sponsored agreements
Typically is the “A” portion of the On-
Campus Research Rate; “F” costs are
direct charged
The “A” portion is generally 26% because of federal cap
110
Budget Development (cont.)
• Other Sponsored ProgramsInstitutions with large amount of non- research sponsored projects may negotiate a separate rate for these projects
• Rates for Specific FacilitiesThe costs of certain programs/facilities may be unique enough to warrant a separate F&A rateExamples: Agricultural Experiment Station; Federally Funded Research and Development Center (FFRDC); University Medical Center
111
Proposal Review
• Typical Institutional Checklistfor Proposal ReviewCorrect FormsInternal Review Checklist/Approval FormCompatibility with Internal Review Checklist
Intellectual PropertySpace NeedsRenovation RequirementsCost Sharing/MatchingHuman Subject Use
review and approvalAnimal Use
review and approval
112
Proposal Review (cont.)
• Checklist for Proposal Review (cont.)
Recombinant DNA
review and approval
Conflict of Interest Policy
Publications/Proprietary Information
Restrictions
Hazardous Materials
Undergraduate & Graduate Students
Page Limitations
Type Size Limitations
All Elements of Proposal Included
113
Proposal Review (cont.)
• Checklist (cont.)Correct Rates Used
Budget Correct
Signatures
Subcontractor Commitment Letter
All Certifications Included
If RFP, is Exception Letter Needed
If Foundation/Corporation, on
“restricted” list
Requirement for State Review Ascertained
Correct Number of Copies, Deadline Date
Mailing/Delivery Address
114
Proposal Review (cont.)
• Checklist (cont.)Method of Transmittal, Packaging
Instructions
Limitation on Number of Proposals
from Institution
And You’re Done!!!
115
Pre-Award: Part IIProposal Submission & Review
• Certifications & Representations
• Routing & Internal Approval Signatures
• Special Consideration
• Peer Review, Site Visits,
• Pre-Award & Audits
116
Representations and Certifications for Proposals
• Civil rights, Non-discrimination• Delinquent Federal Debt• Drug-free Workplace• Drug-free Workforce• Debarment and Suspension• Drug- and Alcohol-free Schools• Procurement Integrity• Small Business Utilization &
Subcontracting• Lobbying
117
Debarment and Suspension (Final Rule May 1989)
• Regulations implemented by common rule (Grants)• Federal Acquisition Regulations (Contracts)
– BACKGROUND: Development of a government-wide system for transactions with federal agencies to detect fraudulent or improper use of government funds
– APPLICABILITY: Agreements in excess of $25,000. Flow down required
– CERTIFICATION: Applicants, their principals and researchers are not:1. Presently debarred or suspended2. Have not been convicted or had civil judgment for fraud rendered within a three
year period3. Are not presently charged by a Government entity4. Have not had a public transaction terminated for cause or default within a three
year period
Sanctions: Termination, debarment or suspension of awardee.Sanctions: Termination, debarment or suspension of awardee.
118
Procurement Integrity
• Applicability:– All federal contracts– Certification required when contract exceeds
$100,000/year– No flow-down requirement
• Requirements:– No competing contractor or any officer, employee or
consultant of such contractor shall:• make any offer or promise of future employment• offer any money, gratuity, or other thing of value to any procurement
officer of such agency• solicit any proprietary data or source selection information concerning
such procurement
– Key to Compliance: inform PI, and others, of requirements
119
Utilization of Small and Small Disadvantaged Business Concerns
• Applicability:– Most contracts in excess of $100,000– Flow-down to subcontractors
• Special requirements:– When contract is in excess of
$500,000, subcontracting plan required and special reporting requirements apply
– Subcontracting” means procurement of goods and services
• Subcontracting plan compliance and reporting can be handled by either purchasing office, research administration, or by project administrator
120
Lobbying Terms Defined• Lobbying activities include:
– Lobbying contacts– Preparation and planning for lobbying– Collaboration with others, such as
associations– Most public activities exempted
• Lobbying contact means:– Any oral, written or electronic
communication– Certain contact with executive officials– Certain contacts with legislative officials– With regard to
• Legislation• Federal rule, regulation, policy• Federal program (contracts, grants, loans, etc.)
Use of appropriated funds to pay a person
to influence or attempt to influence a federal official or employee in
connection with a specific award is
prohibited by law; disclosure required if
use of non-appropriated funds to
pay for lobbying activities
121
Lobbying
• Applicability:– All federal agreements – Flow-down to subcontractors is required
• Aspects Of Compliance:– Lobbying costs may not be paid from federal funds– “Federal funds” interpreted to mean direct costs only– Certification required for awards over $100,000– Disclosure of lobbying expenses required in certain
instances
122
Certification Signatures
• Authorizing Official– Chief Executive or those delegated authority
• Supported by internal approvals and signatures– PI, department, dean, business officers
• Signature is indication of assurances, representations and certifications
• See agency program guides and forms for summary of assurances that are made by signature of authorizing official and principal investigators
123
Typical Institutional Checklist for Proposal Review
• Compliance with Sponsor Requirement
• Compliance with Institutional Policies
• Compliance with Statutory Requirements
• Application Completeness• Appropriateness of Budget• If applicable, review Guidelines
of Solicitation
124
Solicitations – Special Considerationat Time of Institutional Review
contractscontracts
grants and cooperative agreements
grants and cooperative agreements
– RFP Request for Proposals– RFQ Request for Quotation– RFB Request for Bid
– RFA Request for Applications
• Proposers must register objections to proposed terms and conditions, scope of work, etc., at the time of response. It may be the only opportunity to take exception.
• For example:– resist using hours for faculty and professional staff
125
Peer Review• Primary basis for most
funding decisions• Variations: some contract
procurements may be based on a combination of qualifications and proposed cost (administrative and scientific review)
• Role of program official is a variable
• Evaluations are anonymous, and given in summary form to applicant on request
• Reviews usually assign scores, rankings, or categories
• Funding decisions are based on available funds
• Amount of award may be unilateral, or may be negotiated
See program guides or solicitation for details about review criteria
If the proposal is rejected by the sponsor, the PI should obtain the reviews from the sponsor, address the issues, and resubmit the proposal
126
127
Negotiation of Awards, Dispute Resolution
Negotiation Framework:• Clear channels of communication; documentation• Know institutional policies; be familiar with scope of work and your
history with the sponsor, project, PI, …• Terms and Conditions: programmatic and business
Negotiations with federal sponsors often include:• Budget level; Project Goals; Business Standards
Negotiations with non-federal sponsors often include:• Academic principles (freedom, publications, ownership of data and
reports)• Intellectual property• Business standards (salary basis, academic calendar)• Financial reporting (level of detail)
128
Intellectual Property Bayh-Dole Act - 37 CFR Part 401
• Allows retention of entire right, title, and interest throughout the world to each invention made with federal funding
• Government Retains nonexclusive, nontransferable, irrevocable, paid-up license to practice the invention for or on behalf of the government
• Requirements:– Disclosure within two months after inventor discloses to
institution– Election of title within two years of disclosure to agency– Filing of initial patent application within one year of electing
title
129
Material Transfer Agreement Considerations
See Uniform Biological Material Transfer Agreement for standard model (http://www.autm.net/ubmta/UBMTAWord.doc)
Ensure it is an institutional rather than a personal agreementClearly and specifically define material involvedDefine use to which material is (and is not) to be put, and how to
return or dispose of unused quantities.Define limitations on use and what is to be considered confidentialMay address use of names of organizations involvedOwnership of derivativesCommercial/Non-commercial usePublications (usually requires acknowledgement, perhaps co-
authorship)Indemnification
130
Clinical Trials
The institution is usually reimbursed on a per patient basis often with a fixed F & A rate of 20 - 30% TDC
• Negotiation concerns:– Ownership of Data– Ownership and Confidentiality of
Patient Records– Publication of Results– Patent Rights– Indemnification – Billing of Third-party Carriers for
Costs– Liability for Subject Injury– Informed Consent Requirements– F&A Costs
131
Electronic Research Administration
• A Definition of ERA
• What It Means for Sponsored Projects Offices
• The Future of ERA
132
NIH Mail Room at Proposal Deadline
Each day NSF receives a stack of proposals the equivalent of 2-3 stories high
133
ERA: A Definition
• Electronic Research Administration simply means using electronic tools to perform the activities related to research administration. Keeping step with technology and the business world.
• Goal to work more efficiently – time is money
134
ERA: What It Means for Sponsored Projects
• Less Paper
• Training in multiple sponsor systems
• ERA Initiatives from Sponsors
NEED FOR LOTS & LOTS OF PATIENCE!!!
135
ERA: Federal Transactions
• NSF FastLane– Proposal Review– Proposal Preparation & Submission– Checking Proposal Status– Project Report Submission –
Progress and Fiscal
• NIH Commons– Edison Invention Reporting – now
interagency– CRISP – searchable database of
federally funded biomedical research – Electronic Streamlined Noncompeting
Award Process (e-SNAP)
136
ERA Today• Improvements in Technology • More Customized Programs• Not Yet a Paperless Environment• Expanded Federal Participation –
Grants.Gov– http://www.grants.gov
• “a common face of the government, offering all grantees (state and local governments, universities, small businesses, etc.) full service grants processing across all functions in the grant life cycle.”
137
Electronic Data RetentionConversion of Paper Records to Electronic Form• Department of Health and Human Services (HHS)• Office of Grants and Acquisition Management
(OGAM) Action Transmittal 99-1 (8/9/99) (http://www.hhs.gov/grantsnet/gps/ogamat.htm)
– Applicability: HHS Grantees receiving the majority of Federal funding from HHS awarding agencies
– Subject: Use of Electronically Imaged Record Storage
– Purpose: Permits the substitution of electronically imaged records for original records and encourages grants recipients to do so
– Action: Organizations that would like to implement the use of electronic records may do so provided the institution establishes the appropriate procedures and notifies DHHS in writing
138
Federal Demonstration Partnership
• Intent: To reduce administrative burdens in order to increase research productivity by standardizing and simplifying federal regulations.
• Background: Began as a two year pilot program with Florida universities and five federal agencies. Originally called the Florida demonstration project.
• Goal: To demonstrate that accountability may be maintained while simplifying research administration.
• The Federal Demonstration Partnership currently governs grant awards only; contracts and cooperative agreements are not included.
139
Monitoring Requirements
Recipients are responsible for:– Monitoring each project, program,
subaward, function or activity supported by award
– Ensuring subrecipients have met audit requirements
140
a living individual; investigator obtains (1) data through intervention or (2) identifiable private information
a systematic investigation designed to contribute to generalizable knowledge
Research Involving Humans
Research
Human Subjects
Research
Human Subjects
indirect activities (survey, observation)
direct activities or intervention (interview, blood draw)
ANDANDANDANDANDANDANDANDANDAND
141
Elements of Compliance with Human Subjects Regulations
• FWA• Approval from Institutional
Review Board (institutional or local)
• Compliance with requirements - – Institutional– OHRP– Sponsor
142
To provide for the humane care and use of live vertebrate animals in biomedical and behavioral research, teaching or testing.
Use of Animals in Research, Teaching, and Testing
Research
Teaching
Testing
Research
Teaching
Testing
ANDAND
ANDAND
143
Elements of Compliance withAnimal Care Regulations
• Assurance Number
• Approval from Institutional Animal Care & Use Committee
• Compliance with requirements - – Institutional– AAALAC, OLAW– Sponsor
144
145
Research Involving Recombinant DNA Molecules
Applicability Applies to research funded by public or private agencies external to the NIH if
the Institution receives NIH funds for related research. Recombinant DNA molecules are either: (i) molecules constructed outside living cells by joining natural or synthetic DNA segments to DNA molecules that can replicate in a living cell or (ii) molecules that result from the replication of those cells. Revised guidelines issued by the National Institutes of Health in October 2000 - http://www4.od.nih.gov/oba
Institutional Requirements1. Establish and implement policies that comply with NIH
guidelines2. Establish an Institutional Biosafety Committee (IBC) that
a) has at least 5 members selected because of their expertise - 2 unaffiliated, 1 plant expert, 1 animal containment expert, and a Biological
Safety Officer if BL 3 or BL 4 or large scale research is conductedb) reviews and approves all non-exempt rDNA research c) keeps minutes and makes them available to the public on request
146
Research Involving Recombinant DNA Molecules (continued)
Institutional Requirement (continued)
3. Report as required to NIH a) the source(s) of the DNA and nature of the inserted DNA sequence
b) the hosts and vectors to be used c) whether a deliberate attempt will be made to express a foreign
gene d) containment conditions specified in the Guidelines
Exempt categories1. Those that are not in organisms or viruses2. Those consisting entirely of DNA segments from a single
nonchromosomal or viral DNA source3. Those consisting entirely of DNA from a prokaryotic host including its
indigenous plasmids or viruses when propagated only in that host or when transferred to another host by established physiological means4. Certain recombinant DNA molecules consisting entirely of DNA segment
from different species that exchange DNA by known processes
147
Research Involving Human Gene Transfer
• Investigators must:– Obtain prior RAC review, IRB approval and all
applicable regulatory authorizations for experiments involving deliberate transfer of rDNA or DNA or RNA derived from rDNA into human research participants.
– Obtain IND from the Food and Drug Administration if required.
– Submit to NIH, no later than 20 working days after enrollment, a copy of the approved informed consent document, the protocol approved by the IBC and the IRB, the IBC approval and the IRB approval, a brief written report on recommendations of the RAC and any modifications required by the FDA, any NIH grant number, the IND number and the date of initiation.
– Submit Annual Data Report Forms to NIH Office of Biotechnology Activities.
– Clinical trial sites added after RAC review, must submit materials to NIH/OBA prior to any enrollment.
– Submit Serious Adverse Events immediately to IRB, IBC, Office for Human Research Protections (if applicable) and NIH OBA, followed by full written report to each.
148
Hazardous Materials• Statutory Basis
– Sections 103 and 107 of the Contract Work Hours and Safety Standards Act (40 USC 327-330), supplemented by DOL regulations at 29 CFR, Part 5
– FAR, Subpart 23.3– OMB Circular A-110, Subpart D, Appendix
A• Applicability
– All awards over $2000 for construction– All awards over $2500 for other activities
• Requires– Notification to employees– Preparation and submission of a material
safety data sheet
149
USA PATRIOT Act• “Uniting and Strengthening
America Act by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001” was signed by President Bush on October 26, 2001.– Mission: To deter and punish
terrorist acts in the U.S. and around the world and to enhance law enforcement investigatory tools. Criminalized possession and use of a type or quantity of Select Agents not reasonably justified by bona fide research or other peaceful purpose. Criminalized possession, use, or transfer by a restricted person.
150
Data Access and RetentionBasis For Requirement:• ... "Financial records, supporting documents, statistical
records, and all other records pertinent to an award shall be retained for a period of three years from the date of the submission of the final expenditure report”…
• OMB APRIL 11, 1994 LETTER TO NSF GENERAL COUNSEL...."The term 'all other records pertinent to an award' was meant to encompass all records that were produced in connection with a grant. Therefore, laboratory records and primary data should be retained for three years and the recipient should provide access to the records.”
OMB CIRCULAR A-110 SECTION.53(b)
151
Project Close-outResponsibility:• Institution’s Sponsored Projects Office is usually
responsible for overseeing the close-out of awards.
Report Responsible Person/office• Technical Principal Investigator• Equipment Central Property Control Office• Patent/Invention Sponsored Project Office
Collaboration with PI and Technology Transfer Office
• Fiscal Accounting Office• Subrecipients Sponsored Projects Office with PI and
Accounting Office
Reports from Subrecipients Needed in Advance in
Order to Incorporate into Reports to Sponsor
152
“I already wrote the paper. That’s why it’s so hardto get the right data.”
153
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