sponsored projects administration (spa) training program
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June 15, 2000 2
Topics: SPA Training Program
A. Research Mission of the University
B. Five University Initiatives
C. Roles and Responsibilities
D. The Life Cycle of a Sponsored Project
E. What Every P.I./Administrator Should Know
June 15, 2000 3
Five University Initiatives
Management and Internal Controls
1. Personnel Policy Guidelines, Section U606.01: Compliance with University Policies and Procedures
– Communicate to employees their responsibility to adhere to University policies and procedures and report potential or actual violations
– Affirms commitment that individuals who come forward in good faith shall not be subject to reprisal or retaliation
June 15, 2000 4
Five University Initiatives
Management and Internal Controls (con’t)
2. Financial Policy No. 2101: Principal Investigator Responsibilities for Financial Oversight of Grants and Contracts– Encourages delegation of day to day financial
management activities to departmental or Local Business Center personnel
– Communicate P.I. responsibilities for oversight of financial management of grants and contracts
June 15, 2000 5
Five University Initiatives
Management and Internal Controls (con’t)
3.Principal Investigator Certification: Project Proposals– Proposal Transmittal Form (PTF) requires
the P.I. to certify his/her:• Compliance with University Conflict of Interest policies and
procedures• Acceptance of financial oversight responsibilities for the
sponsored project
June 15, 2000 6
Five University Initiatives
Management and Internal Controls (con’t)
4. Increased Internal Audit Focus to Supplement Annual OMB Circular A-133 Audit
– Reinforce importance of compliance with federal regulations and University policy
– Enhance internal control by identifying problems or potential problems• Summary of findings and corrective actions submitted to
University Officers• Material adverse findings reported to Department of Health
and Human Services
June 15, 2000 7
Five University Initiatives
Management and Internal Controls (con’t)
5. Mandatory Training Program– For all University administrative and
clerical employees who work in any area of Sponsored Project Management
June 15, 2000 8
Roles and Responsibilities
Who are the Players? What are their Roles and
Responsibilities?
June 15, 2000 9
Roles and Responsibilities
The Players– Principal Investigator– Unit Administrator– Department Chair– Dean– Central Offices
• Office of the Provost• University Research Administration• Comptroller/Restricted Funds• Others
June 15, 2000 10
Roles and Responsibilities
Principal InvestigatorThe primary person in charge of a research grant,
cooperative agreement, training or service project, clinical study, contract, other sponsored project or material transfer agreement. Usually a faculty member holding a regular appointment, although other employees may be approved to serve as P.I.s. In some sponsored projects, the P.I. may be referred to as the project or program director.
June 15, 2000 11
Roles and Responsibilities
Principal Investigator (Con’t) Responsible for the design and implementation of all
aspects of the project
Prepares, seeks approval and responsible for
Oversight Committee Approvals Develops Research Plan and Technical Proposal Seeks out funding opportunities Prepares technical reports, noncompeting
continuations, interim and final reports
June 15, 2000 12
Roles and Responsibilities
Principal Investigator (Con’t) Determines the budgetary needs of the project Adheres to relevant agency, institutional, divisional
and departmental guidelines Reviews and signs Proposal Transmittal Form (PTF) Discloses Inventions Manages all Project Personnel Reviews and adheres to all terms and conditions of
award
June 15, 2000 13
Roles and Responsibilities
Principal Investigator (Con’t) Oversees workscope and authorizes payments to
consultants and subcontractors Authorizes all expenditures, cost transfers,
rebudgeting Updates Assurance and prepares Disclosure Form if
significant financial conflict of interest develops Provides information on closing reports Retains project data and materials as required
June 15, 2000 14
Roles and Responsibilities
Unit AdministratorAn employee responsible for providing administrative
support to one or more sponsored projects. This position may include a wide variety of roles and position titles including faculty service representative, account manager, grants & contracts administrator, administrative assistant, pre-award administrator, post-award administrator, account assistant, project assistant, secretary, etc.
June 15, 2000 15
Roles and Responsibilities
Unit Administrator (Con’t) Obtains and reviews proposal guidelines/forms Coordinates and communicates with P.I. to
understand relationship between project goals and resources
Prepares (assists with) proposal budget & other administrative documents
Prepares Proposal Transmittal Form (PTF)
June 15, 2000 16
Roles and Responsibilities
Unit Administrator (Con’t) Assures institutional review and approval of
proposal Assures submission of proposal to sponsor Assists with regulatory compliance (human
subjects, animals, biohazards, etc.) Assists with sponsor inquiries & negotiation of
award
June 15, 2000 17
Roles and Responsibilities
Unit Administrator (Con’t) Assists in establishing account Assists with recruitment, appointment and
effort assignment for personnel Reconciles monthly ledgers of expenditures Expedites documentation for purchases,
subcontracts, consulting agreements
June 15, 2000 18
Roles and Responsibilities
Department Head
A University official with managerial and fiscal responsibilities for a designated area, such as department chair, center director, institute director.
June 15, 2000 19
Roles and Responsibilities
Department Head (Con’t) Reviews and approves Proposal Transmittal Form Reviews and endorses requests for P.I. eligibility Approves cost sharing and matching from
departmental funds Expedites request for indirect cost waiver Approves pre-award arrangements and authorizes a
guarantee account from which expenditures may be paid if award is not received
June 15, 2000 20
Roles and Responsibilities
Department Head (Con’t)Provides local oversight for the following: Compliance with regulatory research requirements, as
necessary Rebudgeting, cost transfers, and carry forwards Compliance with effort reporting, reporting of program income,
and all other award terms and conditions Records retention and data ownership Availability of administrative support, facilities and resources
June 15, 2000 21
Roles and Responsibilities
Dean
A University official with managerial and fiscal responsibilities. Each school, division, or college is administered by a dean under the supervision of the Provost of the University.
June 15, 2000 22
Roles and Responsibilities
Dean (Con’t) Approves divisional commitments for cost
sharing/matching Reviews and approves Proposal Transmittal Form Approves requests to Office of the Provost for P.I.
Eligibility Provides divisional/unit oversight for compliance with
regulatory research requirements, such as human & animal subjects, radiation safety, etc.
June 15, 2000 23
Roles and Responsibilities
Dean (Con’t) Provides divisional/unit concurrence in negotiation
and acceptance of awards Interacts with Comptroller’s office and URA in all
areas of compliance with proposal and award terms and conditions, as necessary
Assists with compliance with technical and financial reporting, as necessary
June 15, 2000 24
Roles and Responsibilities
BSD/Office of Research Services (BSD/ORS)Office designated by the Dean of the Division of Biological
Sciences to review and provide divisional approval for all proposals to Federal and other external sponsors (excluding gifts) assuring compliance with divisional policies. Office oversees regulatory compliance for institutional animal care and use committee, BSD-institutional review board, human use of radioisotopes and radioactive drug research committee, institutional biosafety committee. Director of ORS has been delegated signature authority for University approval of certain NIH and several nonfederal proposals.
June 15, 2000 25
Roles and Responsibilities
BSD/ORS (Con’t)Five Sections:
1. Clinical Trial Office– Encourages the growth of Clinical Trial Activity,
Management and Conduct of Trials
2. Research Funding– Distributes funding opportunity information to BSD faculty
and researchers– Manages Internal BSD Funding Opportunities – Selects Candidates for Limited BSD Program Submissions
June 15, 2000 26
Roles and Responsibilities
BSD/ORS (Con’t)3. Regulatory Compliance
Manages and oversees administrative support for four divisional regulatory research committees
• BSD/UCH Institutional Review Boards (IRB)• Institutional Biosafety Committee (IBC)• Institutional Animal Care and Use Committee (IACUC)• UC/UHC Combined committee for Use of Radioisotopes
in Humans (RDRC)
June 15, 2000 27
Roles and Responsibilities
BSD/ORS (Con’t) 4. Grant and Contract Management
– Reviews all BSD proposals with special attention to oversight committee information and approvals, abstracts and lay summaries, budget and justification, divisional and institutional guidelines and policies
– Reviews for divisional approval material transfer agreements and clinical trials
– Approves requests for financial accounts and any postaward modifications for the BSD
June 15, 2000 28
Roles and Responsibilities
BSD/ORS (Con’t)5. Director
– Facilitates Review and Recommendations regarding disclosed conflicts of interest by Dean
– Approves Cost sharing and matching Funds Commitments, and BSD PI status
– Designated Signatory Authority on Certain Applications.
June 15, 2000 29
Roles and Responsibilities
PROVOSTThe chief academic and administrative officer for all
academic units, including the college, the divisions, schools and centers. The Provost oversees the University’s compliance with all academic research policies.
DEPUTY PROVOSTThe chief academic official designated by the Provost
as the person responsible for the direction and guidance of the University’s research mission.
June 15, 2000 30
Roles and Responsibilities
Office of the Provost (Con’t) Oversees the formulation and implementation
of academic research policies governing all units of the University
Approves indirect cost waivers and PI eligibility In cooperation with the Budget Office,
authorizes and approves all University budget cost sharing/matching commitments greater than $100,000 (except BSD)
June 15, 2000 31
Roles and Responsibilities
Office of the Provost (Con’t)
Provides institutional oversight for:– handling of academic fraud allegations and
compliance with other regulatory research policies
– resolution of potential conflict of interest situations
– interactions with ARCH regarding research and technology transfer
June 15, 2000 32
Roles and Responsibilities
University Research Administration (URA)Office designated by the University with the
responsibility to review and provide institutional endorsement for all proposals to Federal and other external sponsors (excluding gifts), assuring compliance with University policies and sponsor terms and conditions. URA is the institutional authority for the negotiation and acceptance of financial support or other contractually-binding obligations in the form of a contract, grant, or agreement, including material transfer agreements and clinical trials. URA is the authorized institutional official for post-award actions necessitating agency approvals: change in P.I., rebudgeting, no-cost extension, etc.
June 15, 2000 33
Roles and Responsibilities
URA (Con’t) Approves and authorizes submission of proposals
and award acceptance on behalf of institution Expedites processing and approval of subcontract
and consulting agreements Reviews, negotiates and approves Material Transfer
Agreements and Clinical Trials Disseminates notification of award and reviews
terms and conditions of award
June 15, 2000 34
Roles and Responsibilities
URA (Con’t) Provides institutional oversight for cost
sharing/matching commitments Maintains database of University-wide proposal
and award activity, including the development of TRACS, coming in Summer 2000
Informs Office of Special Projects and ARCH of sponsor intellectual property and invention reporting requirements
June 15, 2000 35
Roles and Responsibilities
URA (Con’t) Coordinates Legal Counsel and Risk Management
reviews and approvals, as necessary Coordinates with ARCH on negotiation and
acceptance of intellectual property provisions on sponsored research agreements and MTAs involving patents, licensing and commercialization of University-developed inventions
June 15, 2000 36
Roles and Responsibilities
URA (Con’t) Disseminates funding opportunity information to
university community Provides leadership for electronic research
administration planning and implementation
June 15, 2000 37
Roles and Responsibilities
URA (Con’t) Confirms that proposals to “sensitive” foundations
are cleared through development office for submission
Reviews proposals for compliance with university policies and sponsor proposal guidelines and potential award terms and conditions
June 15, 2000 38
Roles and ResponsibilitiesComptroller/Restricted Funds
OFFICE OF THE COMPTROLLERThe Comptroller, at the direction of the Board of Trustees has
supervision over the financial records and accounts of the University. The Comptroller is responsible for keeping proper books of accounts adequately setting forth the financial condition and transactions of the University and shall devise proper methods of accounting and internal controls for all departments of the University.
RESTRICTED FUNDSThe unit of the Comptroller’s Office that is responsible for the
financial accounting, reporting and collecting of funds for federal and other sponsored project awards. Also, this unit is responsible for preparing the Indirect Cost Proposal and negotiating an Indirect Cost Rate Agreement with the Federal Government.
June 15, 2000 39
Roles and Responsibilities
Comptroller/Restricted Funds (Con’t) Establishes and maintains sponsored project accounts in FAS Enforces University financial policies and federal grant and contract
financial regulations Coordinates the preparation and submission of financial reports to the
sponsoring agency Manages project account receivables Monitors overdrafts to ensure their timely resolution Ensures that project accounts are closed in FAS
June 15, 2000 40
Roles and Responsibilities
Comptroller/Restricted Funds (Con’t)Establishes procedures to comply with the sponsor’s financial terms and conditions for:
– Allowable cost– Cost transfers– Direct costs allocations– Cost sharing expenses/matching funds– Effort reporting– Equipment management and reporting– Subrecipient A-133 Audit monitoring
June 15, 2000 41
Roles and Responsibilities
Comptroller/Restricted Funds (Con’t)Establishes procedures to comply with the sponsor’s financial terms and conditions for (Con't):
– Time restrictions on award funds– Program income– Invoicing/letter-of-credit drawdowns– Cash management– Cash receipt/expenditure reporting
June 15, 2000 42
Roles and Responsibilities
Other Players Office of the Comptroller
– Payroll– Independent Contractor/Travel Reimbursement– Property Management
Central Procurement Services HRM
June 15, 2000 43
Roles and Responsibilities
Other Players (Con’t) Facilities Services
– Radiation Safety– Safety and Environmental Affairs– Renovations
Development / Medical Center Development ARCH Dean of Student Offices (Training Awards, Research
Assistant Appts.) University News Office
June 15, 2000 44
Roles and Responsibilities
Other Players (Con’t) Legal Counsel / Medical Legal Risk Management Hospital Safety Medical Legal
June 15, 2000 45
The Life Cycle of a Sponsored ProjectPart I. Proposal preparation
Part II. Budgeting Project Costs
Part III. Compliance Issues
Part IV. Routing and Review Process
Part V. Updating Submissions and Award Negotiations
Part VI. Award Evaluation and Acceptance
Part VII. Administration Information
Part VIII. Award Accounts
Part IX. Managing Programmatic Aspects
June 15, 2000 46
The Life Cycle of a Sponsored Project (Con’t)Part X. Managing Award Funding
Part XI. Audits
Part XII. Financial Reports
Part XIII. Intellectual Property
Part XIV. Project Termination
June 15, 2000 47
Part I. Proposal Preparation
Current Forms and GuidelinesWeb-based information
• Campus resources• Diskettes• Direct to PI
June 15, 2000 48
I. Proposal Preparation
Deadlines/target dates– Target deadline– Rolling deadlines– Deadline– No deadline– Receipt date– Mailing date– Internal deadlines
June 15, 2000 49
I. Proposal Preparation
Limited opportunities
– Coordination of selection process• Deputy Provost/Foundation Relations
• Divisional
• Departmental
– Nomination letters– Assistance in proposal development
Coordination with Foundation Relations
– Limited opportunities
– Sensitive foundations
June 15, 2000 50
I. Proposal Preparation
Funding Instruments – Procurement vehicles
• Contracts
– Assistance vehicles• Grants• Cooperative agreements
June 15, 2000 51
I. Proposal Preparation
Major Federal Regulations– Office of Management and Budget Circulars (OMB)– Federal Acquisition Regulations (FAR)– Code of Federal Regulations (CFR)
Boilerplate Federal Demonstration Partnership (FDP)Terms and Conditions– General– Agency Specific
June 15, 2000 52
I. Proposal Preparation
Funding Instruments (con’t)
Grant • Federal, state and local government,
foundations, voluntary associations, corporations• Oversight, but not direction• P.I. initiated• Federal grants subjects to OMB Circular A-110
and agency implementation, may be awarded under Federal Demonstration Partnership (FDP).
June 15, 2000 53
I. Proposal Preparation
Funding Instruments (con’t)
Cooperative agreement (federal)• Agency initiated• Financial assistance• Oversight and some direction; partnership• Federal cooperative agreements subject to
OMB Circular A-110• Generally not awarded under Federal
Demonstration Partnership
June 15, 2000 54
I. Proposal Preparation
Funding Instruments (con’t)
Federal contract• Federal, state or local government,
corporations• Procurement of services (research)• Sponsor initiated - targeted project
– Oversight– Federal contracts subject to Federal Acquisitions
Regulations (FARs)
June 15, 2000 55
I. Proposal Preparation
Funding Instruments (con’t)– Material transfer agreement
• Incoming/outgoing• Incoming - MTA provided by provider• Outgoing University of Chicago types:
– UBMTA– UC MTA
– Sponsored research agreement – Clinical trial agreement
June 15, 2000 56
I. Proposal Preparation
Solicitation Types Broad agency announcements Request for proposals (contracts/cooperative
agreements) Request for applications (grants) Program announcements (grants/cooperative
agreements)
June 15, 2000 57
I. Proposal Preparation
Types of Proposals
– Letters of intent
– Pre-proposals
– Unsolicited proposals
– Solicited proposals
June 15, 2000 58
I. Proposal Preparation
Project Description
– READ THE GUIDELINES!!!
– Agency/program specific
– Sequence/sections specified
– Use review criteria
June 15, 2000 59
I. Proposal Preparation
PI Eligibility – Two parameters: sponsoring
agency/university policy– Eligible
• Faculty tracks• Academic non-faculty (ANF)
– Senior Scientists, Senior Research Associate and RA track (Asst. Professor, Assoc. Professor, Professor)
– New Hires, not yet in PI eligible positions
June 15, 2000 60
I. Proposal Preparation
PI Eligibility (con’t)Ineligible
• Research scientist• Fellows• Lecturer• Part-Time (PT)• Students• BSD Specific
– Clinical Associate (CA)
– RA (Instructor)
June 15, 2000 61
I. Proposal Preparation
PI Eligibility (con’t)Requesting special permission
• Sectional, departmental support and oversight• Written request with detailed justification• Curriculum Vitae• Approval by Dean or designee• Approval of URA• Final approval by Provost Office
June 15, 2000 62
I. Proposal Preparation
PI Eligibility (con’t)Appropriate Reasons
• Fellowship but agency requires fellow to serve as PI
• In advance of final approval of appointment• Exceptional circumstances on a case by case
basis
June 15, 2000 63
I. Proposal Preparation
Freedom of Information Act (FOIA)– When to mark proposal– Proposal subject to FOIA when awarded– Protection of proprietary/confidential information– To be protected, each proposal page must be
marked– Post award – access to data now required by law
in certain circumstances
June 15, 2000 64
Part II. Budgeting Project Costs
Budgets– Reflect the scope of work of the proposal– Compliant with sponsor guidelines – Necessary to perform the proposed work and are
not precluded by specific program guidelines or applicable cost principles
– Compliant with departmental, divisional, and University policies and guidelines
– Narrative justification
June 15, 2000 65
II. Budgeting Project Costs
Direct Costs– Personnel – confidentiality of salary data– Graduate students – Type A; Type B– Equipment– Consultants– Lab supplies– “Sensitive” categories: office supplies,
telephone costs
June 15, 2000 66
II. Budgeting Project Costs
Direct costs (con’t)– Subcontracts– Graduate student tuition– Travel – foreign; domestic– Publication costs
June 15, 2000 67
II. Budgeting Project Costs
Verification of current rates– Graduate research assistant – division
dependent– Graduate tuition recovery – division
dependent– Fringe benefits – choice of rate depends on
nature of employment and source of funding– Recharge centers
June 15, 2000 68
II. Budgeting Project Costs
Verification of current rates (con’t)– Confirm current rate through Guidelines for Grant
& Contract Management– Specialized service centers – excluded from
MTDC overhead• Animal Facilities Charge• PSD Central Shop
– Use resource web sites• http://www.uchicago.edu/adm/ura/• http://ors.bsd.uchicago.edu
June 15, 2000 69
II. Budgeting Project Costs
Cost sharing/matching commitments– Definitions
• .Required cost sharing or matching is a programmatic requirement – often expressed as a percent of budget request or by requirement of faculty effort without compensation. Required cost sharing should generally not exceed amount required
June 15, 2000 70
II. Budgeting Project Costs
Cost sharing/matching commitments– Definitions (con’t)
• .Voluntary cost sharing is not required, but is sometimes offered to enhance a proposal’s competitiveness. Voluntary cost sharing, including effort without salary recovery, must be prudently allocated.
• .Implicit cost sharing occurs when an agency places a cap or limit on budget items; e.g. NIH salary cap
June 15, 2000 71
II. Budgeting Project Costs
Cost sharing/matching commitments– University policy
• Only when required by sponsor• Avoid commitments requiring detailed
supporting documentation• Designation of source of cost sharing/matching• $100,000 threshold requires additional
approvals
June 15, 2000 72
II. Budgeting Project Costs
Consultants– Individual expert in the field of the technical
project– Use Sponsored Research Consultant
Agreement– Meet IRS test for independent contractor
(should person be a casual employee? Should a subcontract be utilized?)
– Scope of services
June 15, 2000 73
II. Budgeting Project Costs
Consultants (con’t)– Rate of compensation – test for
reasonableness– Rate may be capped by sponsor (e.g. NSF)– Former UC employee is special case– Use SRC Invoice– PI confirmation of satisfactory performance
of service - OK for payment
June 15, 2000 74
II. Budgeting Project Costs
Subcontracts– Organization to organization agreement– Use of personnel and facilities– Approval from subcontracting institution at
the time of proposal submission– Scope of work– Budget, including subcontractor’s indirect
costs
June 15, 2000 75
II. Budgeting Project Costs
NIH training Grants– Special budget restrictions– Stipends are set by NIH– Limited post-award flexibility– Health benefits– Tuition: budget full amount/awarded by NIH
formula
June 15, 2000 76
II. Budgeting Project Costs
NIH modular grants budgets– Designed to focus efforts of investigators and
reviewers on science and away from detailed budget
– No detailed categorical budgets– Direct cost budgets in modules of $25K up to
ceiling of $250K/year – Request the same # of modules for each
budget period of project (exceptions permitted)
June 15, 2000 77
II. Budgeting Project Costs
NIH modular grants budgets (con’t) – No detailed or summary budget pages in
application– No annual escalation – PLAN AHEAD
when estimating modules– Modular budget evaluated on basis of
general, expert estimate of total effort and resources required to carry out the proposed research
June 15, 2000 78
II. Budgeting Project Costs
NIH modular grants budgets (con’t)– Additional budget information will be requested
only under special circumstances– Departmental/divisional guidelines may require
supporting budget detail – Modular awards are issued without direct cost
categorical breakdowns – significant rebudgeting provision does not apply.
– Allocate and account for costs related to award by category within FAS system
June 15, 2000 80
Part III. Compliance Issues
Regulatory compliance– Subject Safety, public trust, public
perception and scientific responsibility– Emergence of regulations– Consequences of non-compliance– Historical perspective
• Tuskegee experiments• Nazi human experimentation
June 15, 2000 81
III. Compliance Issues
Protection of human subjects (con’t)Development of ethical principles
• Nuremberg code– Voluntary consent to participate– Capacity to consent– Freedom from coercion– Appropriate research design– Minimization of risks– Appropriate risk/benefit ratio– Freedom to withdraw at any time
June 15, 2000 82
III. Compliance Issues
Protection of human subjects (con’t)Development of ethical principles (con’t)
• Declaration of Helsinki• Policies for the Protection of Human Subjects
(NIH) • Belmont Report
– Respect for persons– Beneficence– Justice– Boundaries between practice and research
June 15, 2000 83
III. Compliance Issues
Protection of human subjects (con’t)– Federal regulations
• DHHS: 45 CFR 46• Federal Common Rule: 1991 - 16 federal agencies • FDA: 21 CFR 50 and 56
– International Harmonization of Good Clinical Practice
– Recent HHS Announcement • Emerging Requirements for Investigator Training
June 15, 2000 84
III. Compliance Issue
Protection of human subjects (con’t)– Applies to:
• Any research with human subjects or their information, whether linked or not linked by identifiers to individuals and therefore, must be reviewed and approved by a recognized Institutional Review Board or determined to be exempt
– Includes:• Clinical trials • Behavioral research• Epidemiological and survey research
• Outcomes research
June 15, 2000 85
III. Compliance Issues
Protection of human subjects (con’t)Includes (con’t):
• Anthropological research• Educational research• Field research• Oral history
June 15, 2000 86
III. Compliance Issues
Protection of human subjects (con’t)– Institutional Official: Associate Vice
President for Research– Multiple Project Assurance (MPA): M1264– Three IRBs
• Social Science Division and Social Service Administration, Combined in Summer 2000
• Biological Sciences Division/University of Chicago Hospitals (01A and 01B)
June 15, 2000 87
III. Compliance Issues
Protection of human subjects (con’t)Types of review:
• Exempt from committee review• Expedited review• Review by committee
June 15, 2000 88
III. Compliance Issues
Protection of human subjects (con’t)Points to remember:
• Protocols must be approved by the IRB in full prior to the initiation of any research
• The informed consent process must be completed before any subject can be enrolled in a study
• Use of patient charts or radiological films or discarded and unidentified tissues, blood etc, is research and must have IRB approval
• IRBS are not allowed to circumvent these rules
June 15, 2000 89
III. Compliance Issues
Protection of human subjects (con’t)
Institutions are subject to review– Office for the Protection from Research
Risks (OPRR):» MPA process» Query letters» On-site reviews
– Food & Drug Administration (FDA): periodic on-site audits
June 15, 2000 90
III. Compliance Issues
Protection of human subjects (con’t)Resources
• ORS Web-site: http://ors.bsd.uchicago.edu/HS/• OPRR:
http://www.nih.gov/grants/oprr/library_human.htm• BSD/UCH IRB Policy and Procedure Manual• BSD/UCH IRB Member’s Handbook• FDA: http://www.fda.gov• FDA Information Sheets
– http://www.fda.gov/oc/oha/IRB/toc.htm
June 15, 2000 91
III. Compliance Issues
Use of animalsEthical principles: US Government Principles for the
Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching:
– Transportation, care and use of animals should be in accordance with the Animal Welfare Act
– Investigators and other personnel shall be appropriately qualified and experienced for conducting the specified procedures on animals
– The living conditions of animals should be appropriate for their species and contribute to their health and comfort
June 15, 2000 92
III. Compliance Issues
Use of animals (con’t)US Government Principles for the Utilization and Care of
Vertebrate Animals Used in Testing, Research and Teaching (con’t):
– Animals selected for a procedure should be of an appropriate species and quality and the minimum number required to obtain valid results
– Alternatives to use of animals models, such as mathematical models, computer simulation, and in vitro biological systems should be considered.
– Procedures that cause more than momentary or slight pain or distress should be performed with appropriate sedation, analgesia, or anesthesia.
June 15, 2000 93
III. Compliance Issues
Use of animals (con’t)– Principles
• Guide for the Care and Use of Laboratory Animals- National Research Council
– Federal regulations• Public Health Service Policy on Humane Care and
Use of Laboratory Animals• Animal Welfare Act of 1966 (1970, 1976, 1985,
1990) - USDA• Endangered Species Act
June 15, 2000 94
III. Compliance Issues
Use of animals (con’t)Institutional Animal Care and Use Committee
(IACUC) Responsibilities– Approve all use of animals for research, teaching
or testing purposes– Review protocols on an on-going basis– Provide oversight of the Animal Resources Center– Semi-annual program review, includes ARC and
inspection of all labs where animals are housed more than 12 hours
June 15, 2000 95
III. Compliance Issues
Use of animals (con’t)– Institutional Official: Dean of the Biological
Sciences– Assurance: (A3523-01)– New: OLAW-Office of the Laboratory of Animal
Welfare– Single institutional animal care and use committee– Animal Resources Center
June 15, 2000 96
III. Compliance Issues
Use of animals (con’t)IACUC Reviews
• Use of live animals• Use of tissue, including tissue from
slaughterhouse and/or routine tissue harvest• Production of antibodies in live animals,
whether on-campus or from vendor• Use of animal parts from dead animals• Breeding of colonies
June 15, 2000 97
III. Compliance Issues
Use of animals (con’t)Special considerations
• Partnership between Institutional Official (Dean Steele), IACUC, ARC and users
• Occupational health and safety• Coordination with other committees• Periodic review• Good Laboratory Practice• AAALAC Accreditation
June 15, 2000 98
III. Compliance Issues
Use of animals (con’t)Resources
• ORS Web-site: http://ors.bsd.uchicago.edu/• OPRR:
http://www.nih.gov/grants/oprr/library_animal.htm• USDA: http://www.aphis.usda.gov/ac/• AAALAS: http://www.aalas.org• ARC Web-site: http://arc.bsd.uchicago.edu/• ARENA
June 15, 2000 99
III. Compliance Issues
Use of animals (con’t)– Training
• Introduction– Monthly– Required for all with access to ARC facilities
• Monthly seminars• Mandatory training for biohazards, primates
– Printed materials
June 15, 2000 100
III. Compliance Issues
Use of animals (con’t)Special grant related issues
• Who can be PI on a protocol• Verifying protocol numbers and date • Agency notification• NIH requirements: research plan, Section F• FAS accounts/regulatory compliance• Peer review
June 15, 2000 101
III. Compliance Issues
Use of biohazardous materials– Infectious agents
• Risk to laboratory personnel• Risk to general public
– Recombinant DNA• Perceived risk to general public
– Institutional official: Dean of the Biological Sciences Division
– Single institutional biosafety committee
June 15, 2000 102
III. Compliance Issues
Use of biohazardous materials (con’t)Federal oversight and regulations
• Centers for Disease Control - Biosafety in Microbiological and Biomedical Laboratories (BMBL)
• NIH Guidelines for Research Involving Recombinant DNA
• Classification of Etiologic Agents on the Basis of Hazards
• OSHA Blood Borne Pathogen Standard
June 15, 2000 103
III. Compliance Issues
Use of biohazardous materials (con’t)Principles in biosafety
• Biosafety in the laboratory: Prudent practices for the handling and disposal of infectious materials (National Research Council)
• Four biosafety levels• Containment
– Laboratory practice and technique– Safety equipment (primary barriers)– Facility design (secondary barriers)
June 15, 2000 104
III. Compliance Issues
Use of biohazardous materials (con’t)
Principles in biosafety (con’t)• Importation and interstate shipment of
certain biomedical materials– USDA– Department of Transportation– Public Health Service Foreign Quarantine
Regulations
June 15, 2000 105
III. Compliance Issues
Use of biohazardous materials (con’t)Biosafety Levels I-IV
• Biosafety Level 1: well characterized agents not known to cause disease in healthy adults and of minimal potential hazard to lab personnel and the environment
– Recombinant DNA– Vectors from viruses
• Biosafety Level 2: agents of moderate potential hazard– E. Coli, anthrax, chlamydia, most mycobactierim,
adenoviruses, hepatitis, retrovirus
June 15, 2000 106
III. Compliance Issues
Use of biohazardous materials (con’t)Biosafety Levels I-IV (con’t)
• Biosafety Level 3: applicable to clinical, diagnostic, teaching, research or production facilities in which work is done with indigenous or exotic agents which may cause serious or potentially lethal infections
– Mycobacterium tuberculosus, encephalitis
• Biosafety Level 4: dangerous exotic agents– Hanta virus, hemorrhagic fever, ebola
June 15, 2000 107
III. Compliance Issues
Use of biohazardous materials (con’t)
Resources• ORS Website:
http://ors.uchicago.edu/IBC/index.html• CDC:
http://www.cdc.gov/od/ohs/biosfty/bmbl/bmbl-1.htm
• NIH: http://www.nih.gov/od/orda/
June 15, 2000 108
III. Compliance Issues
Use of biohazardous materials (con’t)
Occupational Health and Safety• Human Resources• Health Services• IBC• Coordination with other regulatory
committees
June 15, 2000 109
III. Compliance Issues
Use of radiation – Federal/state oversight
• FDA• Nuclear Energy Commission• Illinois Department of Nuclear Safety
– Oversight• Committee on Radiation Hazards• Radioactive Drugs and Radioactivity Committee (RDRC)
• Office of Radiation Safety
June 15, 2000 110
III. Compliance Issues
Use of radiation (con’t) – Regulatory requirements
• Purchasing restrictions• Emission limits• No eating
– IDNS regulatory licenses• University - laboratory research• Hospital - clinical care and clinical research
– Annual or more frequent inspections– Reports - citations
June 15, 2000 111
III. Compliance Issues
Use of radiation (con’t)– Resources
• ORS Website: http://ors.bsd.uchicago.edu• Radiation Safety Website
– http://adminet.uchicago.edu/adminfac/frameset/facframe.html
– Training• Mandatory training with periodic updates
– Newsletter – Office of Radiation Safety
June 15, 2000 112
III. Compliance Issues
Conflict of interest– Federal regulations– University policy– Assurance Form– Disclosure Form– Process of review– Approval of management plan by Office the
Provost
June 15, 2000 113
Part IV. Routing and Review Process
Proposal review and clearance– Forms and agency guidelines– Project personnel– Evaluation of scope and nature of work to
be performed– Representations and certifications– University audit and financial reports
June 15, 2000 114
IV. Routing and Review Process
Proposal review and clearance– Taking exception to binding terms and conditions– UC Policy does not accept
• Approval of publications• Indemnification• Assignment of intellectual property
– Recipient organization: The University of Chicago (not Medical Center; not Hospital; not department)
June 15, 2000 115
IV. Routing and Review Process
Proposal Transmittal Form (PTF)– Internal control document
(http://www2.uchicago.edu/adm-ura/ura/PTF.pdf)• Purpose• Instructions
– Purpose• Summarizes Information• Mechanism to obtain PI Certification• Ensures endorsement of Department and Division
June 15, 2000 116
IV. Routing and Review Process
PTF (con’t)– Trouble spots
• Incomplete data• PTF data does not match proposal data• Salary and effort of PI and senior investigators
does not match up• Cost sharing/.matching information incomplete• Illegible handwriting
– Sign offs
June 15, 2000 117
IV. Routing and Review Process
Electronic Research Administration (ERA)– National Science Foundation – FASTLANE– URA FASTLANE proposal policies updated
February 1999– NIH Commons – coming to your proposal soon– Many Non Federal Awards and Proposals
(AHA, Cystic Fibrosis Foundation, ACS) with more to come
June 15, 2000 118
IV. Routing and Review Process
Traditional proposal and award procedures– URA completes and authorizes “Reps and Certs”– Comment and sign off by URA– Changes required by URA: “*” requirements
versus suggestions– Submission to agency dy department– Final proposal to URA, BSD/ORS, Division, LBC,
department or local unit for files
June 15, 2000 119
Part V. Updating Submissions and Award Negotiations
Special considerations– Changes in Scope or budget– Regulatory Approvals
• “Just in Time” updates based on priority score assigned by NIH
– Updating Current and Pending Support• “Just in Time” updates based on priority score
assigned by NIH
– Best and Final Offers
June 15, 2000 120
V. Updating Submissions and Award Negotiations
Special considerations (con’t)Site visits
• Inform departmental/divisional/URA offices• Office of Special Projects expertise• Critical importance of run-through• Involve senior academic administrators• Assure administrative and financial systems
support
June 15, 2000 121
V. Updating Submissions and Award Negotiations
Negotiation of award terms and conditions– PI key point of contact for technical
negotiations– URA point of contact for business and
budget negotiations– Review and approval of negotiated
technical and budget changes
June 15, 2000 122
V. Updating Submissions and Award Negotiations
Preaward costs and advance accounts• Account create• Limitations on advance accounts
Postaward considerationsAuthorities
• Preaward Costs• Rebudgeting• Project period• No-cost extension• Carry-forward authority
June 15, 2000 123
V. Updating Submissions and Award Negotiations
Postaward considerations (con’t)– Equipment issues
• Ownership• Reporting
– Financial reporting requirements– Invoicing requirements
June 15, 2000 124
V. Updating Submissions and Award Negotiations
Receipt of award– Email notifications – NSF, NIH– Award letters – unilateral or bilateral – Distribution of award information– Acceptance by “institutional or authorized”
official – this means URA!– Exceptional agreements – PI leaving or left
University
June 15, 2000 125
V. Updating Submissions and Award Negotiations
Special cases– Clinical studies – routing of protocols and
proposed agreements– Visiting scientists – corporate scientific
visitors– Corporate-sponsored research– Gifts and grants and contracts and which is
which is which
June 15, 2000 126
Part VI. Award Evaluation & Acceptance
Notification of award– For most Federal grants: Expenditure of
funds constitutes acceptance of award, e.g. NIH, NSF
– Formal acceptance by “Authorized Institutional Official” - NOT the PI
June 15, 2000 127
VI. Award Evaluation & Acceptance
Trouble spots to look for– Cost Sharing requirements– NSF – budget line M– Unanticipated budget reductions that could
impact scope of work– Never assume year-to-year boilerplate is
same – changes do appear
June 15, 2000 128
VI. Award Evaluation & Acceptance
Legal Office Review-URA point of contact– Indemnification requirements– Unusual certifications and compliance
clauses– National Laboratory User Agreements
June 15, 2000 129
VI. Award Evaluation & Acceptance
ARCH participation in sponsored research & MTA agreements– Unusual intellectual property rights &
requirements– Pre-agreed upon licensing royalty rates for
research outcomes Risk Management--URA point of contact
– Unusual insurance requirements– Off campus site conditions
June 15, 2000 130
VI. Award Evaluation & Acceptance
Notification to URA of PI/departmental/divisional approval to accept:– File Documentation – PI Approval (not
administrator signing for PI)– Acceptance of unusual terms and
conditions by department/division– Distribution of signed agreement
June 15, 2000 131
Part VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approval requirements– Located in
• For grants:– General terms & conditions– Agency publications– Agency administrative regulations that implement
Section 25 of A-110
• For contracts– The “Schedule”
June 15, 2000 132
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approval is mandatory for:– Change in scope– Change in key personnel– Program director/principal investigator’s:
• absence for more than 3 months• 25% reduction in effort
– Need for additional funding
June 15, 2000 133
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approval is mandatory for (con’t)– Transfer of training allowance funds to
other categories– Subcontracting project scope– Award specific restrictions
June 15, 2000 134
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived:– Transfers between direct and indirect cost
categories• FDP awards:
– All agencies have waived
• Other awards– NIH has waived– NSF has waived
June 15, 2000 135
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Transfers between direct and indirect cost
categories (con’t)• Other awards (con’t)
– NASA reserves the right not to waive– DOE has waived unless prohibited by program
regulations– Others: Check agency publications & regulations
that implement A-110 §__.25(c)(5)
June 15, 2000 136
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Costs that require prior approval because of A-21
• Include:– Intra-University Consulting compensation– Insurance on federally-owned equipment– Equipment– Pre-agreement (pre-award) costs– Special arrangement and alteration costs
June 15, 2000 137
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Costs that require prior approval because of A-21
(con’t)• Intra-University consulting compensation
– Assume no waivers
• Insurance on federal owned equipment– Assume no waivers
June 15, 2000 138
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Costs that require prior approval because of A-21
(con’t)• Equipment
– FDP awards» All agencies have waived
– Other awards» NIH has waived for < $25k» NSF has waived» Other agencies: Assume no waivers
June 15, 2000 139
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Costs that require prior approval because of A-21
(con’t)• Pre-agreement (pre-award) costs
– FDP awards» All agencies have waived prior approval for
costs incurred within 90 days of the award– Other awards
» Assume no waivers
June 15, 2000 140
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Costs that require prior approval because of A-21
(con’t)• Special arrangement and alteration costs
– FDP awards» NSF has waived only for arrangement and alteration
cost < $10k» Other agencies have waived
– Other awards» Assume no waivers
June 15, 2000 141
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– One-time no cost extensions
• FDP awards– All agencies have waived
– Agency notifications required
• Other awards– Research awards
» Waiver is likely
– Non-research awards
» Assume no waivers
June 15, 2000 142
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Carry forward unobligated balances to
subsequent funding periods• FDP awards
– All agencies have waived– Agency notifications required
June 15, 2000 143
VII. Administrative InformationProgram and Budget Revisions
Federal agency prior approvals required unless waived (con’t):– Carry forward unobligated balances to
subsequent funding periods (con’t)• Other awards
– Research awards» Waiver is likely
– Non-research awards» Assume no waivers
June 15, 2000 144
VII. Administrative InformationCost Principles
– Allowability of costs is determined in accordance with the provisions of A-21, Cost Principles for Educational Institutions
– A-21 states that specific provisions of the award take precedence
• Effectively allows awarding agencies to write additional cost principles
• NIH Grants Policy Statement and NSF Grant Policy Manual address some costs in more detail than A-21
June 15, 2000 145
VII. Administrative InformationCost Principles
– A-21 reference• For grants:
– General terms & conditions– Agency publications– Agency administrative regulations that implement
Section 27 of A-110
• For contracts– The “Schedule”– Contract Clause 52.216-7
June 15, 2000 146
VII. Administrative InformationPeriod of Availability of Funds
Grants– Period of availability is governed by by Section 28
of A-110.– Section 28 states that where funding period is
specified, only allowable costs resulting from obligations incurred during the funding period are allowable.
– Section 25 of A-110, however, allows awarding agency to give grantee authority to carry-forward unobligated balances to subsequent periods.
June 15, 2000 147
VII. Administrative InformationPeriod of Availability of Funds
Contracts– Unlike grants, contracts that are
incrementally funded do not have those funds restricted to that incremental period. However,
• The “Schedule” may specifically restrict funds to a period
• Funds may be used only for costs incurred within the contract’s period of performance
June 15, 2000 148
VII. Administrative InformationTechnical Reporting Requirements
Grants– Awarding agencies technical reporting requirements
must comply with Section 52 of A-110• Section 51 provides among other things that:
– Reports shall not be more frequently than quarterly, or less frequently than annually
– Annual reports (Technical and Financial
Contracts– Reporting requirements will be detailed in the
“Schedule”
June 15, 2000 149
VII. Administrative InformationFinancial Reporting Requirements
Grants– Awarding agencies financial reporting
requirements must comply with Section 52 of A-110
• Section 52 provides:– Use of standard forms SF269, 269A, 270 or 272– Reports shall not be more frequently than quarterly,
or less frequently than annually– Annual reports (Technical and Financial) shall be
due no later than 90 days after the grant year
June 15, 2000 150
VII. Administrative InformationFinancial Reporting Requirements
Contracts– Reporting requirements will be detailed in the
“Schedule”
June 15, 2000 151
VII. Administrative InformationRecord Retention Requirements
Requirement– Retain records for a period of 3 years from
the date of submission of the annual or final financial report
June 15, 2000 152
Part VIII. Award Accounts
How many accounts are needed?– Every award needs at least one master
account– Are new accounts needed for each budget
year?• Only if carry forward needs agency approval
– Are additional accounts need to show compliance with T&Cs
• Are funds restricted by multiple purposes?
June 15, 2000 153
VIII. Award Accounts
How many accounts are needed? (con’t)– Additional accounts are needed if both on- and off-
campus indirect cost rates are used
– Additional accounts are needed if cost sharing is required
– Additional accounts needed for University management purposes
• Research may be subdivided into multiple subprojects with their own budgets
• University requires multiple accounts when award is for student aid that crosses divisional/school lines
June 15, 2000 154
VIII. Award Accounts
Regulatory complianceApprovals required before account can be
created/opened• Human subjects• Animals• Recombinant DNA• Biosafety
June 15, 2000 155
VIII. Award Accounts
How are Regular Accounts Created? LBC-Account Create Process Non-LBC Account Create Process
(Awards other than NIH and NSF)• Department completes Form 70, “Request for Restricted
Funds Account - Ledgers 5 and 6”• Divisional office reviews and approves• URA reviews and approves• Restricted Funds creates the account
June 15, 2000 156
VIII. Award AccountsNon-LBC Account Create Process (con’t)
– NIH and NSF, AHA and some DOD awards• URA e-mails the awards to
– P.I.– Department– Divisional office– Restricted funds
• Restricted funds creates the account– Based upon Form 70 template completed by
department
June 15, 2000 157
VIII. Award AccountsAdvance accounts
Restricted Funds receives the award from URA
• Changes the status from “Advance” to “Regular”
• Enters the budget based upon the award agreement
June 15, 2000 158
Part IX. Managing Programmatic Aspects
Compliance with terms and conditions of award– Publication review– Publication citations– Sharing research resources
June 15, 2000 159
IX. Managing Programmatic Aspects
Compliance with terms and conditions of award (con’t)– Confidential materials--marking and
storage– Intellectual property--disclosure, informing
sponsor– Record retention and storage
June 15, 2000 160
IX. Managing Programmatic Aspects
Approval of changes to award terms– Expanded authority/FDP
• OMB A-110, plus agency implementation• No cost extensions• Carry-forward
– Requiring agency approvals--grants• Significant change in PI effort• Change in PI• Change in institution
June 15, 2000 161
IX. Managing Programmatic Aspects
Approval of changes to award terms (con’t)– Requiring agency approvals--grants (con’t)
• Significant changes of effort• Significant change in scope of work• Subcontacting• Requests for additional funding• Foreign travel• Use of non-USA airline
June 15, 2000 162
Part X. Managing Award Funding
A-21 Cost Principles Requirements– Reasonable
• Reflects action of a prudent person– Generally recognized as necessary
– Arm’s-length bargaining
– Circumstances at the transaction time
– Institutional policies and practices
– Allocable• Cost can be assigned to a sponsored agreement on the
basis of the relative benefits received or some other equitable basis
June 15, 2000 163
Part X. Managing Award Funding
A-21 Cost Principles Requirements (con’t) – Treated consistently
• Costs incurred for– Same purpose– In like circumstances– Are either direct costs only or indirect costs only
– Cost must• Benefit the project and be charged consistently as direct cost• Be included in the award budget or list of allowable costs
June 15, 2000 164
X. Managing Award Funding
Allowable Cost DeterminatesCosts normally treated as indirect costs
– Administrative, secretary, & clerical compensation– Telecommunications, memberships, postage,
office supplies– University guidelines for charging appear in
Section 307B of URA’s Guidelines for Grant and Contract Management
June 15, 2000 165
X. Managing Award Funding
Other costs that warrant attention– Alterations & renovations
• May require prior approval
– Alcoholic beverages• Generally unallowable
– Animals• Excluded from indirect cost MTDC base
– Books and periodicals• Normally treated as indirect cost
– Dependency allowances• Generally unallowable
June 15, 2000 166
X. Managing Award Funding
Other costs that warrant attention (con’t)– Consultants
• May require prior approval if substantive work is involved• Compensation caps may exist• Sponsored Consulting Agreement required
– Drugs– Entertainment costs-Unallowable– Property insurance
• Prior approval needed for government owned property • University provided insurance generally allowable
June 15, 2000 167
X. Managing Award Funding
Other costs that warrant attention (con’t)– Medical insurance for sponsored fellows and trainees
• Allowable because University requires proof of coverage
– Participant support costs--NSF awards• Rebudgeting prior approval required
– Patient care costs• Routine and ancillary medical services
– Publications• Acknowledgements, disclaimers required
June 15, 2000 168
X. Managing Award Funding
Other costs that warrant attention (con’t)– Student aid (tuition, fees and stipends)
• Unallowable charge to federal research awards– Salaries and wages
• % salaries charged must be <= % of effort• Unallowable if Annual Certification Statement is not
completed– Travel
• Must comply with University travel policies• Use of foreign flag-carriers generally prohibited• Foreign travel may require prior approval
June 15, 2000 169
X. Managing Award Funding
Allocating Costs Guidelines
– A-21, Section C.4.d & University Financial Policy No. 2109
• If a cost benefits one project or activity, the cost should be charged to that project or activity.
• If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit.
June 15, 2000 170
X. Managing Award Funding
Allocating Costs (con’t)– A-21, Section C.4.d & University Financial
Policy No. 2109 (Con’t)• If a cost benefits two or more projects or activities in
proportions that cannot be determined because of the interrelationship of the work involved, then the cost may be allocated to benefited projects on any reasonable basis.
June 15, 2000 171
X. Managing Award Funding
Official Accounting Reports FAS reports
– Monthly Reports– AM090: Account Statement in Whole Dollars– AM091: Report of Transactions
Payroll reports– Reports generated for each monthly and biweekly payroll– Expense Summary Report– Expense Detail Report
June 15, 2000 172
X. Managing Award Funding
Official Accounting Reports Reconcile to “shadow” reports Act to correct errors Update cost projections
– Consider commitments not shown on FAS Reports cease when Acct Admin names
are removed
June 15, 2000 173
X. Managing Award Funding
Cost Sharing Procedures Accounting documents cost sharing
compliance Recorded in separate associate account “Funding” account is designated FAS cost sharing entry moves expense to
funding account See Financial Policy No. 2110
June 15, 2000 174
X. Managing Award Funding
Cost Transfers A-21
– Costs allocable to an award may not be transferred to another award:
• To meet deficiencies caused by overruns• To avoid restrictions imposed by the terms of an
agreement• Or for other reasons of convenience
– Must comply with any agency specific policies
June 15, 2000 175
X. Managing Award Funding
Cost Transfers NIH and PHS Grants Policy Statement
– Requires• Timeliness
– Within 90 days of original transaction
• Full explanation– “To correct error” is insufficient explanation
June 15, 2000 176
X. Managing Award Funding
Cost Transfers University policy & procedures
– Ensure conformance with regulations– Policy
• Financial Policy No. 2111
– Procedures• http://adminet.uchicago.edu/admincompt/
costtran/contents.html
June 15, 2000 177
X. Managing Award Funding
Effort System Required by A-21
– Non-compliance results in disallowance of salaries, wages and benefit expense
System characteristics– Work plan– Monitoring & reporting– Significant changes– Certification
June 15, 2000 178
Part XI. Audits
Test for compliance– Federal regulations
• Award specific• Non-award specific
Not to be feared if– UC policies and procedures were followed– Award specific restrictions were met
June 15, 2000 180
XI. Audits
A-133• Performed by KPMG• Federal programs divided into 3 categories
– Research– Student financial assistance– Other
• Emphasis on UC systems– Allowable costs: Salary caps, student aid, etc.– Effort reporting– Cost transfers
June 15, 2000 181
XI. Audits
A-133 (con’t)• Emphasis on UC systems (con’t)
– Period of funding availability– Financial reporting– Procurement– Recharge center pricing– Billing– Equipment inventory– Subrecipient monitoring
June 15, 2000 182
XI. Audits
A-133 (con’t)• Tests compliance with award specific
restrictions– Prior approval requirement– Cost sharing– Student assistance awards unique regulations– Training program eligibility– Etc.
June 15, 2000 183
XI. Audits
Award interim and closeouts• Performed by
– DHHS – Prime contractor– Non-federal awarding agency
• Usually federal direct contracts or subcontract• Desk audit vs.. on-site audit• Tests for allowable costs• Tests for compliance with award specific
restrictions
June 15, 2000 184
Part XII. Financial Reports
Deadlines A-110 requires agencies to impose filing date
deadlines Most are due 90 days after end of reporting period Non-compliance is reported as an audit finding
Types Request for Advance or Reimbursement (SF 270) Report of Federal Cash Transactions (SF 272) Financial Status Report (SF 269, 269A)
June 15, 2000 185
XII. Financial Reports
Closing Memo– The Closing Memo is a workpaper used to complete FSR
(i.e., Financial Status Report SF 269 or 269A)– Closing Memo is issued to Account Administrator #1 one
month prior to budget or award end date– Closing Memo is returned to Comptroller’s Office no later
than 15 days prior to the FSR due date
June 15, 2000 186
XII. Financial Reports
When are Closing Memos required?– Required for all final FSRs– Interim FSRs
• Required only if prior approval required for carry forward of unobligated balance
June 15, 2000 187
XII. Financial Reports
Closing Memo (Con’t)Steps to complete:
1.Post the Budget Balance from AM090
2.Add encumbrance balance from AM090
3.Add trailing credit transactions
4.Subtract trailing charge transactions
5.Equal unobligated balance to report
6.Certify the charges are appropriate (allowable) to the award.
June 15, 2000 188
XII. Financial Reports
Financial Status Report (SF 269, 269A)Steps to complete
– Step 1: Closing Memo issued to Account Administrator
– Step 2: Closing Memo returned to Comptroller’s Office
– Step 3: Closing Memo audited by Comptroller’s Office
– Step 4: FSR completed and submitted by Comptroller’s Office
June 15, 2000 189
XII. Financial Reports
Other Financial Reports Request for Advance or Reimbursement (SF 270)
– Completed for awards not funded by a letter of credit agreement
– May require Closing Memo
– Completed by Comptroller’s Office
Report of Federal Cash Transactions (SF 272)– Shows both expenditures and cash receipts
– Completed by Comptroller’s Office
Non-federal reports– Similar to federal reports
June 15, 2000 190
Part XIII. Intellectual Property
University policies– Patent Policy – Board of Trustees Statute 18
• http://ap-www.uchicago.edu/UCPOL/UCPOLidx.html
– New Information Technologies – Rights to Intellectual Property
– Determination of who has rights to discoveries in the course of sponsored research/projects?
June 15, 2000 191
XIII. Intellectual Property
Data Rights– Who has access rights?– What are PI responsibilities for retention of data?– Do employees who have worked in a sponsored project
have the right to remove data, materials from The University when they leave?
FOIA public right to federally-sponsored research data– OMB issued prescribed implementing regulation– Each agency has agency-specific implementation191191
June 15, 2000 192
XIII. Intellectual Property
PI responsibility to disclose discoveries– Office of Special Projects
http://www.uchicago.edu/adm/spec-proj/• Guidance on Disclosure Process and forms
• Review of Disclosure to confirm sponsored research and relevant MTAs
– University turns over disclosure to ARCH– ARCH assesses commercial potential of discovery– ARCH has brief period to elect title to disclosure– If elected, ARCH seeks appropriate protection for IP
June 15, 2000 193
XIII. Intellectual Property
Governing regulations for IP derived from sponsored projects– Bayh-Dole spells out extensive compliance and
reporting requirements for IP elected by ARCH– Terms and Conditions of awards for other sponsored
projects– Compliance obligations
• Royalty sharing• Release of IP if unelected or ARCH abandons
commercialization effort• Rights of Sponsors take precedence over rights of PI
June 15, 2000 194
XIV. Project Termination
Final technical report – Sponsor may withhold funding for
University if ANY Final Report is overdueAgencies that do this include NEH, Air Force
– Confirm submission of report to URA– URA follows up on late technical reports –
Administrator, PI, Department Chair, Dean, Provost
June 15, 2000 195
XIV. Project Termination
Integration of close out of records with restricted funds– Confirmation of Compliance with Technical
Reporting requirements– Confirmation that Restricted Funds has closed
financial report– All URA Terminated Project Files archived for at
least 3 years after closing of project– A-110 records retention requirement– Obligations to keep local records
June 15, 2000 196
XIV. Project Termination
Delete project accounts from FAS– Before accounts can be delete
• Budget balance must be reduced to zero• Voucher payable balance and other balance
sheet account controls must be zero
– AM090 and 91 reports stop only after accounts have been deleted
– Accounting is not completed until accounts are deleted
June 15, 2000 197
What Every PI and Administrator Should Know Indicators of problems
– Unauthorized or inappropriate charges– Unallowable costs– Improper cost allocations– Overdrafts– Assignments of costs based on fund availability or project
expiration– Frequent delinquent cost transfers– Equipment purchases near end of project
June 15, 2000 198
What Every PI and Administrator Should Know (Con’t)
See handout for information on the following topics:
– General rules– Major federal regulations– Performance periods– Unallowable costs– Cost sharing/matching– Salary/effort commitments and reporting– Travel and business expenses– Equipment purchases– Indirect costs
June 15, 2000 199
What Every PI and Administrator Should Know (Con’t)– Budgeting/rebudgeting– Cost transfers– Program income– Monthly account/financial reviews– Agency reporting– Invoicing– recharge centers
June 15, 2000 200
What Every PI and Administrator Should Know (Con’t)– Regulatory compliance– Other research related policies– Knowing your resources– Consultants/subcontractors
June 15, 2000 201
Acknowledgements
Judith K. Argon, Director of Research Services, BSD Arnold Aronoff, Director of Training, HRM Sandra Bateman, Director of Employee Relations, HRM William J. Hogan, Jr., Comptroller Thomas P. Jurczak, Manager, PSD Local Business Center Lauren McGrath, Grants and Contracts Manager, URA Casey J. Murray, Associate Comptroller for Restricted Funds Mary Ellen Sheridan, Associate Vice President for Research, URA Robert Smentek, Associate Comptroller for Disbursements Lynda Wolter, Associate Director of Research Services, BSD Robert Zimmer, Deputy Provost for Research