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The Life Cycle of a Sponsored Project: An Integrated Approach: 

The Life Cycle of a Sponsored Project: An Integrated Approach Part 1

I. Introduction: 

I. Introduction Overview of session

II. Roles and Responsibilities of Primary Players: 

II. Roles and Responsibilities of Primary Players Proposals Principal Investigator (PI) Unit administrator Divisional review University approval Provost office Foundation Relations/Development Legal/Chief Financial Officer

II. Roles and Responsibilities of Primary Players: 

II. Roles and Responsibilities of Primary Players Beyond proposals Comptroller’s office Restricted Fund accounting Purchasing

II. Roles and Responsibilities of Primary Players: 

II. Roles and Responsibilities of Primary Players Key agency personnel Programmatic personnel officer Grants and contracts (administrative) officials

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Resources URA Web site URA electronic distributions IRIS Fed-X BSD communication tools ORS Web site Signals E-signals

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Resources (con’t) BSD communication tools (con’t) Biomedical Sciences Report Faculty Awards Committee Bulletin Professional periodicals

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Mentors/colleagues Service on study section/review committees Current and past funding sources Determining appropriateness Read the guidelines Determine appropriateness for: The institution? The individual? The project?

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Searches Custom searches Funding opportunity notification systems IRIS-Alerts Fed-X NSF Custom Search Ad-hoc searches Agency Web pages URA training program - using search tools

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Agency contacts Technical contact/scientific liaison Programmatic discussion Special approvals/exceptional issues - appendices/late proposals Funding level Review process

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Current Forms and Guidelines Check for most current forms and guidelines Web-based information Campus resources Diskettes Direct to PI

III. Identifying Funding Opportunities : 

III. Identifying Funding Opportunities Deadlines/target dates Target deadline Rolling deadlines Deadline No deadline

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Deadlines/target dates (con’t) Receipt date Mailing date Internal deadlines

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Limited opportunities What is a limited opportunity Coordination of selection process Deputy Provost/Foundation Relations Divisional Departmental Nomination letters Assistance in proposal development

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Coordination with Foundation Relations Limited opportunities Sensitive foundations

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Funding instruments Procurement vehicles Contracts Assistance vehicles Grants Cooperative agreements

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Funding instruments (con’t) Grant federal, state and local government, foundations, voluntary associations, corporations investigator initiated financial assistance oversight, but not direction federal grants subjects to OMB Circular A-110 and agency implementation

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Funding instruments (con’t) Grant (con’t) Federal grants may be awarded under Federal Demonstration Partnership (FDP) Federal grants may be awarded under expanded authority/SNAP; some SNAP submissions may now be handled electronically (eSNAP)

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities 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

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities 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) Sponsored research agreement Clinical trial agreement

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Funding instruments (con’t) Material transfer agreement Purpose Incoming/outgoing Incoming - MTA provided by provider Outgoing University of Chicago types: UB MTA UC MTA (new version to be posted soon)

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Solicitation types Broad agency announcements Request for proposals (contracts/cooperative agreements) Request for applications (grants) Program announcements (grants/cooperative agreements)

III. Identifying Funding Opportunities: 

III. Identifying Funding Opportunities Types of proposals Letters of intent Pre-proposals Unsolicited proposals Solicited proposals

IV. Proposal Preparation: 

IV. Proposal Preparation Project description Read the guidelines Agency/program specific Sequence/sections specified Use review criteria

IV. Proposal Preparation: 

IV. Proposal Preparation Project description (con’t) Standard research elements Hypothesis Specific aims Background Significance Materials and methods

IV. Proposal Preparation: 

IV. Proposal Preparation Project description (con’t) Seek advice and input Identify mentor Critique specific aims Critique project description

IV. Proposal Preparation: 

IV. Proposal Preparation Determination of project requirements Space Personnel Equipment Specialized resources Access to expertise

IV. Proposal Preparation: 

IV. 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

IV. Proposal Preparation: 

IV. Proposal Preparation PI eligibility (con’t) Ineligible Research scientist Lecturer Adjunct appointees Staff Fellows Students

IV. Proposal Preparation: 

IV. Proposal Preparation PI eligibility (con’t) Ineligible Part-Time (PT) RA BSD Specific Clinical Associate (CA) RA (Instructor)

IV. Proposal Preparation: 

IV. 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 Faculty Appointments - Mary Harvey Academic Non-Faculty - Aneesah Ali

IV. Proposal Preparation: 

IV. 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

IV. Proposal Preparation: 

IV. Proposal Preparation Endorsement and support letters Uncompensated collaborators Those supplying essential research resources Mentors Letters of recommendation Mentor/department chair letter for NIH K-series

IV. Proposal Preparation: 

IV. Proposal Preparation Acquisition of technical advice/assistance Collaborators Consultants/independent contractors Subawards

IV. Proposal Preparation: 

IV. Proposal Preparation Agency and university guidelines Read in detail the solicitation/program guidelines Proposal checklist Adhere to requirements for: Title length Description length Margins

IV. Proposal Preparation: 

IV. Proposal Preparation Agency and university guidelines (con’t) Adhere to requirements for (con’t): Type size/font Obtaining prior sponsor approval for exceptions Biosketch/CV Current and pending support Resources and facilities Use most current agency forms

IV. Proposal Preparation: 

IV. Proposal Preparation Completing proposal forms University Information Congressional District Employee Identification Number (EIN) DUNS Number Tax exempt materials University annual report List of board of trustees

IV. Proposal Preparation: 

IV. Proposal Preparation Completing proposal forms (con’t) Representations and certifications Board of Trustees resolution on signatory authority

IV. Proposal Preparation: 

IV. Proposal Preparation Completing proposal forms (con’t) Boilerplate University description Divisional/department capabilities Resources and facilities Resources for descriptions

IV. Proposal Preparation: 

IV. Proposal Preparation Other supporting materials Current and pending support References Appendices information Biosketch Format Page limits Key information Conflict of interest

IV. Proposal Preparation: 

IV. Proposal Preparation Just-in-Time applications/modular grants Abbreviated requirements Special instructions: Just in Time (JIT): Minimal budget/detailed justification Special biosketch requirements No checklist required

IV. Proposal Preparation: 

IV. Proposal Preparation Just-in-Time applications/modular grants (con’t) Special instructions (con’t) Modular grant: Special biosketch instructions Minimal budget/minimal justification No other support Checklist page required

IV. Proposal Preparation: 

IV. Proposal Preparation Small business plans Contracts only Best and final Work with central procurement Small business, minority- and women-owned Examples available from URA Routing - local unit/div/URA

IV. Proposal Preparation: 

IV. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Art of budget development

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Budget categories -- direct costs Personnel – confidentiality of salary data Graduate students – Type A; Type B Equipment Consultants Lab supplies 'Sensitive' categories: office supplies, telephone costs

V. Budgeting Project Costs: 

V. Budgeting Project Costs Budget categories -- direct costs (con’t) Subcontracts Graduate student tuition Travel – foreign; domestic Publication costs

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Verification of current rates (con’t) Recharge centers – verify rates, e.g. Biostatistical Lab; SSD Survey Research Center

V. Budgeting Project Costs: 

V. Budgeting Project Costs Verification of current rates (con’t) Specialized service centers – excluded from MTDC overhead Animal Facilities Charge PSD Central Shop

V. Budgeting Project Costs: 

V. Budgeting Project Costs Verification of current rates (con’t) Confirm current rate through Quick Reference Fact Sheet Use resource web sites URA

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Cost sharing/matching commitments (con’t) Approvals Department/division Provost’s Office Concurrence of Budget Office Documentation of approval to URA

V. Budgeting Project Costs: 

V. Budgeting Project Costs Typical budget problems Compensation- employee; consultant; subcontractor; independent contractor Fellows versus postdoctoral research associates Salaries or stipends Equipment that should be supplies (andlt;$5,000)

V. Budgeting Project Costs: 

V. Budgeting Project Costs Typical budget problems (con’t) Effort on PTF matching effort in proposal Effort on budget does not match effort in justification Translating effort to calendar/academic months BSD faculty appointments are 12 month (CY) appointments

V. Budgeting Project Costs: 

V. Budgeting Project Costs Typical budget problems (con’t) Non-BSD faculty appointments are 9 month (AY) appointments Calculation of Animal Facilities Charge Justification matches budget

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. 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?) Scope of services

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Subawards Organization to organization agreement Use of personnel and facilities Approval from subrecipient institution at the time of proposal submission Scope of work Budget, including subrecipient’s indirect costs

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs NIH modular grants budgets (con’t) Request the same # of modules for each budget period of project (exceptions permitted)

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. 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

V. Budgeting Project Costs: 

V. Budgeting Project Costs Modular grant – postaward notations 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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Regulatory compliance Public trust, public perception and scientific responsibility Emergence of regulations Consequences of non-compliance

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects Historical perspective Tuskegee experiments Nazi human experimentation

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues 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, Includes: Clinical trials Behavioral research Epidemiological and survey research Outcomes research

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Includes (con’t): Anthropological research Educational research Field research Oral history

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Any research with human subjects must, therefore, be reviewed and approved by a recognized Institutional Review Board or determined to be exempt

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Institutional Official: Associate Vice President for Research Federal-Wide Assurance (FWA): FWA00005565 Three IRBs Social Science Division (03) Social Service Administration (02) Biological Sciences Division/University of Chicago Hospitals (01)

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Types of review Exempt from committee review Expedited review Review by committee

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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 Cannot initiate clinical trial without BOTH approved protocol and approved clinical trial agreement The informed consent process must be completed before any subject can be enrolled in a study

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Points to remember (con’t): Otherwise - study data is illegitimate Use of patient charts or radiological films or discarded and unidentified tissues, blood etc, is research and must have IRB approval Student research subject to human subjects requirements Deception only allowed at discretion of IRB

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Points to remember: Field work subject to human subjects requirements Oral history projects subject to human subjects requirements IRBS are not allowed to circumvent these rules Protocol approval for one year or less

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Points to remember: Institutions are subject to review Office for the Protection from Research Risks (OPRR): MPA process Query letters On-site reviews Food andamp; Drug Administration (FDA): periodic on-site audits

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Human subject challenges Balancing ethical principles and research needs Proxy consent/waiver of consent Changing face of research, particularly genetic analysis Need to develop local policy ahead of federal policy to keep up

Vi. Proposal preparation--compliance issues: 

Vi. Proposal preparation--compliance issues Protection of human subjects (con’t) Human subject challenges (con’t) Constantly changing regulations Changing institutional boundaries International/target group field work Sensitivity to cultural differences Defining research versus case studies, quality assurance, journalism

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Resources ORS Web-site: http://ors.bsd.uchicago.edu/ Office of Human Research Protection US Food andamp; Drug Administration FDA Information Sheets

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Resources (con’t) PRIMandamp;R (Public Responsibility in Medicine and Research) BSD/UCH IRB

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Training BSD/UCH IRB Videos Annual orientation provided by UC/UCH IRB BSD Initiatives GCRC training Health studies seminar series K30 proposal

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Grant-related issues Who can be PI on a protocol Verifying protocol numbers and date FDA requirements NIH requirements 398 Research Plan, Section E Inclusion of women and minorities, children

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Protection of human subjects (con’t) Grant-related issues (con’t) Notification of approval to agency Ban on fetal research FAS accounts/regulatory compliance

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals Ethical 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 Procedures involving animals should be designated and performed with due consideration of the relevance to human or animal health, the advancement of knowledge, or the good of society

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Ethical principles (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.

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Ethical principles (con’t) US Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching (con’t): Proper use of animals, including the avoidance or minimization of discomfort, distress and pain Procedures that cause more than momentary or slight pain or distress should be performed with appropriate sedation, analgesia, or anesthesia.

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Ethical principles (con’t) US Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching (con’t): Animals that would suffer severe or chronic pain or distress that cannot be relieved should be painlessly killed at the end of the procedure The living conditions of animals should be appropriate for their species and contribute to their health and comfort

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Ethical principles (con’t) US Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Teaching (con’t): Investigators and other personnel shall be appropriately qualified and experienced for conducting the specified procedures on animals Any exceptions to these principle can be made only by the IACUC

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) 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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Principles Guide for the Care and Use of Laboratory Animals- National Research Council

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Principles (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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) PHS regulations apply to all use of animals in research, teaching, testing USDA regs currently apply to: non-human primates, cats, dogs, pigs, sheep, rabbits, hamsters, chincillas, etc. USDA regs do not currently apply to: rodents, birds, fish or reptiles

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Institutional Official: Dean of the Biological Sciences Assurance: NIH-OPRR Single institutional animal care and use committee Animal Resources Center

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) IACUC Reviews (con’t) Field research Preserved specimens

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Special considerations Special mandate to reduce the number of animals used in research, to replace animals with either lower order animals or in vitro/computer methods and to refine methods to reduce pain and distress Animals cannot give consent, so IACUC charged with their welfare

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Special considerations (con’t) Special issues Production of antibodies using the Ascites Method Sensitivity toward animal rights Need for security Animal must be ordered through ARC IACUC/ARC responsible for all animals, even if housed outside ARC Housing outside ARC is supposed to conform with standards of Guide

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Special considerations (con’t) Special issues (con’t) 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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Special considerations (con’t) Special issues (con’t) Laboratory protocol No eating Standard requirements

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Special considerations (con’t) Special issues (con’t) Physical restraint Training Appropriate anaesthesia/analgesia Multiple survival surgery Food or fluid restrictions Peer review Transferring animals into and out of institution

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of animals (con’t) Resources ORS Web-site: http://ors.bsd.uchicago.edu/

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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 Grace period NIH requirements: research plan, Section F FAS accounts/regulatory compliance Peer review

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials Infectious agents Risk to laboratory personnel Risk to general public Recombinant DNA Perceived risk to general public

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Institutional official: Dean of the Biological Sciences Division Single institutional biosafety committee

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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)

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Biosafety Levels I-IV (con’t) Biosafety Level 2: agents of moderate potential hazard E. Coli, anthrax, chlamydia, most mycobactierim, adenoviruses, hepatitis, retrovirus

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Determining BL risk group American Type Culture Collection Catalogues Department of Labor, Occupational Safety and Health Administration - Exposure to Bloodborne Pathogens International Committee on Taxonomy of Viruses Chart: 61 FR 1486

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Noteworthy considerations Identify biohazard Determine biosafety level/risk group Facilities limitations

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Pertains to: Laboratory work Work with animals Work with plants Greenhouses

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Resources ORS Website: http://ors.uchicago.edu/l Institutional Biosafety Committee (IBC) University Safety and Environmental Affairs Office NIH Office of Biotechnology Activities Office of Recombinant DNA Activity USDA Biotech and Science Services

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Training PI training Videos on biosafety or infectious agents available in crerar library

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of biohazardous materials (con’t) Occupational Health and Safety Human Resources Health Services IBC Coordination with other regulatory committees

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of radiation Federal/state oversight FDA Nuclear Energy Commission Illinois Department of Nuclear Safety

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of radiation (con’t) Oversight Committee on Radiation Hazards Human Use of Radioisotopes and Radioactive Drug Research Committee (RDRC) Office of Radiation Safety

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of radiation (con’t) Regulatory requirements Purchasing restrictions Emission limits No eating

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of radiation (con’t) IDNS regulatory licenses University - laboratory research Hospital - clinical care and clinical research Annual or more frequent inspections Reports - citations

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Use of radiation (con’t) Resources ORS Website: http://ors.bsd.uchicago.edu Radiation Safety Website http://facilities.uchicago.edu/organization/radiation/home.html Training Mandatory training with periodic updates Newsletter – Office of Radiation Safety

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Other Regulatory considerations Chemical and laboratory safety OSHA Occupational health and safety

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Conflict of interest Federal regulations University policy Assurance Form Disclosure Form Process of review Approval of management plan by Office the Provost

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Compliance with University policies U103 – 'Whistleblower' policy [Compliance with University Policies and Procedures] http://hr.uchicago.edu/policy/p103.html PI eligibility

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Compliance with University policies (con’t) Development- sensitive foundations Cost sharing/ matching funds

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Compliance with divisional/departmental guidelines BSD – faculty salary recovery Tuition recovery for graduate research assistants

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues 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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Proposal review and clearance (con’t) Taking exception to binding terms and conditions Approval of publications Indemnification Assignment of intellectual property Recipient organization: The University of Chicago (not Medical Center; not Hospital; not department)

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Proposal review and clearance (con’t) Deadline management – where does the responsibility lay?

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Proposal Transmittal Form – internal control document Purpose Instructions

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Proposal Transmittal Form (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

VI. Proposal Preparation--Compliance Issues: 

VI. Proposal Preparation--Compliance Issues Proposal Transmittal Form (con’t) Not required for revised budgets – but major project budgets, especially with cost sharing, are rerouted for approval when proposed award has significant budget reduction

VII. Routing and Review Process: 

VII. Routing and Review Process Electronic research administration National Science Foundation – FASTLANE NIH Commons See URA page on electronic submissions

VII. Routing and Review Process: 

VII. Routing and Review Process Traditional proposal and award procedures Review through channels of draft cover page + budget +abstract + current and pending support + senior investigator CVs + draft project description URA completes and authorizes 'Reps and Certs'

VII. Routing and Review Process: 

VII. Routing and Review Process Traditional proposal and award procedures (con’t) URA provides financial reports; insurance/liability certifications Comment and sign off by URA Changes required by URA: '*' requirements versus suggestions

VII. Routing and Review Process: 

VII. Routing and Review Process Traditional proposal and award procedures (con’t) Submission to agency Final proposal to URA, division, LBC, department or local unit for files

VIII. Updating Submissions and Award Negotiations: 

VIII. Updating Submissions and Award Negotiations Special considerations Changes in Scope or budget Regulatory Approvals Updating Current and Pending Support Just in Time Updates Best and Final Offers Preaward audits

VIII. Updating Submissions and Award Negotiations: 

VIII. 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

VIII. Updating Submissions and Award Negotiations: 

VIII. 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

VIII. Updating Submissions and Award Negotiations: 

VIII. Updating Submissions and Award Negotiations Preaward costs and advance accounts Account create Limitations on advance accounts State and local government agreements are increasingly problematic Clinical Studies – subjects may not be enrolled until agreement is negotiated and signed (IRB approval is not sufficient)

VIII. Updating Submissions and Award Negotiations: 

VIII. Updating Submissions and Award Negotiations Postaward considerations Authorities Preaward Rebudgeting Project period No-cost extension Carry-forward authority

VIII. Updating Submissions and Award Negotiations: 

VIII. Updating Submissions and Award Negotiations Postaward considerations (con’t) Equipment issues Ownership Reporting Financial reporting requirements Invoicing requirements

VIII. Updating Submissions and Award Negotiations: 

VIII. 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

VIII. Updating Submissions and Award Negotiations: 

VIII. Updating Submissions and Award Negotiations Special cases Clinical studies – routing of protocols and proposed agreements Visiting scientists – corporate scientific visitors Corporate-sponsored research Subsequent to ARCH license agreement Gifts and grants and contracts and which is which is which

The Life Cycle of a Sponsored Project: An Integrated Approach: 

The Life Cycle of a Sponsored Project: An Integrated Approach Part 2

The Life Cycle of a Sponsored Project: An Integrated Approach: 

The Life Cycle of a Sponsored Project: An Integrated Approach Part 2 Outline IX Award evaluation andamp; acceptance X Referenced conditions andamp; documents XI Administrative information XII Award review with PI XIII Award accounts XIV Managing programmatic aspects XV Managing award funding XVI Audits XVII Financial reports XVII Billing andamp; collecting funds XIX Intellectual Property XX Project Termination XXI Relinquishing/transferring programs or awards

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; 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

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; Acceptance Administrator’s role: Review of terms andamp; conditions of award Notation of special restrictions/conditions Limitation on spending, prior approvals

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; Acceptance Trouble spots to look for Cost Sharing requirements Unanticipated budget reductions that could impact scope of work Never assume year-to-year boilerplate is same – changes do appear

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; Acceptance Legal Office Review--URA point of contact Indemnification requirements Unusual certifications and compliance clauses National Laboratory User Agreements

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; Acceptance UCTech participation in sponsored research andamp; MTA agreements Unusual intellectual property rights andamp; requirements Pre-agreed upon licensing royalty rates for research outcomes

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; Acceptance Risk Management--URA point of contact Unusual insurance requirements Off campus site conditions

IX. Award Evaluation & Acceptance: 

IX. Award Evaluation andamp; 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

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants OMB Circulars General terms and conditions Specific terms and conditions Agency publications Administrative regulations Program regulations

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants OMB Circulars A-21: Cost Principles for Educational Institutions A-110: Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants OMB circulars (con’t) A-133: Audits of States, Local Governments, and Non-Profit Organizations

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants OMB Circulars (con’t) Referenced through: General Tandamp;Cs Referenced agency publications Referenced administrative regulations

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants General terms and conditions Federal Demonstration Partnership (FDP) terms and conditions andamp; agency specific terms and conditions Research awards from: NSF, NIH, NASA, Energy, Air Force, Army, EPA, ONR andamp; USDA

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants General terms and conditions (con’t) NSF Grant General Conditions (GC-1) Cooperative Agreement General Conditions (CA-1) Facilities Modernization Grant Conditions (FAA GC-1) Fixed Amount Award General Conditions (FAA GC-1)

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Award specific Tandamp;Cs

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Agency publications NSF Grant Proposal Guide NIH Grants Policy Statement NASA Grant and Cooperative Agreement Handbook

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Agency administrative regulations Includes agency’s implementation of A-110 Examples Agriculture: 7 CFR 3019 DHHS: 45 CFR 74 Education: 34 CFR 74 Energy: 10 CFR 600 NASA : 14 CFR 1260`

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Program regulations May be published in Code of Federal Regulations Agency publications

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Program regulations (con’t) When are they important? Research awards? No, information tends to apply to whole class of awards

X. Referenced Conditions & DocumentsFederal Grants: 

X. Referenced Conditions andamp; Documents Federal Grants Program regulations (con’t) When are they important? Non-research awards? Yes, information tends to be award specific Usually available through other agency publications Examples: 34 FR 648: Graduate Assistance in Areas of National need 34 CFR 675: Federal Work-Study Program

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts Consists of 4 parts Part I: The 'Schedule' Part II: Contract clauses Part III: List of documents, exhibits and other attachments Part IV: Representations and instructions

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts The 'Schedule' Section A: Solicitation information May contain administrative information, instructions Section B: Description of the supplies or services Section C: Specifications and statement of work

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts The 'Schedule' (con’t) Section D: Packaging and marking requirements Section E: Inspection and acceptance requirements Section F: Requirements for delivery and performance

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts The 'Schedule' (con’t) Section G: Contract administration Section H: Special contract requirements See 35.015 requirements that would be placed here

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts Part II: Contract Clauses Many clauses are sited Clauses that warrant particular attention include 52.216-7 Allowable cost andamp; payment Reference OMB Circular A-21 52.232-20 Limitation of cost Applies to 'fully funded' contracts Requires notification when cost thresholds are approached

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts Part II: Contract Clauses (Con’t) Clauses that warrant particular attention include (con’t) 52.232-22 Limitation of funds Applies to incrementally funded contracts Requires notification as cost thresholds on allotted funds are approached

X. Referenced Conditions & DocumentsFederal Contracts: 

X. Referenced Conditions andamp; Documents Federal Contracts Part II: Contract Clauses (Con’t) Clauses that warrant particular attention include (con’t) 52.244-2 Subcontracts Requires contracting officer approval 52.245-5 Government property Maintenance and management requirements Unless specifically stated in the 'Schedule', title vests with the government 35.014 Addresses equipment title subject

X. Referenced Conditions & DocumentsNon-Federal Grants & Contracts: 

X. Referenced Conditions andamp; Documents Non-Federal Grants andamp; Contracts Conditions andamp; documents are referenced in a manner similar to what is done for federal grants and contracts

XI. Administrative Information: 

XI. Administrative Information Administrator needs to learn from the award instrument information on: Program and budget revisions Cost Principles Period of availability of funds Program (technical) reporting requirements Financial reporting requirements Record retention requirements

XI. Administrative Information: 

XI. Administrative Information Administrator needs to learn from the award instrument information on (con’t): Cost sharing Program income Equipment

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program and Budget Revisions Federal agency grant prior approval requirements Located in For grants: General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 25 of A-110 For contracts The 'Schedule'

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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 andamp; regulations that implement A-110 §__.25(c)(5)

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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 federal owned equipment Equipment Pre-agreement (pre-award) costs Special arrangement and alteration costs

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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 andlt; $25k NSF has waived Other agencies: Assume no waivers

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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 andlt; $10k Other agencies have waived Other awards Assume no waivers

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Program and Budget Revisions: 

XI. Administrative Information: Program 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

XI. Administrative Information:Cost Principles: 

XI. Administrative Information: Cost 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

XI. Administrative Information:Cost Principles: 

XI. Administrative Information: Cost Principles A-21 reference For grants: General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 27 of A-110 For contracts The 'Schedule' Contract Clause 52.216-7

XI. Administrative Information:Period of Availability of Funds: 

XI. Administrative Information: Period 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.

XI. Administrative Information:Period of Availability of Funds: 

XI. Administrative Information: Period of Availability of Funds Grants (con’t) Most multi-year awards are incrementally funded. Each incrementally funded period then has its funds restricted to obligations that arise during that period Section 25 of A-110, however, allows awarding agency to give grantee authority to carry-forward unobligated balances to subsequent periods.

XI. Administrative Information:Period of Availability of Funds: 

XI. Administrative Information: Period of Availability of Funds Grants (con’t) A-110 reference General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 28 andamp; 25 of A-110

XI. Administrative Information:Period of Availability of Funds: 

XI. Administrative Information: Period of Availability of Funds Contracts There is no FAR clause analogous to Section 28 of A-110

XI. Administrative Information:Period of Availability of Funds: 

XI. Administrative Information: Period 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

XI. Administrative Information:Technical Reporting Requirements: 

XI. Administrative Information: Technical Reporting Requirements Grants Awarding agencies technical reporting requirements must comply with Section 51 of A-110 Award references General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 51 of A-110

XI. Administrative Information:Technical Reporting Requirements: 

XI. Administrative Information: Technical Reporting Requirements Contracts There is no FAR clause analogous to Section 51 of A-110 Reporting requirements will be detailed in the 'Schedule'

XI. Administrative Information:Financial Reporting Requirements: 

XI. Administrative Information: Financial 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 shall be due no later than 90 days after the grant year

XI. Administrative Information:Financial Reporting Requirements: 

XI. Administrative Information: Financial Reporting Requirements Grants (con’t) Awarding agencies financial reporting requirements must comply with Section 52 of A-110 (con’t) Award references General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 52 of A-110

XI. Administrative Information:Financial Reporting Requirements: 

XI. Administrative Information: Financial Reporting Requirements Contracts There is no FAR clause analogous to Section 52 of A-110 Reporting requirements will be detailed in the 'Schedule'

XI. Administrative Information:Record Retention Requirements: 

XI. Administrative Information: Record Retention Requirements Grants Awarding agencies financial reporting requirements must comply with Section 53 of A-110 Award references to Section 53 General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 53 of A-110

XI. Administrative Information:Record Retention Requirements: 

XI. Administrative Information: Record Retention Requirements Grants (con’t) Requirement Awards that are renewed quarterly or annually Retain records for a period of 3 years from the date of submission of the quarterly or annual financial report Awards that are renewed annually Retain records for a period of 3 years from the date of submission of the quarterly or annual financial report

XI. Administrative Information:Record Retention Requirements: 

XI. Administrative Information: Record Retention Requirements Contracts FAR clause 52.215-2 is analogous to Section 53 of A-110 Requirement 'The contractor shall make available . . . records until 3 years after final payment. . . .'

XI. Administrative Information:Cost Sharing: 

XI. Administrative Information: Cost Sharing Cost sharing expenses are award expenses funded by the University Cost sharing not required as a condition of the award is referred to as voluntary Cost sharing required as a condition of the award is referred to as mandatory

XI. Administrative Information:Mandatory Cost Sharing: 

XI. Administrative Information: Mandatory Cost Sharing Grants Awarding agencies cost sharing requirements must comply with Section 23 of A-110 Award references to Section 23 General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 23 of A-110

XI. Administrative Information:Mandatory Cost Sharing: 

XI. Administrative Information: Mandatory Cost Sharing Grants (con’t) Requirements Allowable cost Documentation Cost sharing indirect costs requires agency prior approval Contracts Cost sharing almost never applies to a contract

XI. Administrative Information:Program Income: 

XI. Administrative Information: Program Income Program income is income that is earned as a result of an award funded activity Possible examples Fees charged for award sponsored conferences Equipment user charges

XI. Administrative Information:Program Income: 

XI. Administrative Information: Program Income Grants Awarding agencies must comply with Section 24 of A-110 Award references to Section 24 General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 24 of A-110

XI. Administrative Information:Program Income: 

XI. Administrative Information: Program Income Grants Requirement Agencies may exclude royalty and copyright income For included income, agencies may Allow the income to be added to the award Allow the income to be used to fund required cost sharing Reduce the award by the amount of income

XI. Administrative Information:Program Income: 

XI. Administrative Information: Program Income Contracts There is no FAR clause analogous to Section 24 of A-110 Reporting requirements will be detailed in the 'Schedule'

XI. Administrative Information:Equipment: 

XI. Administrative Information: Equipment Grants Awarding agencies equipment requirements must comply with Section 33 of A-110 Award references to Section 33 General terms andamp; conditions Agency publications Agency administrative regulations that implement Section 33 of A-110

XI. Administrative Information:Equipment: 

XI. Administrative Information: Equipment Grants Requirement Title For research awards, title may be vested with the University Most, if not all, agencies have done this For other awards, title remains with the government Equipment Management Prudent maintenance and safekeeping Inventory records Annual reporting of government owned equipment

XI. Administrative Information:Equipment: 

XI. Administrative Information: Equipment Contracts FAR clause 52.245-1 is analogous to Section 53 of A-110 Requirement Title belongs to the government

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions Article 1 of NSF Tandamp;Cs require that, 'the Principal Investigator or Project Director receives a copy of the award conditions, including the award letter, the budget, the general terms and conditions, any special terms and conditions, and any subsequent changes in the award conditions.'

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs Artl. 1 Recipient responsibilities and federal requirements Artl. 2 Allowable costs and prior approvals Artl. 3 Programs of related projects Artl. 4 Payment Artl. 5 Significant project changes Artl. 6 Non-competitive or continuation award requirements

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs (con’t) Artl. 7 Financial reports Artl. 8 Final report requirements Artl. 9 Dissemination of project results Artl. 10 Acknowledgement of support and disclaimer Artl. 11 Data collection Artl. 12 Site visits Artl. 13 Pre-award costs

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs (con’t) Artl. 14 Extensions without additional funds Artl. 15 Equipment and real property Artl. 16 Alteration and renovation Artl. 17 Use of U.S.-Flag air carriers Artl. 18 Financial management system Artl. 19 Procurement system Artl. 20 Program income

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs (con’t) Artl. 21 Unobligated balances and limit of federal liability Artl. 22 Patents and inventions Artl. 23 Audits and records Artl. 24 Termination and enforcement Artl. 25 National security Artl. 26 Nondiscrimination Artl. 27 Animal Welfare

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs (con’t) Artl. 28 Research involving recombinant DNA Molecules Artl. 29 Clean air and water Artl. 30 Human subjects Artl. 31 Activities abroad

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions General T andamp; Cs FDP T andamp; Cs (con’t) Artl. 32 Debarred or suspended parties Artl. 33 Closeout Artl. 34 Rights in data Artl. 35 Changes

XII. Award Review with the PITerms & Conditions: 

XII. Award Review with the PI Terms andamp; Conditions Special terms andamp; conditions What controls are needed to ensure compliance?

XII. Award Review with the PIAdministrative information: 

XII. Award Review with the PI Administrative information Administrative information learned from the award instrument Program and budget revisions Cost principles Period of availability of funds Program income requirements

XII. Award Review with the PIAdministrative information (con’t): 

XII. Award Review with the PI Administrative information (con’t) Administrative information learned from the award instrument Cost sharing requirements Equipment management requirements Program (technical) reporting requirements Financial reporting requirements

XII.Award Review with the PIBudget: 

XII.Award Review with the PI Budget Compare award budget to proposal budget What is the impact of the changes Are additional funds needed? Can work be revised without changing scope? Is there an impact on other awards?

XII.Award Review with the PIBudget: 

XII.Award Review with the PI Budget Develop a budget management strategy Taylor to the specific award Develop reporting mechanism Reconcile reports back to FAS’ AM090, 91 Reports Establish reporting formats andamp; schedule

XII.Award Review with the PIBudget: 

XII.Award Review with the PI Budget Payroll appointments Verify compensation budget Individuals to be charged Charge % andlt;= Effort % Other account distributions that are affected Procurements Are agency prior approvals required? Equipment Subcontracts

XII.Award Review with the PIBudget: 

XII.Award Review with the PI Budget Procurements (con’t) One-time When: Now or future How andamp; when should procurement be initiated? Recurring Recharge center procurements Other misc’l supplies andamp; expenses

XII.Award Review with the PIBudget: 

XII.Award Review with the PI Budget Establish communications protocol Identify roles and responsibilities of: P.I. Research staff Administrative staff Review Financial Policy No. 2101, PI Responsibilities for Financial Oversight of Grants and Contracts

XIII. Award AccountsConsiderations: 

XIII. Award Accounts Considerations 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 Tandamp;Cs Are funds restricted by multiple purposes?

XIII. Award AccountsConsiderations: 

XIII. Award Accounts Considerations 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

XIII. Award AccountsConsiderations: 

XIII. Award Accounts Considerations How many accounts are needed? (con’t) Are 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

XIII. Award AccountsConsiderations: 

XIII. Award Accounts Considerations Regulatory compliance Approvals required before account can be created/opened Human subjects Animals Recombinant DNA Biosafety

XIII. Award AccountsHow are Regular Accounts Created: 

XIII. 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

XIII. Award AccountsHow are Regular Accounts Created: 

XIII. Award Accounts How are Regular Accounts Created Non-LBC Account Create Process (con’t) NIH and NSF 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

XIII. Award AccountsHow are Regular Accounts Created: 

XIII. Award Accounts How are Regular Accounts Created Advance accounts Restricted Funds receives the award from URA Changes the status from 'Advance' to 'Regular' Enters the budget based upon the award agreement

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects Interim technical reporting to funding agency Critical stewardship Requirement = part of terms and conditions On-going, incremental funding may be dependent upon programmatic reporting Timing: annual or more frequent Differing formats

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NSF requirements Annual progress report Submitted to cognizant program officer with copy to URA Expected three months before end of current funding period NSF annual reports now submitted electronically by PI

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NSF requirements (con’t) Report format requests information on: Summary of progress Summary of proposed work in next year of support Proposed budget for coming year

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NSF requirements (con’t) Report format requests information on (con’t): Current and pending support Contribution to education and human resource development Updated info on animal, human, biosafety, etc. PI certification

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations under SNAP Administrative, financial, and programmatic review Four core questions-gauge key issues Personnel/effort Spending patterns Budget required ? Human subjects/animals

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations eSNAP submissions Annual progress report NIH prepares pre-printed 2590 face page; see NIH Commons Requires administrative, financial and programmatic review

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations (con’t) NIH Awards under SNAP ( R and K series) Budget not required Requires four questions: Significant rebudgeting Carry forward of 25% or $250,000 Change in the effort of key personnel Change in other support of key personnel

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations (con’t) NIH Awards under SNAP ( R and K series) Requires four questions con’t): Answers of yes trigger - Justification Additional, updated materials, like Current and Pending Support Budget

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations (con’t) NIH Awards under SNAP ( R and K series) Narrative Report on Programmatic Progress Update on Human and Animal use Update on project effort for key personnel Updated checklist with indirect cost rate (not calculation)

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects NIH non-competing continuations (con’t) If not awarded under SNAP Budgets required Review by program officer Review triggers non-competing NGA

XIV. Managing Programmatic AspectsAnnual Regulatory Review: 

XIV. Managing Programmatic Aspects Annual Regulatory Review Continuing review requirements Regulatory requirement No less than annual Period determined at initial review or previous continuing review

XIV. Managing Programmatic AspectsAnnual Regulatory Review: 

XIV. Managing Programmatic Aspects Annual Regulatory Review Human subjects Is study/protocol still active Have any changes crept in Have there been adverse events Do benefits outweigh risks

XIV. Managing Programmatic AspectsAnnual Regulatory Review: 

XIV. Managing Programmatic Aspects Annual Regulatory Review Human subjects (con’t) Is consent form still current and appropriate Must be reviewed at convened meeting Approval must occur before the anniversary date If not renewed in time, terminated

XIV. Managing Programmatic AspectsAnnual Regulatory Review: 

XIV. Managing Programmatic Aspects Annual Regulatory Review Animal care and use Is study still active Reassess animal numbers Morbidity/mortality in animals Annual renewals maybe approved by subcommittee Every three years, complete resubmission

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects Compliance with terms and conditions of award Publication review Publication citations Sharing research resources

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects Compliance with terms and conditions of award (con’t) Confidential materials--marking, storage, agreement with research team Intellectual property--disclosure, informing sponsor Record retention and storage

XIV. Managing Programmatic Aspects: 

XIV. 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

XIV. Managing Programmatic Aspects: 

XIV. 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

XIV. Managing Programmatic Aspects: 

XIV. Managing Programmatic Aspects Approval of changes to award terms (con’t) Requiring agency approvals--contracts Change in budget Carry forward Change in personnel/effort Etc.

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates 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

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates 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

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates A-21 Cost Principles Requirements (Con’t) Conform to limitations in A-21 or the sponsored agreement Examples A-21 prohibits student aid charges to research agreements DHHS awards prohibit salary charges at a rate that exceeds $125,900/yr..

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates A-21 Cost Principles Requirements (Con’t) Practical guidelines Cost must Benefit the project Be charged consistently as direct cost Be included in the award budget or list of allowable costs in Section J of A-21 or an agency publication

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Costs normally treated as indirect costs Administrative, secretary, andamp; clerical compensation Telecommunications, memberships, postage, office supplies University guidelines for charging appear in Section 307B of URA’s Guidelines for Grant and Contract Management

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention Alterations andamp; renovations May require prior approval Alcoholic beverages Generally unallowable Animals Excluded from indirect cost MTDC base

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Books and periodicals Normally treated as indirect cost Dependency allowances Generally unallowable

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates 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

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Property insurance Prior approval needed for government owned property University provided insurance generally allowable Medical insurance for sponsored fellows and trainees Allowable because University requires proof of coverage

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Participant support costs--NSF awards Rebudgeting prior approval required

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Patient care costs Routine and ancillary medical services Require prior approval Publications Costs exceeding certain amount may require prior approval Acknowledgements, disclaimers required

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Salaries and wages % salaries charged must be andlt;= % of effort Must conform with effort reporting procedures Unallowable if Annual Certification Statement is not completed

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Salaries and wages (con’t) Salary funds may become restricted if Research Career Development Award is received College Work Study Program may be used to pay non-federal share of research project expenses

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Student aid (tuition, fees and stipends) Unallowable charge to federal research awards Special terms and conditions usually apply e.g.. NRSA awards

XV. Managing Award FundingAllowable Cost Determinates: 

XV. Managing Award Funding Allowable Cost Determinates Other costs that warrant attention (con’t) Travel Must comply with University travel policies Use of foreign flag-carriers generally prohibited Foreign travel may require prior approval

XV. Managing Award FundingAllocating Costs: 

XV. Managing Award Funding Allocating Costs Guidelines A-21, Section C.4.d University Financial Policy No. 2109

XV. Managing Award FundingAllocating Costs (con’t): 

XV. Managing Award Funding Allocating Costs (con’t) If a cost benefits one project or activity, the cost should be charged to that project or activity.

XV. Managing Award FundingAllocating Costs (con’t): 

XV. Managing Award Funding Allocating Costs (con’t) 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.

XV. Managing Award FundingAllocating Costs (con’t): 

XV. Managing Award Funding Allocating Costs (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.

XV. Managing Award FundingOfficial Accounting Reports: 

XV. Managing Award Funding Official Accounting Reports FAS reports Monthly Reports AM090: Account Statement in Whole Dollars AM091: Report of Transactions

XV. Managing Award FundingOfficial Accounting Reports: 

XV. Managing Award Funding Official Accounting Reports Payroll reports Reports generated for each monthly and biweekly payroll Expense Summary Report Expense Detail Report

XV. Managing Award FundingOfficial Accounting Reports: 

XV. 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

XV. Managing Award FundingCost Sharing Procedures: 

XV. 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

XV. Managing Award FundingCost Transfers: 

XV. 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

XV. Managing Award FundingCost Transfers: 

XV. 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

XV. Managing Award FundingCost Transfers: 

XV. Managing Award Funding Cost Transfers University policy andamp; procedures Ensure conformance with regulations Policy Financial Policy No. 2111 Procedures

XV. Managing Award FundingEffort System: 

XV. 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 andamp; reporting Significant changes Certification

XV. Managing Award FundingEffort System: 

XV. Managing Award Funding Effort System Work plan Payroll distributions reflect work plan Distributions to sponsored agreements % of salary charge andlt;= % of effort

XV. Managing Award FundingEffort System: 

XV. Managing Award Funding Effort System Monitoring andamp; reporting Payroll reports issued with pay periods Monthly monitoring report Individuals charge to sponsored agreements Shows all payroll % distributions Distributed to departmental payroll contact person Attachment to 'closing memo' Shows % distribution and end date

XV. Managing Award FundingEffort System: 

XV. Managing Award Funding Effort System Significant changes Future Enter payroll distribution changes Retroactive Submit cost transfers

XV. Managing Award FundingEffort System: 

XV. Managing Award Funding Effort System Certification Monthly employees Annual Biweekly employees Biweekly

XVI. Audits: 

XVI. Audits Test for compliance Federal regulations Award specific Non-award specific Not to be feared if UC policies and procedures are followed Award specific restrictions are met

XVI. Audits: 

XVI. Audits Audit requests Comptroller Office coordinates response Department assists in response where necessary

XVI. Audits: 

XVI. Audits Types A-133 Award closeout Special subjects Proposal

XVI. Audits: 

XVI. Audits Types A-133 Performed by KPMG Federal programs divided into 3 categories Research Student financial assistance Other

XVI. Audits: 

XVI. Audits Types A-133 (con’t) Emphasis on UC systems Allowable costs: Salary caps, student aid, etc. Effort reporting Cost transfers Period of funding availability Financial reporting

XVI. Audits: 

XVI. Audits Types A-133 (con’t) Emphasis on UC systems (con’t) Procurement Recharge center pricing Billing Equipment inventory Subrecipient monitoring

XVI. Audits: 

XVI. Audits Types A-133 (con’t) Tests compliance with award specific restrictions Prior approval requirement Cost sharing Student assistance awards unique regulations Training program eligibility Etc.

XVI. Audits: 

XVI. Audits Types (con’t) 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

XVI. Audits: 

XVI. Audits Types (con’t) Special subjects Examples NSF Graduate Research Training Program NSF travel expenses HHS Recharge centers

XVI. Audits: 

XVI. Audits Types (con’t) Proposal Seldom done Usually involves contracts Emphasis is on Reviewing estimating techniques Compliance with FAR solicitation provisions

XVII. Financial ReportsDeadlines: 

XVII. 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

XVII. Financial ReportsTypes: 

XVII. Financial Reports Types Request for Advance or Reimbursement (SF 270) Report of Federal Cash Transactions (SF 272) Financial Status Report (SF 269, 269A)

XVII. Financial ReportsClosing Memo: 

XVII. 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

XVII. Financial ReportsClosing Memo (Con’t): 

XVII. 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.

XVII. Financial ReportsFinancial Status Report (SF 269, 269A): 

XVII. Financial Reports Financial Status Report (SF 269, 269A) When are Closing Memos required Required for all final FSRs Interim FSRs Required only if prior approval required for carry forward of unobligated balance

XVII. Financial ReportsFinancial Status Report (SF 269, 269A): 

XVII. 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

XVII. Financial ReportsOther Financial Reports: 

XVII. 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

XVII. Financial ReportsOther Financial Reports: 

XVII. Financial Reports Other Financial Reports Report of Federal Cash Transactions (SF 272) Shows both expenditures and cash receipts Completed by Comptroller’s Office

XVII. Financial ReportsOther Financial Reports: 

XVII. Financial Reports Other Financial Reports Non-federal reports Similar to federal reports

XVIII. Billing & Collecting Funds: 

XVIII. Billing andamp; Collecting Funds Billing Federal 95% are letter-of-credit funded ('billed') 5% are invoiced Non-federal 5% are invoiced 95% are on a payment schedule or paid up front

XIX. Intellectual Property: 

XIX. Intellectual Property University policies Patent Policy – Board of Trustees Statute 18 New Information Technologies – Rights to Intellectual Property Determination of who has rights to discoveries in the course of sponsored research/projects?

XIX. Intellectual Property: 

XIX. 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?

XIX. Intellectual Property: 

XIX. Intellectual Property FOIA public right to federally-sponsored research data OMB in process of defining implementing regulation Each agency will do agency-specific implementation

XIX. Intellectual Property: 

XIX. Intellectual Property PI responsibility to disclose discoveries Office of Special Projects Guidance on Disclosure Process and forms Review of Disclosure to confirm sponsored research and relevant MTAs University turns over disclosure to UCTech

XIX. Intellectual Property: 

XIX. Intellectual Property PI responsibility to disclose discoveries (con’t) UCTech assesses commercial potential of discovery UCTech has brief period to elect title to disclosure If elected, UCTech must seek appropriate protection for intellectual property (IP)

XIX. Intellectual Property: 

XIX. Intellectual Property Governing regulations for IP derived from sponsored projects Bayh-Dole Act for all Federally-funded IP Bayh-Dole spells out extensive compliance and reporting requirements for IP elected by UCTech Terms and Conditions of awards for other sponsored projects MTA Terms andamp; Conditions

XIX. Intellectual Property: 

XIX. Intellectual Property Governing regulations for IP derived from sponsored projects (con’t) Compliance obligations Royalty sharing Release of IP if unelected or UCTech abandons commercialization effort Rights of Sponsors take precedence over rights of PI March-in

XX. Project Termination: 

XX. Project Termination Final technical report FASTLANE for NSF projects Confirmation of receipt of FASTLANE submission sent to URA Other Technical Reporting – Confirm submission of report to URA URA follows up on late technical reports – Administrator, PI, Department Chair, Dean, Provost

XX. Project Termination: 

XX. Project Termination Final technical report (con’t) Sponsor may withhold funding for University if ANY Final Report is overdue Agencies that do this include NEH, Air Force

XX. Project Termination: 

XX. Project Termination NIH Invention Report Requires URA signature

XX. Project Termination: 

XX. 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

XX. Project Termination: 

XX. Project Termination Integration of close out of records with restricted funds (con’t) A-110 records retention requirement Obligations to keep local records

XX. Project Termination: 

XX. 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

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Managing Faculty Arrivals/Departures Faculty appointment/termination Space commissioning/decommissioning Equipment - transfer in and purchase/ transfer out and sell Other personnel Protocols - initiating/terminating Subcontracting to or from current/new institutions

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Managing Faculty Arrivals/Departures (con’t) On-going responsibilities - IP, record retention and access, sharing research resources Transferring awards into or out of University of Chicago

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transferring property to/from U of C Title generally resides with University University must approve transfers of equipment to which it holds title If University does not hold title, entity with title must provide permission

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transferring property to/from UC (con’t) Property inventory and tagging, as well as local inventories = key Transferring property with Departing Faculty Agency expectations for equipment in support of active awards Equipment purchased from institutional funds University policy and form

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transferring property to/from UC (con’t) Transferring property for Newly-recruited faculty Decision made at prior institution Effect official transfer of title U of C property to tag and inventory

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Agency prerogative Agency requirements vary

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transfer of awards from U of C Should U of retain award Change of PI On-going support of personnel/students Is award individual or institutions (e.g. RO1 versus training grants, SCOR, etc.) Issues: Estimating final balances Carry forward

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transfer of awards from U of C (con’t) Possibilities Leave award at U of C and name substitute PI Leave at U of C, name substitute PI and request permission to subcontract Relinquish award Relinquish award with expectation of subcontract to U of C

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring a NIH award from UC Contact program officer and request institute specific instructions Prepare and submit through normal sign-off channels: Relinquishment statement Invention and Patent statement List of equipment purchased from that award and proposed to be moved A copy of the instructions received from NIH

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring a NIH award to the UC Contact program officer and request institute specific instructions Prepare and submit through normal sign-off channels: Face page (with IRB/IACUC info) Proposed budget (transfer year and future years) and justification Workscope

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring a NIH award to the UC (con’t) Prepare and submit through normal sign-off channels: Description of effects of transfer on project Description of Facilities and Resources at U of C Biosketch and other support, if changing Checklist page Copy of original NGA Specific instructions from NIH

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring NSF award from U of C Contact program officer to determine course of action If NSF endorses transfer, complete NSF Form 1263 - NSF Grant Transfer Request Cover memo explaining impending move and requesting grant be transferred List of equipment purchased with grant funds for transfer

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring NSF award to U of C Contact program officer to determine course of action If NSF endorses transfer, complete NSF Form 1263 - NSF Grant Transfer Request Brief summary of progress to date Description of work to be completed Budget and justification List of equipment Ideally, copy of original grant and award letter

XXI. Relinquishing/Transferring Programs or Awards: 

XXI. Relinquishing/Transferring Programs or Awards Transfer of awards Transferring NSF award to U of C (con’t) Contact program officer to determine course of action Contact program officer and request institute specific instructions Prepare and submit through normal sign-off channels

Related Web Sites: 

Related Web Sites FDP general and agency specific terms andamp; conditions NSF Grant Proposal Guide NIH Grants Policy Statement

Related Web Sites: 

Related Web Sites NIH terms and conditions for individual and institutional National Research Service Awards OMB Circulars A-21, A-110, A-133

Related Web Sites: 

Related Web Sites NASA Grant and Cooperative Agreement Handbook Code of Federal Regulations (CFR) Agency administrative regulations that implement A-110 (Accessible through the CFR Web site) Agriculture 7 CFR 3019 Defense 32 CFR 32

Related Web Sites: 

Related Web Sites Agency administrative regulations that implement A-110 (Accessible through the CFR Web site) Con’t: Education 34 CFR 74 Energy 10 CFR 600 NIH/DHHS 45 CFR 74 HUD 24 CFR 84 Interior 43 CFR 12 Justice 28 CFR 70 Labor 29 CFR 95 State 22 CFR 145

Related Web Sites: 

Related Web Sites Agency administrative regulations that implement A-110 (Accessible through the CFR Web site) Con’t: DOT 49 CFR 19 AID 22 CFR 226 EPA 40 CFR 30 NASA 14 CFR 1260 Federal Acquisition Regulations

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