Pre Award

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					Get Me the Money!
Pre-Award Activities

                                 Audit Forum
          Joyce Freedman, Assistant Vice Chancellor,
              Research Administration & Compliance
                                    UC, Berkeley
                                  February 24, 2004
Vice Chancellor for Research
Research Administration Organization
      Sponsored Funding at Berkeley

                     Awards at Berkeley, 2002-2003

All Agency Sources
    Agency Type            Ê    Budget Period      Ê    Project Period

Federal                         $269.6     (61%)        $295.2     (64%)
Nonprofit Agencies                75.0     (17%)          89.5     (19%)
State of California               58.7     (13%)          39.2      (8%)
University of California          18.0      (4%)          22.6      (5%)
Industry                          15.5      (3%)          11.2      (2%)
Other Government                   4.4      (1%)           4.3      (1%)
Grand Total                Ê   $441.2    (100%)    Ê   $461.9    (100%)
Awards by Sponsor (budget period), 2002-
2003

                              4%




                17%




                                       60%




                         3%
                                   Federal
                                   Industry
          16%

                                   Non-fed Govt
                                   Non-profit
                                   UC
  Total = $461,900,000
Recent History of Federal Regulations
Recent history of regulations governing federal
funds
   The 90’s – more regulation than before
     use of funds more restricted (A21, F6B)

     intellectual property (Bayh-Dole)

   Post 9/11 – tightening security and increased
    oversight
     security

     publication restrictions

     foreign scholars
Recent history (con’t)


   Changes in the environment in the 90’s
       F6B
       Decentralization of responsibility
       Increased awareness of audit issues, greater
        focus on audit by the present administration
Hot Issues -- Always and New
Hot issues

   Cost sharing and matching funds
       Reporting
       Cost sharing of effort
   Effort and effort reporting
   Equipment management
   Sub-recipient monitoring
   Cost transfers
Hot issues

   Export controls
   Intellectual property
   National security
       Restrictions on publications
       Approval of publications
       ITAR
Hot issues

   Conflict of Interest
   Use of human subjects in research
   Use of animal subjects in research
   Use of regulated materials (chemicals,
    biologicals, drugs)
   Use of select agents
   A Road Map to Funding @ UCB
P ROP OSA L A ND AWA R D STEP S                                                                        A CT IONS


                                                                                                       C o nt      h
                                                                                                             act t e Spo nsored Pr oj e t c s
Step 1.    The Princ ipal In v e  g tor se
                                sti a      ek s exte nal fund i g
                                                    r         n             NO                          O ffic e or searc h SPO we   b for
                       c     g nc y a
            k n ows wh i h a e        nd its gu idelines?                                                a e
                                                                                                          g nc y gu i ed line           n
                                                                                                                              s or fund i g
                                 YE S                                                                                       u
                                                                                                                    op por t nities



Ste p 2. PI p repar e              l c
                       s pro posa a cor ding to a e g nc y                                              Send dr a  ft to SP O . SPO staff
gu id el in es an d UC Berk le y po li ci es. Ob tai ns
                             e                                                                                 v             d         n s
                                                                                                       will r e iew & pr ov i e co mme t
          p
        a pr ov al s to b e PI o r use different I DC rate.                                                        r
                                                                                                         This is st on gly recom me nd e d




Step 3.            al
           Pr opo s s uses hu ma s or anima
                                  n           ls as res  r
                                                       ea ch                YE S                       Su bmit Pr otoc ol to A C UC ,
                           c s or EH &S is
                     subj e t             sues?                                                              C PHS & /or EH&S .
                                 NO



Step 4.    Pr opo s             s      b
                   al inv o lv e c olla orat iv e s baward s
                                                   u                        YE S                                   h             l
                                                                                                       A co py of t e pro posa & a
                        to othe     n tit t
                                  r i s  u ion s?                                                      le   r
                                                                                                         tte of co ncu rr enc e from
                                   NO                                                                          r
                                                                                                       subawa d i s     u ion is r e uired
                                                                                                                   n tit t          q
                                                                                                                 n
                                                                                                       Must b e i clud e              al
                                                                                                                         d in pr opo s .



Step 5.    Pr opo s             s           r
                   al inv o lv e c ost sha ing fro m UC B or                YE S                           tt
                                                                                                       A le er fro m o f     l
                                                                                                                        ficia with
                                        r y
                               third p a t ?                                                            u h   ty to comm i f nds
                                                                                                       a t or i              t u
                                 NO                                                                                n
                                                                                                       must b e i clud e d in pr opo s  al
                                                                                                                      u
                                                                                                       m at eri al s s bm i tt ed t o SPO



Ste            s                l
    p 6. PI fill o ut P ro posa Rou t ing F or m, ro utes                                              Ch a                        v ews
                                                                                                           ir or O RU Director r e i
pr opo s         u
        al and s ppo rting do cum e    nts to De a t
                                                p r ment/O R U                                         pr opo sal for p ro grammatic is sues
                            for appr ov al.                                                                  ,      ,
                                                                                                       spac e time cost sharing , e  tc.
                                                                                                       Sign a                n
                                                                                                             tur e on PR F i dicates
                                                                                                             n
                                                                                                            e dor s      n
                                                                                                                    eme t of pr oj ect.

Ste p 7. PI b ring s s ign e          n            n l
                             d PR F a d the orig i a p ro posa l
                  v                l
to SPO for r e iew and officia univ ersit    y endo rse  ment.                                                     Dea       v
                                                                                                                        n r e iews
C o rr e          r    u
        ction s a e ret rn e d to PI . Pro posa ret rn to PI
                                                 l   u                                                 pr opo sal for p ro gramma  tic issues
        for mai          g nc y or S PO ma
                ling to a e                     .
                                             ils Ele t onic
                                                     c r                                                       ,      ,
                                                                                                        spac e time cost sharing , e    tc.
                pr opo s     u
                        als s bmit ted by SPO st   aff.                                                   Sign a                n
                                                                                                                 tur e on PR F i dicat es
                                                                                                             n
                                                                                                            e dor s       n
                                                                                                                     eme t of pr oj ect.

 Ste   .
    p 8 Pr opo s         n ered into SPO 's d a
                  al is e t                    tabase.
PI a            fie
     nd A U n oti   d that pr opo sal has bee n subm i tted.

Step 9.                c iv es pr op os
           A gency r e e               al. Be i s the r e iew
                                             g n         v                                              Q ues  tions a                 l
                                                                                                                        bo ut p ro posa &/o r
               pr oc ess. C an tak e u p to 9 mo nths                                                  pr oj e t r e
                                                                                                              c       r
                                                                                                                    fe red t o S PO

Step 10.    Ag enc y decides to fun d pr oj ect?                            NO                                  fie
                                                                                                       SP O n oti        n
                                                                                                                   s PI a d A U
                               YE S

Step 11. Aw ard terms are d e  r
                             te mine              ia
                                    d and nego t tions
begin betwee            n
            n agen cy a d SPO . A cc e ptan ce o f a ward
                           n liz
                       is fi a  ed.
                            YE S

Step 12. Ag e       k s        r
             nc y ma e the awa d a d s
                                    n   ends awa d r                                                   SP O n otifies PI/ A U/ and
                             r  s e
     do cuments to SPO . A wa d i  nte e
                                      r d in C o eus.                                                      r mu ral F unds A cc oun t
                                                                                                       Ex t a                        ing

                                                                    A c cou nt es  b ished s
                                                                                 ta l       pendin g
                                                                                  begins
Tools to develop proposals

            For proposal preparation

   The Request for Proposals (RFP)
   The Proposal Review Form (PRF)
   Federal circulars, University and sponsoring
    agency policies
Request for Proposals (RFP)

   What is the deadline?
    Receipt or postmark?
   Who in your unit is responsible for pre-award
    activities?
    Someone should review the RFP to identify
    information the faculty need to prepare the
    proposal and to highlight potential issues that
    must be resolved prior to proposal
    submission.
RFP: Eligibility

   Basic information about who can apply
    (individuals, institutions, tax status,
    citizenship status, etc.)
   Does the sponsor limit the number of
    proposals from the institution?
       “Limited submissions” require additional review.
       Submit to SPO by established deadline.
   Is there a pre-proposal stage?
RFP: Proposal/Submission Instructions

   Forms and general submission guidelines
   Budget and budget justification requirements
    and limitations
   Indirect cost limitations
   Paper or electronic submission
       Electronic submissions are often more difficult and
        time consuming than paper submissions.
RFP: 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.
RFP: Award Administration

   Type of award
       Grant: Used for the conduct of research or other
        program. Used when the sponsor anticipates no
        substantial programmatic involvement with
        grantee.
       Contract: Used to procure a tangible product or
        service (deliverable) with specific obligations for
        both sponsor and recipient.
       Cooperative Agreement: Similar to grant but
        sponsor anticipates having substantial
        involvement in project activities.
RFP: Award Administration

   Collaborative project?
       Intra-institutional, multidisciplinary project
       Inter-institutional project
       University-industry or University-government
        project
RFP: Award Administration

   Award conditions
       General conditions (general guidelines often
        contained in another publication)
       Federal Demonstration Partnership (FDP)
       Special provisions or conditions
       Reporting requirements
RFP: Award Administration

   Publications
       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.
RFP: Award Administration

   Classified or restricted projects
       Is the project intended to be classified, secret or in
        anyway restricted by the federal government,
        corporate sponsor, or other funding organization?
       It is against University policy to accept such
        awards.
RFP: Award Administration

   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.
RFP: Award Administration

   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.
RFP: Award Administration

   Third party liability (legal)
       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.
RFP: Award Information

   Anticipated funding available
   Estimated number of awards
   Anticipated type of award
   Agency contacts
   Reviews, continuation of support, etc.
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: PI & Campus Information

   Principal Investigator (PI) Policy
       Only voting members of the Academic Senate
        automatically receive PI status on research
        projects or Project Director (PD) status on
        education or public services projects.
        Others may serve as PI or PD only by exception.
       See SPO website for policy and exception
        procedure.
       Route through cognizant dean to VCR.
PRF: PI & Campus Information

   Administering Unit
       Guarantees the appropriate facilities and
        infrastructure (including administrative support) is
        available to conduct the project.
PRF: Proposal/Sponsor Information

   Basic information from the RFP and PI.
   What is the deadline and when will you be
    able to send the proposal to SPO for review?
    SPO requests 10 working days and requires
    minimum 2 full working days in advance of
    the agency deadline.
   Paper or electronic submission?
PRF: Project Information

   What space is required?
       Is space available?
       Will the project be on or off-campus?
        Reflected in indirect cost rate applied.
       Are renovations required?
        Can the proposed project pay for costs of
        renovations?
PRF: Project Information

   PI release time?
       Approval letter from the appropriate Department
        Chair or Dean is required when requesting 50% or
        more release time.
   Cost sharing or matching?
       Letters from the person authorized to commit the
        funds or resources must be provided to SPO at
        proposal submission.
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 $1,500 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
        dictating an IDC rate different from federally
        negotiated rates. Most often applies to 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, routed to VCR and
        then to OP.
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.
PRF: Compliance Reviews

   Human subjects?
   Vertebrate animals?
   Custom antibodies?
   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, UC Discovery Grants, American
        Cancer Society, or American Heart Association:
        Federal Financial Disclosure Form and PRF
        Addendum.
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.
       Nora Watanabe reviews PRF/proposals for Vice
        Chancellor Burnside’s approval.
   Dean of School or College
Circulars, Policies, and Procedures

   RFP will indicate which Federal 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.
Who can submit proposals?

   The Sponsored Projects Office (SPO) is the
    only Berkeley campus office delegated to
    accept or execute extramurally sponsored
    awards on behalf of the Regents of the
    University of California.
Post-Submission Communications


   Requests for additional information from
    sponsor
   Award/contract negotiations
       Scope of work changes
       Budget changes
   Declinations
Resources

   Sponsored Projects Office
       The campus “experts” on pre-award activities
       Quick guides -- paper form and on the web
       Web pages: provide important information
           Indirect cost rates
           Salary escalation projections
           Employee benefits projections
           Forms, policies, procedures, web links
    Help! RAC and SPO

   Web site
   Research Advocate
   Quick Guides
   Quick News
   People