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Pre-Award Research Administration by forrests

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									Pre-Award Research Administration
RAC Forum
March 2007

Marcia Smith AVC-RAC

Pre-Award Research Administration Agenda
• Requirements for Grantee Institutions
– – – – Institutional Compliance Infrastructure Who Can Submit Proposals? Institutional Review Deadlines and Review Schedules

• All Research $ is Not the Same
– Sponsor Policies and Procedures – Types of Awards – Grants vs. Contracts – Types of Activities

Pre-Award Research Administration Agenda
• The Solicitation – RFP’s, PA’s, BAA’s, Guidelines, Instructions
– – – – – Proposal Essentials Proposal Review Form – Review Checklist Award Terms and Conditions On-Line Grant Submission Grant Budget Essentials
• Modular to Cost/Pricing Data • Cost Principles • Justifying Admin Costs as Major Project

Pre-Award Research Administration Agenda
• Roles and Responsibilities • Grant Issues After Award
– Post Submission Communications – Other Support – Changes – Reporting

• Case Studies • Resources

Requirements for Grantee Institutions:

Institutional Infrastructure • Grant and contract awards are made to Institutions not to Principal Investigators • To be eligible to accept awards, institutional infrastructure must ensure compliance with all applicable policies, Federal statutes, and regulations

Institutional Infrastructure
• Compliance Assurance - grant & contract administration, IRB, IACUC, safety, scientific misconduct, conflict of interest, intellectual property protection...

• Financial Management Systems accounting systems, indirect cost and patient care rate agreements, financial reporting capabilities, audit procedures...

Institutional Infrastructure
• Industry Alliances Office: corporate sponsored research agreements, intellectual property issues, material transfer agreements… • Research Administration and Compliance: proposals to federal, non-profit, and foundation sponsors; award data and set-up for all research funds; financial conflict of interest compliance; human subjects research compliance; animal subjects research compliance… • University Relations: philanthropic gifts, private donors… • Extramural Funds Accounting: post-award fund administration, audit coordination, financial reporting… • Environmental, Health & Safety (EH&S): laboratory safety, radiation safety, bio-safety, laser safety…

Research Administration and Compliance
• • • • • Office for Animal Care and Use Committee Office for Protection of Human Subjects Sponsored Projects Office Financial Conflict of Interest Administration RAC Information Systems Support

(Collaborating with UCOP, EFA, IPIRA, EH&S, IS&T…)

Research Administration and Compliance Performance Requirements
• Customer Service – support to investigators throughout the contract/grant life cycle • Compliance – ensure compliance with institutional, federal, state and sponsor policies: administrative, financial, and programmatic monitoring and reporting commitments • Communication – communicate opportunities, policies, emerging/strategic issues and provide needed training

Research Administration and Compliance: Some Goals
• • • • • • • Increase operational capacity to manage growth in research program volume and complexity Focus on assurance of institutional compliance Improve services to investigators and staff Expand access to timely and accurate information to support strategic management decisions Ensure necessary RAC staff training and professional development to maintain cutting-edge RAC operations Expand training and communication to research community Support and prepare for Federal and other sponsor reinvention, including electronic research administration (eRA) initiatives: Grants.gov, Proposal Central, etc.

Institutional Review
• All research proposals to external sponsors must be reviewed and approved by the authorized institutional office BEFORE submitting to sponsoring agency, foundation, or company! • All research proposals require Proposal Review Form (PRF) signed by Principal Investigator (PI), Co-PI, Department Chair or ORU Director and Dean of School or College. • SPO Administrators on Federal and Non-Federal teams are assigned to review proposals based on sponsoring agency – see: http://www.spo.berkeley.edu/StaffAgency.html

Who can submit proposals?
• The Sponsored Projects Office (SPO) and the Industry Alliances Office (IAO) are the only Berkeley campus offices delegated to accept or execute extramurally sponsored awards on behalf of the Regents of the University of California.

All Research Money is Not the Same

$$$$$$$$$$$$

Government, Non-Profit and Industry Sponsors
Competitive Awards or Negotiated Agreements

Grants Contracts Subcontracts Gifts Other Agreements

Types of Funding Agreements
• Government, non-profit, industry sponsors • Competitive awards, negotiated agreements • Grants, Contracts, Subcontracts, Gifts, Other Agreements • Fellowships, Institutional Training Grants, Career Development Awards, Research Projects, Cooperative Agreements, Task Ordering Agreements…

Government Contracts RFP = Request for Proposal =

Government Contract
• Procurement of specific goods or services -statement of work and deliverables • Governed by Federal Acquisition Regulation (FAR)

• Requirement for certified cost and pricing data -pre-award audit

Government Grants
RFA = Request for Application = Government Grant
• Financial assistance for approved scope of work -specific aims and progress reports • Governed by
– OMB Circular A-110 (Uniform Administrative Requirements for Grants and
Agreements With Institutions of Higher Education, Hospitals, and Other NonProfit Organizations)

– FDP Terms and Conditions – Sponsor Grants Policy

• Requirement for consistency in cost estimating – (increasing use of “modular grants”?)

Differences Between Contracts and Grants
• Government initiates the contract Statement of Work • Greater Government control/direction of contract project • Contract proposals are evaluated against technical evaluation criteria crafted for that project • Contract award may include conduct of negotiations with objective of reaching a “fair and reasonable price” and opportunity to submit revised proposals after negotiations are concluded • Contracts are subject to protests, claims, terminations for default or convenience, and penalties for nonperformance

Differences Between Contracts and Grants
• Most contract awards are competitive. Under certain authorities, sole source (noncompetitive) awards are permitted. • Contracts are subject to public policy initiatives and socio-economic programs such as contracts reserved for small businesses, evaluation of small business participation, and a requirement for acceptable plans to subcontract with small businesses, small disadvantaged businesses, historically-underutilized small businesses, women-owned small businesses, and veteran-owned small businesses.

Analysis of the RFA/RFP
• Who in your unit is responsible for preaward activities?
– The responsible administrator should review the RFA/RFP to identify information the faculty need to prepare the proposal and to highlight potential issues that must be resolved prior to proposal submission.

• What is the proposal deadline? • Receipt date or postmark date? • Electronic or paper submission?

Plan for Deadlines and Review Schedules
• Sponsor Receipt Dates • Departmental Review • Institutional Review • IRB Review?

• IACUC Review?

Applicant Eligibility
• Who can apply (types of individuals, institutions, tax status, citizenship status, etc.)? • Does the sponsor limit the number of proposals allowed from the institution?
– “Limited submissions” require additional review. – Submit preliminary to SPO by established deadline. – Institutional review committee determines institutional nominees for limited submissions.

• Is there a pre-proposal stage? Letter of intent?

Proposal Submission Instructions • Forms and general submission guidelines • Paper or electronic submission
– Electronic submissions may be more time consuming than paper submissions.

• Budget and budget justification requirements and limitations • Indirect cost limitations

Proposal Submission Instructions
• Cost sharing or matching requirement
– Cost sharing: Arrangement in which more than one party supports a project. UCB policy allows cost sharing only when required by the sponsor and incorporated in the program announcement. – Matching: Funds raised from sources outside the institution to support a project. Federal funds cannot be used to match another federally funded project. Personnel effort and reduced indirect costs cannot be used as matching.

Proposal Planning
• Collaborative project?
– Intra-institutional, multidisciplinary project – Inter-institutional project – University-industry or Universitygovernment project

Proposed Terms and Conditions of Award
• Award conditions
– Review general conditions (often contained in another publication) – Review Federal Demonstration Partnership (FDP) terms – Look for and carefully review special provisions or conditions – Give careful consideration to feasibility and cost of reporting requirements

Proposed Terms and Conditions of Award
• Publication Terms
– Are there any restrictions on the publication of results of the proposed work? – Has the sponsor required that they approve or accept the content of publications or technical deliverables? – The University cannot accept any fundamental limitations on the freedom to publish.

Proposed Terms and Conditions of Award
• Classified or restricted projects
– Is the project intended to be classified, secret or in any way restricted by the federal government, corporate sponsor, or other funding organization? – It is against University policy to accept such awards.

Proposed Terms and Conditions of Award
• Foreign nationals
– Does the sponsor require that foreign nationals be listed and named at the time of the proposal or award? – Is the sponsor asking for a background check on members of the project team? – University policy states that discrimination in employment based on citizenship is unacceptable.

Proposed Terms and Conditions of Award
• Intellectual property (IP)
– Does the sponsor insist on ownership of the intellectual property or the data that results from the research project? – The IP and all original data belong to the Regents of the University and cannot be owned by the sponsor.

Proposed Terms and Conditions of Award
• Third party (legal) liability
– Anyone other than the sponsor or proposer can be a third party (i.e. subcontractors, consultants, even interested parties that are not part of the agreement.) – Does the sponsor require that the University take on third party liability when undertaking the research activities? – The Regents expressly prohibit doing so.

Proposed Terms and Conditions of Award
• • • • • • • Anticipated funding available Estimated number of awards Anticipated type of award Invoicing requirements Reporting requirements Agency contacts Reviews, continuation of support, etc.

Regulations, Policies, and Procedures
• RFP will indicate which Federal regulations, circulars and sponsor general guidelines apply.
– Use the circulars, policies, and procedures to determine what is allowable and can be included in proposal preparation.

• When policies conflict, the most restrictive policy applies. • When in doubt, ask! • It is better to acknowledge and resolve issues prior to award whenever possible.

Proposal Review Form
• A Proposal Review Form (PRF) is required with every proposal submitted through SPO. • Faculty and other academic employees who receive any part of their salary through the University, or whose activities use any University resources or facilities, must submit their proposals through SPO. • PRF is available from the SPO website.

PRF: Project Information
• Indirect costs (IDC)
– Federally negotiated rates apply to all projects. – “Base” for calculation is modified total direct costs (MTDC). MTDC excludes:
• equipment (useful life one year or more, cost $5,000 or more) • capital expenditures • patient care charges • tuition remission, scholarships, or fellowships • rental costs of off-site facilities • the portion of each sub award in excess of $25,000.

– See SPO website for current rates.

PRF: Project Information
• Indirect costs
– Off-campus rate: projects conducted at facilities not owned or leased by the University. If project uses leased space and lease costs are directly charged to the project, also use off-campus rate. – Projects conducted in both on- and off-campus locations: either the on-campus or off-campus rate is applied consistent with the location of a majority of the work (based on salary cost). – Use of both on-campus and off-campus rates for a single project may be justified if 25% or more of the total project costs can be identified with each rate AND total salary costs exceed $250,000. – Not sure which rate to use? Contact SPO.

PRF: Project Information
• Indirect costs
– Campus automatically grants waivers or reductions of IDC for most agencies that have formal policies that require an IDC rate different from federally-negotiated rates. Usually it is non-profits or foundations that limit IDC for all awards by policy. – IDC waivers considered only for projects that rigorously meet UCOP criteria for “vital programs.” See SPO website for criteria and other details. – Waiver requests are sent to SPO for review and analysis in preparation for consideration by VCR Office. Waivers endorsed by VCR are forwarded to UCOP for final approval.

PRF Project Information
• Collaborative sub-agreements?
– A sub-agreement or sub-award transfers a portion of the scope of work or substantive effort of the prime agreement to another institution or organization (the sub-recipient.) – A statement of work, budget (including cost share or matching, if required), and official institutional endorsement is required for any sub-agreement as part of the proposal submission.

• How do you differentiate routine purchased services from collaborative sub-agreements?

PRF: Compliance Reviews
• • • • • • Human subjects? Vertebrate animals? Radiation, Laser, Imaging proposed? Environmental health and safety issues? Select agents? See PRF instructions for procedures— SPO sends proposal copies to CPHS, ACUC, or EH&S, as necessary. Department works directly with compliance unit.

PRF: Compliance Reviews
• Disclosure of financial interests required?
– Disclosure of financial interests (investment, income, loan, gift, or travel payment) is required for those with principal responsibility for a research project. – For non-governmental entities: Form 700U, Statement of Economic Interests. – For NSF, DHHS, CIRM, UC Discovery Grants, American Cancer Society, or American Heart Association: Federal Financial COI Checklist and Disclosure Form if required.

PRF: Signatures/Approvals
• Principal Investigator and Co-PI • Department Chair or ORU Director
– In cases where the ORU Director is also the PI or Co-PI and the unit does not report through a cognizant Dean, send PRF and proposal to the Vice Chancellor for Research for secondary signature.

• Dean of School or College

Proposal Review Checklist
• Electronic application Complete application, with final research plan, due to SPO not less than five (5) business days before sponsor deadline. • Paper application due to SPO not less than ten (10) business days before sponsor deadline.
See “Proposal Checklist” at: http://www.spo.berkeley.edu/guide/checklist.html and “Quick Guide to Proposal Review and Submission” http://www.spo.berkeley.edu/guide/submitquick.html

Online Grant Submission
• Electronic grant application process using the Grants.gov interface required for all federal agencies (PL 106-107). • Grants.gov “Find” and “Apply” capabilities implemented by agencies on an incremental basis. • Standard Form 424 grant application form will be used by all federal grant agencies, with agency-specific “R&R” Form implementation.

Online Grant Submission
• Funding opportunities – PAs, RFAs and other solicitations are posted on the Grants.gov website. • SF424 R&R Forms are unique to each opportunity and must be downloaded for each funding opportunity. • Use “Form Filler” and “Form Checker” tools at SPO website.

Online Grant Submission
• Non-federal sponsors are using “Proposal Central” or their own on-line submission systems. • Contact your SPO representative as soon as you know you plan to respond to a solicitation that will require electronic submission. • Look for periodic communications from RAC to keep updated on changes and developments.

Proposal Essentials
Encourage your PI’s to

START EARLY!
WARNING: Grants.gov and other electronic proposal submission systems have “hardwired” validation protocols that limit SPO staff’s ability to “work around” the system.

Grant Budget Essentials
• Estimate and charge costs consistently • Use established institutional rates
– – – – Fringe benefits Animal care Recharge fees for services Facilities & Administrative Costs (Indirect Costs)

• Justify non-routine requests • Include only allowable costs • Look for “Modular” budgets from NSF following NIH lead.

The Modular Research Grant: Features at a Glance
• Applies to NIH research grant applications requesting up to $250,000 direct costs per year • Request total direct costs in modules of $25,000, reflecting appropriate support for project. No future year escalations

• Typical modular grant application requests the same number of modules in each year
• Provide budget narrative regarding Personnel by position, role, and level of effort

The Modular Research Grant: Features at a Glance
• Include a total cost estimate for any Consortium/Contractual arrangements
• Additional narrative budget justification allowed only if there is a variation in the number of modules requested • Additional budget justification requested "just-in-time" only in exceptional circumstances • Make non-categorical, total direct cost awards

• Eliminate line item re-budgeting review requirements

Grant Review and Award: Roles and Responsibilities • Scientific Review Administrator
• Program Official • Grants Management Officer • Grants Management Specialist • Authorized Institutional Official

• Principal Investigator

Scientific Review Administrator
• Performs administrative and technical review of applications and is initial point of contact for applicants • Overall responsibility for the peer review process
– Manages peer review activities – Selects reviewers – Prepares review summary – Provides information about the review process and recommendations

Program Official
• Responsible for programmatic, scientific, and technical aspects of assigned grants

• Identifies areas of scientific importance and develops research programs and initiatives to meet the mission of the agency • Monitors scientific progress

Grants Management Officer
• Responsible for the business management of the grant award • Only agency official authorized to obligate agency to the expenditure of funds or to change the funding, duration, or other terms and conditions of award • Focal point for approval requests • Interprets and ensures compliance with Federal regulations, policies, and procedures

Grants Management Specialist
• Agent for the Chief Grants Management Officer

• Monitors financial and administrative aspects of projects
• Analyzes grant applications

• Reviews and responds to grantee inquiries and requests
• Interprets and ensures compliance with Federal regulations, policies, and procedures

Authorized Institutional Official
• Designated representative of the grantee organization in matters related to the award and administration of its sponsored agreements, including those that require sponsor approval of changes in award terms and conditions
• Signature of this official is required for all official correspondence with sponsor

Authorized Institutional Official
This Official’s signature on a grant application:

• Certifies that the applicant organization will comply with all applicable assurances and certifications referenced in the application
• Assures that the applicant organization will be accountable for the appropriate use of funds awarded and for the performance of the grant-supported project or activities resulting from the application • Attests to the fact that all information contained in the application is true and complete and is in conformance with Federal and organizational requirements

Principal Investigator
• Responsible for the scientific aspects of the grant and for the day-to-day management of the project • Responsible for ensuring compliance with financial and administrative requirements of the grant award • Responsible for maintaining contact with:
– Agency Program Official regarding scientific or technical issues of the project – Agency Grant Management Officials concerning business and administrative aspects of the award (AFTER conferring with department and institution reps)

Principal Investigator
Works closely with organization officials to:

• Create and maintain necessary documentation, including both technical and administrative reports
• Prepare justifications

• Ensure Federal support of research findings is appropriately acknowledged in publications, announcements, news programs, etc.
• Comply with organizational as well as Federal requirements

Department Research Administrator
The PIs are responsible for the overall management of their awards. The role of the Research Administrator is to:
– Help PI manage awards within applicable policy
• Know A-21 & sponsor policy • Apply A-21 and sponsor policy to local situations • Apply “Prudent Person” tests

When Your Grant is Selected for Award: Post-Submission Communications
• Requests for additional information – IRB approvals – IACUC approvals – Other support

• Award/contract negotiations

When Your Grant is Selected for Award: Post-Submission Communications

• Scope of work changes • Budget changes • Declinations

Change in Scope Requires Prior Approval
Change in Scope is a change in direction, type of training, or other areas that constitute a significant change from the aims, objectives, or purposes of the originally approved project Whenever you are contemplating significant postaward changes and you are uncertain about the need for prior approval, consult, in advance, with your:
– Departmental advisor – Office for Sponsored Research – Agency Grants Management Officer/ Specialist

Actions Likely to Indicate Change in Scope
• Change in the specific aims approved at award

• Change from the approved use of animal or human subjects (substitution of one animal model for another)
• Shifting research emphasis from one area to another

• Applying a new technology
• Transferring the performance of substantive programmatic work to a third party through consortium agreement, contract, or other means

Actions That May Indicate Change in Scope
• Change in key personnel whose expertise is critical to the approved project
• Significant rebudgeting.

Change in Status of PI and Other Key Personnel Requires Prior Approval
• Must notify sponsor if the PI or other key personnel named in the award/contract will: – withdraw from the project entirely – be absent 3 months or more – Significantly reduce time devoted to the project
• Must request approval of a substitute PI/key person • Must notify the sponsor in writing if we wish to terminate because we cannot make suitable alternate arrangements

Resources
• Your PI and Department
– How important is this proposal to our unit? – Is the appropriate infrastructure in place? – Previous proposals and award experience can provide valuable information. – BAIRS reports can provide estimates of similar costs for use in proposal budgets.

Resources
• Sponsored Projects Office
– The campus “experts” on pre-award activities – Quick guides: provided as handouts – Web pages: provide important information
• • • • Indirect cost rates Salary escalation projections Employee benefits projections Forms, policies, procedures, web links

Questions?

Renewal (or Close-out)
Annual Report (Year 3)

Grant Life Cycle
Draft Proposal

Administrative Review Scientific Review Review Boards

Annual Report (Year 2)

Human Studies

Annual Report (Year 1)

Grant Award

Animal Studies Sponsor

Account Setup

Life Cycle Timeline ...
11 12 10 9 8 7 1 2 3

3 wks
Draft

9 Months

12 Months

Annual Report

3-5 Years
Renewal

6

4/10./98 5

Partners IS Y.O.D.A. Update


								
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