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Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium at Mission Bay & Room 116 at the Fresno Campus & Live Webcast Contracts and Grants Accounting

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Page 1: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Research Administration Town Hall

Thursday, January 29, 201510:00-12:00 PM

HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium at Mission Bay & Room 116 at the Fresno

Campus & Live Webcast

Contracts and Grants Accounting

Page 2: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office 2

Agenda

Topic Speaker Dual Usage of Research Peili Zhu Export Controls Stephanie Morgan Uniform Guidance Nilo Mia, Regnier Jurado, Rick Blair On & Off Campus F&A Changes Rick Blair Cost Share Guidance Clarification Rick Blair NOT-OD Updates Joyce Abe Award Hot Topics Michael Grafton

Page 3: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

3Controller’s Office

Export Controls

Page 4: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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What is an Export?

An “export” occurs anytime an item or information is exchanged

Sendingtransferring or taking

tangible items and information outside of

the U.S.

DisclosingReleasing information in

any format accessible including visual and oral

disclosure, technical data, technology to a non U.S.

person, in the U.S. or abroad.

Providing

technical assistance, training, repair, or

other services for, or on behalf of, foreign nationals or entities,

whether in the U.S. or abroad.

Page 5: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Export Control and Responsible Agencies

The U.S. government maintains three primary sets of export control regulations that may impact University research. • The Department of Commerce Export Administration Regulations (EAR) regulate

exports of commercial items with potential military applications and dual-use items. These regulations include: Commerce Control List (CCL), Denied Persons List, Entity List.

• The Department of State International Traffic in Arms Regulations (ITAR) regulate exports of items and services specifically designed for military applications. These regulations include the U.S. Munitions List (USML)

• The Treasury Department’s Office of Foreign Asset Controls (OFAC) prohibits transactions with countries subject to embargoes and trade sanctions. Sanctioned countries include: Iran, Syria, China, North Korea, Sudan and Russia. These regulations include the Specially Designated National List (SDNL).

Page 6: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Fundamental Research Exclusion

information that qualifies as “fundamental research” is not subject to export control regulations.

Fundamental Research does not include:

Transactions involving embargoed sanctioned

countries and individuals

Controlled technology and

data received from a sponsor

Research involving creation or use of

encryption

Exports of software, technology, biological

material, chemicals and hardware

Defense articles and export restricted

activities

These activities are not protected and our subject to export control.

Page 7: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

What might need a license?

Chemical processing equipment (ECCN 2B350) Software Technology (Development, Production, Use) Foreign worker in US facility (deemed export) Biological agents and genetic elements (1C351-1C360) Chemicals (ECCN 1C350-354) Biological processing equipment (ECCN 2B352 - such

as BSL 3 and 4 facilities)

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Page 8: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Commerce Control List (EAR)

Example ECCN:6A001Category 6-Lasers/SensorsA-Components001-National Security

A= Systems, Equipment and Components

B=Test inspection/Product Equipment

C=Material

D=Software

E=Technology/Tech Data

000-099-National Security

100-199-Missile Technology

200-299-Nuclear Proliferation

300-399-Chemical/Biological

900-999-Unilateral Foreign Pol.

980-989-Crime Control

990-999-Anti-terrorism or UN

0-Nuclear & Miscellaneous

1-Materials, Chemicals, Microorganisms and Toxins

2- Materials Processing

3-Electronics

4-Computers

5-Telecommunications

5- Part 2 Information Security

6-Sensors and Lasers

7-Navigation and Avionics

8-Marine

9-Aerospace and Propulsion

The last 3 characters tell you the numerical order and “reasons for control”

Page 9: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

U.S Munitions List (ITAR) Category I

Firearms, Close Assault Weapons, and Combat Shotguns Category II

Materials, Chemicals, Microorganisms, and Toxins Category III

Ammunition/Ordnance Category IV

Launch Vehicles, Guided/Ballistic Missiles, Rockets, Torpedoes, Bombs, and Mines

Category VExplosives and Energetic Materials, Propellants, Incendiary Agents,

Category VIVessels of War and Special Naval Equipment

Category VIITanks and Military Vehicles

Category VIIIAircraft and Associated Equipment

Category IXMilitary Training Equipment

Category XProtective Personnel Equipment

Category XIMilitary Electronics

Category XII

Fire Control, Range Finder, Optical, Guidance, and Control Equipment

Category XIIIAuxiliary Military Equipment

Category XIVToxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment

Category XVSpacecraft Systems and Associated Equipment

Category XVINuclear Weapons, Design, and Testing Related Items

Category XVIIClassified Articles, Technical Data, and Defense Services Not Otherwise Enumerated

Category XVIIIDirected Energy Weapons

Category XXSubmersible Vessels, Oceanographic, and Associated Equipment

9

22 CRF 121.1

Page 10: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Procurement and Export Control Purchase requisitions- first in line in identifying export controlled items.

Contact the supplier/manufacturer (recommended) Since ITAR inventory is restricted from foreign national access even where

intended for use in fundamental research, it is important for Procurement to identify any ITAR items that are the subject of a purchase transaction.

Software classified as EAR99 and is being flagged for general “boilerplate” purposes, would have to be evaluated for as these items would be subject to OFAC and EAR regulations.

If software that is controlled under an ECCN (e.g. due to cryptographic functionality), then UCSF will need to address the access control implications associated with any potential proprietary technical data that is not in the public domain.

Where an item is identified by a vendor as being governed by ITAR (or where Procurement has independent information that the item is ITAR-governed), Procurement shall immediately notify Export Control Administrator of such intended procurement, enabling Administrator to determine whether, in fact, the department or laboratory is equipped to restrict such item as necessary under the ITAR regulations. The procurement process of such ITAR items may be not be completed until such time as the Administrator has approved of the procurement.

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Page 11: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Procurement and Export Control

When an “export control” notification accompanies the software license or agreement to license, refer licensor’s export control language to the Export Administrator to determine the actual level of control; if there is a specific level of control, the Administrator will determine and communicate related access and transfer restrictions.

The following language may be used in Procurement purchase orders or Master Sales Agreements to help identify ITAR item(s): • “Vendor/Supplier will provide the export control classification (USML Category No) associated

with the commodity being purchased or licensed, to the extent that this item is controlled under the International Traffic in Arms Regulations (ITAR).”

The following language may be used to alert the PI or requisitioning Lab personnel to the ITAR issue: Based on information provided from the vendor of this instrument (or other named item),

this item is export controlled under the International Traffic in Arms Regulations [identify control level]. ITAR items require that foreign national researchers and staff be restricted from accessing such equipment. As such, UC’s Export Administrator is currently evaluating all export control access implications The Procurement team is monitoring the situation closely, and will, along with Administrator communicate the final outcome of this evaluation.

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Page 12: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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ITAR Certification

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Page 13: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Restricted Party Screening (RPS)

Who should be screened in Visual Compliance?Vendors, foreign sponsors, MOU, MOA, service partners, institutional collaborators

Where should screening be done?HR, Purchasing, Finance, Shipping, Sponsored Research, Student Services, Security and Export Control

When should screening be done?Prior to Business activities / transactions start

Do I have to screen every person / every entity?Yes

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Page 15: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

15Controller’s Office

Dual Usage of Research

Peili Zhu, Biosafety Officer

Environment, Health and SafetyUC San Francisco

Page 16: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Dual Use Research In The Life Sciences

Good science can be put to bad uses

Dual use research (DUR) is research conducted for legitimate purposes that generates knowledge, information, technologies, and/or products that can be utilized both for benevolent and harmful purposes

Page 17: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Dual Use Research of Concern (DURC)

Most life sciences research conceivably could be considered DUR in that it has some potential to generate information that could be misused

Page 18: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Dual Use Research of Concern (DURC)

There is a subset of research that has the greatest potential for generating information that could be readily misused in ways that threaten public health and national security. Such research has been termed Dual Use Research of Concern (DURC) and is the focus of the US Government oversight policies

Page 19: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

US Government Definition of DURC

Life sciences research that, based on current understanding, can be reasonably anticipated to provide knowledge, information, products, or technologies that could be directly misapplied to pose a significant threat with broad potential consequences to public health and safety, agricultural crops and other plants, animals, the environment, materiel, or national security.

Page 20: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Oversight of DURC

The dual use potential of certain life sciences research has been recognized as an important biosecurity issue for a number of years

Managing the risks associated with DURC is a responsibility shared by:

Researchers Journal editors and publishers Institutional officials Local oversight bodies The Federal government

Page 21: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

US Government Policies for DURC Oversight

These policies: Aim to preserve the benefits of life sciences

research while minimizing the risk of misuse of the knowledge, information, products, or technologies provided by such research; and

Complement existing regulations and policies governing the safe and secure use of pathogens and toxins

Page 22: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Research Subject to the Policies

Does research involve one or more of 15 agents or toxins listed in the Policy?

Does research aim to produce one of seven listed experimental effects?

Does research meet definition of DURC?

Page 23: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Research Subject to the Policies

Requires additional Federal and local oversight and risk

mitigation strategies to address dual use concerns

Page 24: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

The US Policy for Oversight of Life Sciences DURC (March 2012)

Requires Federal departments and agencies to review their research portfolios, both intramural and extramural, to:

Identify all research under the policy with DURC potential

Mitigate the risks posed by any DURC identified

Page 25: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

The US Policy for Oversight of Life Sciences DURC (Sept. 2014)

Institutional oversight of DURC is a critical component of a comprehensive oversight system that involves:

Principal Investigators (PIs)

Institutional Review Entity (IRE)

Institutional Contact for Dual Use Research (ICDUR)

United States Government (USG)

Page 26: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Overview of the Process for Institutional DURC Oversight

PI identifies research that involves any of the 15 listed agents

Institutional Review Entity (IRE): Determines whether the research involves any of the 7

experimental effects; If so, conducts a risk assessment to determine whether the

research is DURC; If so, weighs the risks and benefits and develops a draft risk

mitigation plan

Page 27: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

What Research is Subject to the Policy?

Research that directly involves any of the following 15 agents and toxins* Avian influenza virus (highly pathogenic) Bacillus anthracis Botulinum neurotoxin (in any quantity) Burkholderia mallei Burkholderia pseudomallei Ebola virus Foot-and-mouth disease virus Francisella tularensis Marburg virus

Page 28: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

What Research is Subject to the Policy?

Reconstructed 1918 Influenza virus Rinderpest virus Toxin-producing strains of Clostridium botulinum Variola major virus Variola minor virus Yersinia pestis * Except attenuated strains of the agents that are excluded from the Select Agent list and inactive forms of botulinum neurotoxin

Page 29: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

What Research is Subject to the Policy?

Experimental effects Enhances the harmful consequences of the agent or

toxin Disrupts immunity or the effectiveness of an

immunization against the agent or toxin without clinical and/or agricultural justification

Confers to the agent or toxin resistance to clinically and/or agriculturally useful prophylactic or therapeutic interventions against that agent or toxin or facilitates their ability to evade detection methodologies

Page 30: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

What Research is Subject to the Policy?

Experimental effects Increases the stability, transmissibility, or the

ability to disseminate the agent or toxin Alters the host range or tropism of the agent

or toxin Enhances the susceptibility of a host

population to the agent or toxin Generates or reconstitutes an eradicated or

extinct agent or toxin listed in the policy

Page 31: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Determine if the Research Meets the Definition of DURC

If the research with any of the 15 agents involves any of the 7 experimental effects,

conduct a risk assessment to determine if it meets the following definition:

Page 32: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Life sciences research that, based on current understanding, can be reasonably anticipated to provide knowledge, information, products, or technologies that could be directly misapplied to pose a significant threat with broad potential consequences to public health and safety, agricultural crops and other plants, animals, the environment, materiel, or national security.

Determine if the Research Meets the Definition of DURC

Page 33: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Risk Assessment and Risk Mitigation

For projects that are determined to meet the definition of DURC, the IRE must develop a risk mitigation plan to apply any necessary and appropriate risk mitigation measures

Page 34: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Management of DURC-Associated Risks

DURC risk mitigation strategies may include: Changing the design or conduct of the research

or not conducting certain aspects of DURC

Applying specific biosecurity and/or biosafety measures

Developing a plan for monitoring the research for findings with additional DURC potential

Page 35: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Management of DURC-Associated Risks

DURC risk mitigation strategies may include:

Developing plan for responsibly communicating the results of DURC

In rare instances, when appropriate, restricting communication of experimental details or other specific information

Page 36: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Key Responsibilities of Investigators

Identify and refer to the IRE all research involving one or more of the agents or toxins listed in the Policy, along with an assessment of whether the research involves any of the seven listed experimental effects

Work with the IRE to assess the dual use risks and benefits of the research in question and develop risk mitigation measures

Page 37: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Key Responsibilities of Investigators

Conduct DURC in accordance with the risk mitigation plan

Be knowledgeable about and comply with all institutional and Federal policies and requirements for oversight of DURC

Continue to assess research to determine if, at any time, the research becomes subject to the policy

Page 38: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Key Responsibilities of Investigators

Ensure that laboratory personnel conducting research with any of the 15 listed agents have received education and training on DURC

Communicate DURC in a responsible manner, throughout the research process, not only at the point of publication Ensure that communication is in compliance with

the risk mitigation plan approved by the appropriate Federal funding agency

Page 39: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Key Responsibilities of US Government Funding Agencies

Require policy implementation at all institutions subject to the Policy.

When notified by an institution of research meeting the scope of the Policy: Notify the institution when the USG funding

agency disagrees with any part of the IRE’s review outcome

For research determined to be DURC, work with the institution to finalize a risk mitigation plan

Page 40: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Key Responsibilities of US Government Funding Agencies

Respond to questions from institutions regarding DURC oversight and compliance with the Policy

Respond to reports of non-compliance and work with the institution to address such non-compliance

Page 41: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Companion Guide

Available at: www.phe.gov/s3/dualuse

Page 42: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Questions?

Contact the UCSF Biosafety Officer, Peili Zhu, if you have any questions or

concerns.

Tel: 514-2824

E-mail: [email protected]

Page 43: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Uniform Guidance TopicsTopic Speaker

Administrative & Computing Charges Nilo Mia Change In Foreign F&A Rate Regnier Jurado Participant Support Cost vs. Research

Subject Payments Rick Blair

Page 44: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Uniform Guidance: Administrative and Computing Device Charges

Page 45: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Allowable Costs

Computing Devices §200.453 & 200.453(c) Allowable direct cost when the device is essential,

allocable and used to advance the aims of the project, but may be used for other purposes as well.

How is computing device defined? Computing devices are defined as machines used to

acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing information. §200.20

Page 46: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Direct Charging of Computing Devices

Computing devices < $5,000 that are essential and allocable, but not solely dedicated to the performance of a federal award, may be charged 100% to an award or may be allocated to several awards. Computing devices > $5,000 are considered equipment and must be appropriately described in the proposal budget.

No prior agency approval is required however, computing devices should be itemized in the proposal budget.

In addition, the project must not have reasonable access to other devices or equipment that can achieve the same purpose. Devices may not be purchased for reasons of convenience or preference. (Essential to aims of project)

Page 47: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Allowable Costs

Direct Costs - Administrative and Clerical §200.413(c) Allowable direct cost when administrative and clerical

staff services are: Integral to the project. Essential to the project’s goals and

objectives, rather than necessary for the overall operation of the institution;

The individual(s) can be specifically identified with the project or activity;

Such costs are explicitly included and awarded in the budget or have written approval by the sponsor. Approval may be requested through the proposal or in writing after the award is made.

Costs are not also recovered as indirect costs.

Page 48: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Examples of Administrative and Clerical

Allowable Management and organization of large complex group and annual

meetings. Project/activity website development. Management of teleconferences and other communications. Coordination of scientific meeting presentations and publication of data. Management of internal data and reagent sharing or shipping. Tracking project progress and meeting NIH reporting requirements of

award. Management of the participation of the Advisory Panel. Management of sub-recipient agreements.

Unallowable Monthly general ledger reconciliation. Monthly budget status reports. Purchasing.

Page 49: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Additional Guidance(To Be Vetted)

Administrative and clerical threshold needed to ensure “reasonable” amounts and levels of effort are contributed to the project or activity and that the work is intimately related to work under the agreement. Personnel costs must be integral and essential to the

performance of the award or activity. Administrative and clerical support must not be incidental

which is defined as individual annual effort less than 10% or less than $3,000 dollars budgeted per year.

Instances where individual(s) is on 3 or more awards and cumulative annual effort charged to federal sources is equal to or greater than 75%, budgets must be evaluated for appropriateness with university and federal guidelines.

Page 50: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Uniform Guidance: Change In Foreign F&A Rate

Page 51: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Change in Foreign F&A Rate

Proposals are being submitted at 10% until NIH provides new guidance

Subawards under existing awards will remain at 8%

Page 52: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Uniform Guidance: Participant Support Cost vs. Research Subject Payments

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53Controller’s Office

Participant Support Costs

Participant Support Costs must be separately identified from other Research Subject Payments as participant support costs cannot be assessed F&A under the new the Uniform Guidance Participant Support Costs are items such as stipends or

subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects A new GL account 57824 has been created to track these costs

Research Subject Payments, also known as patient incentives and respondent fees, are small payments made to individuals who are participating in a research project as a “human subject” Use existing GL Account 57823

A new MTDC Base Code “R” will be effective March 1

Page 54: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Uniformed Guidance Resources

UCSF WebsiteOffice of Sponsored Research-Uniform

Guidance http://osr.ucsf.edu/content/uniform-guidance-federal-awards

Page 55: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

55Controller’s Office

On & Off Campus F&A Changes

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56Controller’s Office

UCSF Operating Principles

The following provides principles and guidance related to F&A (indirect) costs for faculty who are moving from off- to on-campus locations: We do not expect support for researchers’ efforts to be negatively

impacted by a change in their work location. As a result, researchers will not be asked to “make up” for any change in indirect rates through a reduction of their direct cost budgets.

Efforts will be made to negotiate a change in the indirect rates to reflect the proper location of the work. Our goal is to capture as much of the indirect costs as possible.

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57Controller’s Office

UCSF Operating Principles

If a negotiation to the new, higher on-campus rate is not possible as it would require an increase in total funds awarded, then we will attempt to negotiate a reduced on-campus rate that is equal to the budgeted off-campus rate and rent (note, this keeps the budget whole). If the sponsor will not agree to this rebudgeting of costs, the budget will not be revised until there is a competitive break that will allow for inclusion of the new on-campus rate (note, this leaves unspent budget on the table equal to the rent). This reduced on-campus rate will be calculated on an award by award basis by

CGA with 3 days lead-time for the request. Submit request to the Assistant Controller – CGA.

Following competitive breaks, awards are expected to include the on-campus indirect rate. Waivers for exceptions must be supported by the EVCP.

Page 58: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

58Controller’s Office

UCSF Operating Principles

Where the award budget plans for the change in rates, the new rate will be implemented effective the date of the move. If the budget did not plan for the proper date of the move (i.e., the budget planned for the move in January and it occurred in October) and the actual F&A charges exceed the budgeted F&A plus rent for the months in question, the department RSA may ask for F&A adjustment from the Assistant Controller – CGA. The adjustment will be granted to ensure there is no negative impact from this change in work location. CGA has obtained a list from facilities for some moves, where we cannot

obtain this information an email from the RSA to CGA representing the date of the move is sufficient documentation to update the award records. The email should be submitted no later than 2 weeks prior to the move.

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Cost Share Guidance Clarification

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60Controller’s Office

Cost Sharing Guidance Updated

CGA and RMS have updated the cost sharing guidance to help distinguish between voluntary committed and uncommitted cost sharing

A new Cost Sharing Summary job aid and additional FAQs has been posted to the CGA website http://controller.ucsf.edu/pam/procs.asp

The new guidance clarifies for voluntary committed cost sharing to occur, the effort had to be both quantified in the accepted budget and the award notice had to be silent on cost-sharing requirements

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Does Cost Sharing Make the Proposal More Competitive?

NOUnder the Uniform Guidance, cost sharing on

federal proposals will not be a factor during the merit review of a proposal except when allowed in the program announcement

The only time cost share increases the chance for funding is when cost sharing is required or where the request for proposal or funding announcement explicitly states that cost sharing is a review criterion Some sponsors, such as NSF, actually prohibit cost

sharing unless specifically required by a solicitation

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Cost Sharing is a Burden

Committed cost sharing requires carefully tracking and reporting by department and CGA

If the department is unable to fulfil the cost sharing commitment, the sponsor may have the right to reduce or cancel the award

The cost sharing portion is included in the organized research base for computing or allocating F&A costs, i.e., when UCSF negotiates our F&A rate, it lowers our F&A rate

For more details, please see the updated job aid and updated FAQ’s at

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63Controller’s Office

NOT-OD Updates

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NOT-OD-15-032

New NIH Biosketch FormatBecomes Mandatory May 25, 2015 and

ForwardNew Section C requirementsUse of SciENcv to build and maintain multiple

profilesNIH Biographical Sketch Format webpage

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NOT-OD-15-039

66

Late Application Submission Policy Effective starting with January 25, 2015 due dates2-week Window of Consideration from published

due dates on PA, RFA and PARExceptions:

RFAs that specify that No Late Applications will be accepted

New Investigator R01 applications with special due dates that have already been extended

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NOT-OD-15-102

67

NIGMS Revised Funding Guidelines Effective for applications due on/after January 2,

2016Limits the number of NIGMS research grants

awarded to Investigators with substantial, long-term, unrestricted supportHoward Hughes Medical Institute InvestigatorsHolders of endowed chairs supporting undefined

researchRecipients of gifts that support research

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NOT-OD-15-044

NIH Rollout of ASSIST during 2015ASSIST will be opened as an option to submit most

competing applications for grant programs and cooperative agreements

Reminder: UCSF uses a system-to-system solution (eProposal) to submit through the federal portalASSIST may be considered as an option as it becomes

available for FOAs that are not supported by eProposalRollout by activity code will commence at the end of

January 2015 with small research grants (R03) and exploratory/developmental grants (R21)

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NOT-OD-15-048

FY-2015 NRSA Stipends LevelsEffective October 1, 2014For Kirschstein NRSA Awards

NIH Individual Fellowships (F series)NIH Institutional Training Grants (T series)

The following remain unchanged:Tuition and Fees calculation and capsTraining Related Expenses on Training GrantsInstitutional Allowance for Individual Fellows

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Controller’s Office 70

Award Hot Topics

NOT-OD-15-049 Salary Cap Change NIH Subaccounts Update STIP Attribute Who & How To Update The RSA Contact Information

Page 71: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

71Controller’s Office

Salary Cap Change

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NOT-OD-15-049

For Fiscal Year 15, the Executive Level II salary level will increase to $183,300 effective January 11, 2015 Use the new NIH salary cap for new, renewal, supplement, or

resubmission proposals now To use the new salary cap on a new budget in eProposal, select

“$183,300 – FY2015 NIH Salary Cap 01/11/15-Forward” from the Salary Cap dropdown list on the budget setup page and continue creating your budget as you normally do

To update an existing budget in eProposal from the current NIH salary cap of $181,500 to the new NIH salary cap of $183,300:

Select “$183,300 – FY2015 NIH Salary Cap 01/11/15-Forward” from the Salary Cap dropdown list on the budget setup page

Click “Save Changes to Budget Setup” Click on the “Detailed Budget” tab Click “Calculate and Save Changes”

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The new salary cap may be used for existing awards as described in the NIH announcement If the increased salary cap is adopted on existing awards, you will be

allowed to rebudget funds to accommodate the new cap, however no additional funding will be provided by the sponsor

Following our normal practice, UCSF will use an effective date of February 1, 2015 (beginning of the first full calendar month) for payroll processing using the new salary cap If you wish to use the new cap on existing awards, please update

payroll distribution by submitting an SRS ticket to Human Resources or by accessing MPM for faculty distribution changes by the 2/16/2015 processing deadline to avoid PETs for the month of February

The new NIH salary cap will be available in the MPM as CAP 24 – Remember, when increasing the salary cap, you will need to reduce or remove the

differential (OTC Over-the-Cap) for the associated account

NOT-OD-15-049

Page 74: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

74Controller’s Office

NIH Subaccounts Update Upcoming changes to the U.S.

Department of Health and Human Services (DHHS) payment policies

Page 75: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

All DHHS Awards will be Re-Issued

Per NOT-OD-14-093, May 16, 2014, all awards issued by the DHHS (NIH, HRSA, CDC, AHRQ) will be re-issued on subaccounts to track spending by award. Currently, all awards are in a pooled fund

In order to process these awards for individual billing, we need to create new A#s for continuations and supplements that would otherwise have kept the same A#

Our current practice is to issue new A#s for renewals, so there is no change to the renewal process

Sub-In agreements are billed individually, so we do not need to create new A#s for Sub-In continuations and supplements when the parent award migrates to a subaccount

The current practice of issuing new A#s for Sub-Ins when the parent award is competitively renewed will continue

Page 76: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

Controller’s Office

Effective Dates

All non-NIH DHHS awards with budget periods beginning 10/1/14 or later have been or will be issued on subaccounts

NIH delayed implementation to budget periods beginning 10/1/15 or later, per NOT-OD-14-103 on 7/11/14

CGA will send a list of all awards migrating to subaccounts to Department post-award staff and RMS

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77Controller’s Office

Award Migration

We expect the awards to migrate as follows

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STIP Attribute

Page 79: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Monitoring STIP

A new attribute titled “STIP_REQ” was created in Research Administration System

Page 80: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

80Controller’s Office

Monitoring STIP

As of January, 61 awards spanning 11 sponsors were given this attribute

Going forward, the CGA Award Set-up team will add the new attribute to new awards

Remember, STIP may only be transferred to sponsored awards with this attribute

SponsorsBill & Melinda Gates FoundationBristol-Myers Squibb Foundation, Inc.California HealthCare FoundationDoris Duke Charitable FoundationGordon and Betty Moore FoundationHitachi FoundationNora Eccles Treadwell FoundationPew Charitable TrustsResearch to Prevent Blindness, Inc.Sidney Kimmel Fdn for Cancer ResearchWilliam and Flora Hewlett Foundation

Page 81: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

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Who & How To Update The RSA Contact Information

Page 82: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

82Controller’s Office

RSA Update in RAS

Departments have the ability to change the RSA for any project in PeopleSoft Go to the Project Detail Page and make the

change under the Department Information section

The RSA named on the PRIMARY project is the name that is displayed as the award RSA To change the award RSA, change the PRIMARY

project RSA

Page 83: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

83Controller’s Office

RSA Update in RAS

Page 84: Controller’s Office Research Administration Town Hall Thursday, January 29, 2015 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium

84Controller’s Office

CGA Staffing Announcements

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86Controller’s Office

QUESTIONS?

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87Controller’s Office

We Are Here To Serve You

Research Management Services (RMS) for federal grants, fellowships, cooperative agreements and all non-profit sponsorshttp://osr.ucsf.edu/find-my-osr-staff

Government and Business Contracts (GBC) for federal contracts and all state, city, county, and foreign government/organization sponsorshttp://osr.ucsf.edu/content/gbc-contact-information

Industry Contracts Division (ICD) for all industry sponsors (industry is the prime sponsor)http://ita.ucsf.edu/about/staff

CGA Service Desk for post-award issues [email protected] Also a CGA service quality survey at https://ucsf.co1.qualtrics.com/SE/?SID=SV_cuSKJUDE6sZTnjT