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Post Award 101 for Principal Investigators


									Navigating the Basics of
 Sponsored Programs
 A Training Tutorial for Faculty and Staff

                           Office of Sponsored Programs
                           Web Tutorial as of 11/30/10
This Tutorial Will Cover:

     Sponsored Program
     Sponsors, Proposals &
      Funding Mechanisms
     Typical Proposal
     Cost Types
     Regulatory Environment
     Roles
     Compliance
     Red Flags
     Key WPI Contacts

                               Office of Sponsored Programs
The Sponsored Program Lifecycle


                         Office of Sponsored Programs
Who Are Our Sponsors?
 Examples include…
    Federal
      –   National Institutes of Health
      –   National Science Foundation
      –   National Endowments for the Arts/Humanities
      –   Department of Defense (Air Force, Army, Navy)
    State
      –   MA Board of Library Commissioners
      –   MA Technology Collaborative
    Industry
      –   Intel Corporation
      –   The MathWorks
      –   Raytheon Corporation
    Foundations, Associations, Foreign Organizations
      –   Alfred P. Sloan Foundation
      –   EADS Company Foundation

                                                          Office of Sponsored Programs
Proposal Types
    Letter of Inquiry - Used by foundations for screening to second
    Concept Paper - Generally, an internal working document used
     to solicit informal feedback
    White Paper - A concept paper (either unsolicited or required in
     advance of a full proposal) sent to a sponsor
    Preliminary Proposal - Often, the first stage of a two-stage
     submission process that can be either requested or required by
     a sponsor
    Formal (Full) Proposal - the submission used by a sponsor to
     determine whether a program should be funded or rejected. Full
     proposals are submitted as new, non-competitive continuation,
     competitive continuation (also called competing renewal), and

                                                  Office of Sponsored Programs
Funding Mechanisms
    Sponsors use formal agreements and these
     agreements represent exchange transactions (i.e., the
     sponsor receives something of value in exchange for
     having provided funding)
    Funding mechanisms
      – Grant (financial assistance)
      – Cooperative Agreement (financial assistance)
      – Contract (procurement or “purchase of services”)
    The mechanism (e.g., financial assistance vs.
     procurement) is determined by sponsor according to
     the performance requirements, sponsor involvement,
     and activity type of the project

                                               Office of Sponsored Programs
Funding Mechanisms
    Grant
      – project conceived by investigator
      – investigator defines details and retains scientific freedom
      – used to transfer money, property, services, or anything of
        value to recipient to accomplish a specific purpose
      – considered to be financial assistance or "support"
      – no substantial involvement between sponsor and recipient
        during project performance
    Cooperative Agreement
      – much like a grant...used to transfer money to recipient to
        accomplish a specific purpose
      – also considered to be financial assistance, but...
      – substantial involvement in the project by both sponsor and
        recipient                                                           7

                                                 Office of Sponsored Programs
Funding Mechanisms
    Contract
      – project conceived by sponsor
      – used to acquire product or services for the direct benefit or
        use of sponsor
      – generally requires strict adherence to budget
      – sponsor exercises direction or control
      – most contentious award instrument on issues such as
        ownership, indemnification, etc.


                                                  Office of Sponsored Programs
Typical Proposal Components
    Most formal (full) proposals submitted to the
     federal government and/or in response to a
     formal sponsor announcement will contain
     many of the proposal components listed on
     the following slides
    Formatting varies widely by sponsor and type
     of proposal (hard copy vs. electronically
    Less formal proposals minimally include a
     cover page, scope of work, budget, and
     budget justification                                      9

                                    Office of Sponsored Programs
Typical Proposal Components
    Title/Cover Page with appropriate signatures
    Table of Contents
    Abstract/Project Summary (normally no more than a single
    Statement of Work/Project Description
    Bibliography
    Personnel Vitae (normally, for key persons only)
    Current and Pending Support
    Budget for submitting organization and any collaborators
    Budget Justification
    Facilities/Resources Statement
    Representations, Certifications, and Assurances
    Appendices (as needed and judiciously selected)

                                                Office of Sponsored Programs
Cost Types
    Direct Costs - Direct costs are defined by the federal
     government as "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 easy with a
     high degree of accuracy."
    Examples include:
      –   Personnel
      –   Equipment
      –   Travel
      –   Professional Services/Consortium/Contractual Costs
      –   Materials & Supplies
      –   Other Direct Costs (e.g., tuition, publications, service center costs)


                                                          Office of Sponsored Programs
Cost Types
    Indirect costs (a.k.a., overhead), which are now officially called
     Facilities and Administrative (F&A) costs by the federal
     government, are defined as "costs that are incurred for common
     or joint objectives and, therefore, cannot be identified readily
     and specifically with a particular sponsored project,
     instructional activity, or any other institutional activity."
    Indirect costs are charged as a rate and include expenses that
     cannot be charged directly to grants and contracts, such as:
      –   lights and heat
      –   snow removal
      –   office supplies
      –   building maintenance
      –   the services of administrative offices (e.g., OSP, Accounting)


                                                        Office of Sponsored Programs
Sample Budget
                                                         Sample Budget

                                                                        07/01/10 -    07/01/11 -       07/01/12 -
                              Cost Categories                           06/30/11      06/30/12         06/30/13      Totals
       Senior Personnel
             J. Smith, Principal Investigator (1 Month/Year)                $7,000         $7,210          $7,426      $21,636
             R. Jones, Co-Principal Investigator (1 Month/Year)              7,034          7,245           7,462       21,741
       Other Personnel
             Postdoctoral Research Associate (12 Months/Year)               40,000         41,200          42,436      123,636
             Graduate Research Assistant (9 Months Stipend/Year)            16,650         17,150          17,664       51,463

                   Total Salaries and Wages                                $70,684        $72,805        $74,989      $218,477

       Fringe Benefits @ 26.8% of Non-Student Salaries                      14,481         14,916          15,363       43,758

                   Total Personnel                                         $85,165        $87,720        $90,352      $262,235

       Travel                                                                 5,000            5,000        5,000       15,000

                   Total Travel                                               5,000            5,000        5,000       15,000

       Other Direct Costs
             Materials and Supplies                                          3,000          3,000           3,000        9,000
             Publication Costs                                               1,000          1,000           1,000        3,000
             Graduate Research Assistant Tuition (18 Credits/Year)          11,610         11,958          12,317       35,885

                   Total Other Direct Costs                                $15,610        $15,958        $16,317       $47,885

                   Total Direct Costs                                     $105,775      $108,678        $111,669      $325,120

       Indirect Costs @ 58.2% of MTDC*                                      54,804         56,291          57,823      168,335

                   Total Costs                                            $160,579      $164,969        $169,491      $493,455

       *MTDC = Modified Total Direct Costs, which is total direct costs less equipment, tuition and the excess of the first
        $25,000 of each subcontract.

       Budget Notes:
            Annual increases for salaries and tuition in years 2 and 3 are calculated at 3%.
            Year 1 Graduate Research Assistant stipend is $1,850 X 9 months.                                                           13
            Year 1 Graduate Research Assistant tuition is $645 per credit hour.

                                                                                                             Office of Sponsored Programs
The Regulatory Environment


                      Office of Sponsored Programs
The Regulatory Environment
    Tier 1: The Regulations
 OMB Circulars A-21 and A-110
 Federal Acquisition Regulations
           Public Laws

             Tier 2: Implementation of Tier 1
                  NSF Grant Policy Manual
                NIH Grant Policy Statement
                       DFARS, etc.

                                      Tier 3: Individual Award
                                   Terms & Conditions from Tier 2
                                     Supplementing guidelines


                                                  Office of Sponsored Programs
Federal Regulations
    As a Principal Investigator, some of
     what you need to know about Tier I
     (Regulations) is summarized on the next
     few slides.
    This generalizable knowledge will help
     you to determine where to look and
     which questions to ask in order to avoid
     any unnecessary involvement in “red
     flag” transactions.

                                 Office of Sponsored Programs
Federal Regulations (Tier 1)
   Cost Principles for Educational Institutions (OMB
    Circular A-21)
     – Guide to determining direct and indirect costs on federal
        • Defines what is normally allowed and not allowed on
          Federal grants – exceptions for “major programs”
     – Allowable
        • Direct expenses, such as salary, travel, project-related
          supplies, research assistants, publications, etc.
        • Also, an expense may be allowable, but not as a direct
          expense because it is included as part of the indirect cost
          calculation (e.g., general supplies)
     – Unallowable
        • Entertainment, air travel on a foreign carrier (under most
          circumstances), lobbying costs, alcoholic beverages,
          subscriptions, memberships, etc.

                                                  Office of Sponsored Programs
Federal Regulations (Tier 1)
    Cost Principles for Educational Institutions
     (OMB Circular A-21)
    You should become familiar with the
     following two sections of Circular A-21:
      – Section F.6.b describes departmental
        administration expenses and why certain costs
        may not be charged directly to awards
      – Section J of this circular explains the allowable
        and unallowable cost categories
      – Visit:

                                                   Office of Sponsored Programs
Federal Regulations (Tier 1)
    General Administrative Requirements
     (OMB Circular A-110)
      – Prescribes standards for consistency and
        management of federal funds
      – Primary concerns for PIs are in:
         • Subpart C Post-award requirements
         • Subpart D After-the award requirements
      – To learn more, please visit:


                                             Office of Sponsored Programs
Federal Regulations (Tier 1)
    General Administrative Requirements (OMB
     Circular A-110)
        • Subpart C Post-award requirements
           –   Relates payment to performance
           –   Defines qualifying cost sharing or matching
           –   Prescribes methods for calculating program income
           –   Specifies requirements for re-budgeting actions, no-cost
               extensions, absence of PI, etc.
           –   Covers audits and allowable costs (Circular A-21)
           –   Defines requirements for property standards
           –   Establishes procurement standards
           –   Reports and records (how long and types)
           –   Prescribes conditions for termination and enforcement

                                                    Office of Sponsored Programs
Federal Regulations (Tier 1)
    General Administrative Requirements
     (OMB Circular A-110)
        • Subpart D After-the award requirements
          – Sets forth closeout procedures (e.g., timing,
            property, accountability)
          – Prescribes subsequent adjustments and
            continuing responsibilities of awardees (e.g.,
            disallowed costs, refunds of Federal cash, code
            of conduct, property requirements, record


                                          Office of Sponsored Programs
Federal Regulations (Tier 1)
    In addition to OMB Circulars A-21 and A-110,
     you should understand that the mechanism
     for determining whether the University has
     successfully complied with these regulations
     is contained in another circular – OMB
     Circular A-133 (Audits of States, Local
     Governments, and Non-Profit Organizations).
    Each year, WPI is audited on 14 separate
     compliance points to determine that it has
     complied with OMB Circulars A-21 and A-110,
     and other applicable award requirements.                 22

                                    Office of Sponsored Programs
Federal Regulations (Tier 1)
    Audits (OMB Circular A-133)
      – Defines auditee (WPI) responsibilities
      – Prescribes subrecipient monitoring
      – Sets forth 14 separate audit tests to determine
        compliance (e.g., allowability, allocability,
        records management, and timeliness,
        accuracy and completeness of reporting)
      – To learn more, please visit:


                                             Office of Sponsored Programs
Federal Regulations (Tier 1)
    Federal Acquisition Regulations (FAR)
      – Regulations that apply to contracts
        (codified at Title 48 of the Code of Federal
      – Each agency uses its own version for
        procurement actions (e.g., NASAFAR,
        DFARS, etc.)
      – Incorporates OMB Circular A-21, Cost
        Principles for educational Institutions
      – To learn more, please visit:

                                      Office of Sponsored Programs
Other Federal Regulations
    Depending on the scope of your program
     and the terms and conditions of your
     awards, other federal regulations will often
     apply, including:
      – Fly America Act – requires use of a U.S. flag
        carrier for foreign travel
      – Export Control Regulations (with prior approval of
        WPI senior administration)
      – E-Verify – requires verification of eligibility to
        work on qualifying federal contracts


                                          Office of Sponsored Programs
Sponsor Guidelines (Tier 2)
  The purpose of these guidelines is to
  implement the Tier 1 federal regulations and
  supplement them with agency-specific
  requirements. Links may be found at:

  Examples include :
       • NSF Proposal and Award Policies and
         Procedures Guide (PAPPG)
       • NIH Grants Policy Statement
       • NASA Grant and Cooperative Agreement

                                            Office of Sponsored Programs
Award Terms & Conditions (Tier 3)

    On Federal Awards
      – Additional terms and conditions may be
        added beyond the previously described
        sponsor guidelines (e.g., NSF conference
        grant guidelines, NIH training grant
    On Non-Federal Awards
      – Corporations and foundations often
        impose conditions that are more strict
        than federal regulations

                                     Office of Sponsored Programs


        Office of Sponsored Programs
Areas of Responsibility
    Principal Investigator
      –   Completion of the project scope of work
      –   Managing, processing, and justifying project expenses
      –   Monitoring the activities of subrecipients
      –   Submission of required technical or narrative reports
      –   Completion of reports for compliance (e.g. IRB, IACUC, etc.)
      –   Disclosure of inventions during the project
    Technology Transfer Office
      –   Determining the potential of inventions disclosed
      –   Filing patent applications
      –   Reporting to sponsors on inventions or patents
      –   Negotiating terms of licensing agreements
      –   Assignment of rights to inventions

                                                   Office of Sponsored Programs
Areas of Responsibility
    Property Administration
      – Tag, inventory, manage and determine disposition for all
        equipment purchased with sponsor funds
      – Screen for same, like or substitutable items
      – Report on status of equipment purchased
    Research Accounting
      – Award set-up and creation of budgets
      – Monitoring and approval of expenditures
      – Submission of invoices and other cash management
        activities (e.g., reconciliations, drawdowns, etc.)
      – Completion of financial reports
      – Distribution of and follow-ups on effort certification reports
      – Coordinate financial closeout of awards

                                                   Office of Sponsored Programs
OSP Responsibility
    Negotiating, accepting and transmitting awards
    Acting as principal liaison with sponsor for approvals
     and award modifications
    Monitoring non-financial compliance with sponsor
     terms and conditions
    Coordinating non-financial close out activities
     between WPI and sponsor
      –   Contacting PI for technical report
      –   Contacting Research Accounting for financial report
      –   Contacting Property Administration for property report
      –   Contacting Technology Transfer Office for patent report
      –   Collecting report documentation for files
    Responding to auditor inquiries regarding

                                                  Office of Sponsored Programs


             Office of Sponsored Programs
Why Should You Care About Compliance?
  University of Minnesota       University of Alabama           Northwestern University
  Misuse of federal funds            Birmingham                Committed Time and Effort
        $32 million          Effort Certification & Clinical          $5 million
                                    Research Billing
                                      $3.4 million
      Yale University                                              New York University
   Cost Transfers/Salary                                              Medical Center
         Charges                 Duke University                 Inflated Research Grant
        $7.6 million         Administrative and Clerical                   Costs
                               Expenses on Awards                      $15.5 million
                                    $1.7 million
    Florida International
    Effort Certification &                                          Harvard/BIDMC
                                                                    Costing Issues
 Direct Cost Disallowances
        $11.5 million
                                    Non-                             $3.25 million

  East Carolina University
    Questioned Costs
                                   Results                      Johns Hopkins University
                                                                  Effort Certifications
      HHS/OIG Audit
        $2.4 million
                                  at Other                            $15.5 million


                                                               Office of Sponsored Programs
Sponsor Reporting Requirements

      Technical, Progress, and/or Narrative Reports
      Project Deliverables
      Property Reports
      Expenditure and Other Financial Reports
      Cash Management Reports
      Invention or Patent Reports
      Time and Effort Reports (Internal only, but
       reviewed by auditors to verify reported effort
       is reasonable in relation to salary charges)
      ARRA Reports, as applicable


                                       Office of Sponsored Programs
Institutional Review Board
    Human Subject use in Research (IRB)
      – PI is responsible for compliance with
        DHHS protection of human subjects
        regulations-45 CFR Part 46
      – PI is responsible for compliance with
        FDA’s regulations for investigational new
        drugs and medical devices-21 CFR Part 50
      – The IRB supports efforts of Investigators
        to conduct research which protects the
        rights and promotes the welfare of human

                                    Office of Sponsored Programs
Institutional Review Board
  – WPI IRB reviews non-federally and federally
    sponsored human subject research
  – Online human subjects training and
    certificate of completion required
  – Annual reviews of protocols and adverse
    event reporting
  – Chairperson, Kent Rissmiller x5019 and
    Secretary, Ruth McKeogh, x6699


                                 Office of Sponsored Programs
Animal Care and Use Committee
   Institutional Animal Care and Use in Research (IACUC)
      – PI is responsible for compliance with Public Health
        Service Policy (PHS) on humane care and use of
        laboratory animals-review every 3 years
      – PI is responsible for compliance with USDA
        established standards for overseeing the humane
        care and treatment of animals and compliance with
        the Animal Welfare Act-annual reviews
      – IACUC oversees and evaluates programs,
        procedures and facilities for the proper care, use
        and humane treatment of animals
      – Chairperson and contact, Glenn Gaudette, x6086

                                           Office of Sponsored Programs
Export Controls
   PI is responsible for compliance with the
    Federal Export Control laws
     – ITAR – Department of State
         • U.S. Munitions List
     – EAR – Department of Commerce
         • Dual Use Technology and Articles
     – OFAC – Department of Treasury
         • Economic Trade Sanctions
   Compliance may include securing lab facilities, restrictions
    on researcher and/or student participation, restrictions on
    transmittal of information, and prepublication

                                               Office of Sponsored Programs
    Biological, Radiation, Occupational and
     Laboratory Safety
      – PI is responsible for complying with a
        variety of federal regulations and WPI
        policies associated with each type of
        safety issue
      – Online lab safety training requirement for
        lab safety
      – Reports to Safety Office, Dave Messier,

                                     Office of Sponsored Programs
Red Flags


            Office of Sponsored Programs
Be Prepared for Anything…


                      Office of Sponsored Programs
Risk Areas
    Some of the most common and highest risk
     areas that create “red flags” are:
      – Cost transfers that are not properly justified, are
        not timely, and/or attempt to move a deficit from
        one award to another
      – Inaccurate effort reporting and failure to match
        pay for performance
      – Failure to perform subrecipient monitoring
        activities to ensure performance
      – Erratic spending patterns, especially just prior to
        expiration to use available funds

                                           Office of Sponsored Programs
WPI Contacts
    Associate Controller
      – Yvonne Harris, x5755,
    Research Accounting Manager
      – Heather Bilotta, x5422,
    Technology Transfer Director
      – Mike Manning, x5834,
    Property Administrator
      – Clarence Plant, x5137,
    University Compliance Officer
      – Mike Curley, x6919,

                                         Office of Sponsored Programs
OSP Contacts
    Director
      – Franc Lemire, x5811,
    Associate Director, Pre-Award
      – Ted Russo, x5583,
    Associate Director, Post Award
      – Tina DeVries, x6716,
    Assistant Director
      – Tammy Houle, x5489,
    Proposal Services Administrator
      – Jeff Stokes, x5235,
    Sponsored Programs Coordinator
      – Kayla Carroll, x5359,

                                            Office of Sponsored Programs
Please Contact OSP with Questions about This Tutorial


                                     Office of Sponsored Programs

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