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Wayne State University

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Oct 15 / RAS

You’re Certifiable

It’s that time of year again: effort reporting and certification is upon us.  Wayne State relies upon effort reporting for faculty and staff on grants to confirm that salaries and wages charged to sponsored projects are reasonable for the agreements in place and the actual work performed.  Without effort reporting and certification compliance, financial penalties and expenditure disallowances could result.


In order to help navigate the effort certification system, the folks at CLAS put together some very helpful materials:


And for further reading on the process itself, check out SPA’s effort reporting page.  If you have any difficulty with the system or figuring out who needs to certify whom, RAS has been there and can offer guidance!

Oct 1 / RAS

Lunatic Fringe

Our friends in Sponsored Program Administration recently announced adjustments to the fringe benefit rates, based on the amendment to our Federal Rate Agreement.  These changes are effective today (10/1/14); here are the highlights, in case you missed them:


  1. There are now only four fringe rate categories (reduced from the previous six).
  2. Employee classes are allocated by new role/function definitions.
  3. The “premium” rate that was previously applied to certain designated funds has been eliminated.


These changes will impact the charges to non-General Fund funds, depending on the categorical mix of employees that are charged to those funds.  A schedule showing the “old” and “new” rates by employee class was provided by the Associate Vice President for Fiscal Operations and Controller (Jim Barbret), and is accessible here.


Mr. Barbret has indicated that the Fiscal Operations website will be updated as soon as the updated rate agreement is in hand.  Gail Ryan, Assistant Vice President for SPA, has also offered to answer any questions that you may have.  And, as always, RAS is here to help as well!

Sep 24 / RAS

International Trial of Mystery

Is your department conducting (or planning to conduct) international, patient-oriented research?  NIAID (National Institute of Allergy and Infectious Diseases) has a database of country-specific clinical research regulatory information called ClinRegs, and it is now live (beta)!


ClinRegs is a public resource designed to assist in the planning and implementation of international clinical research.   The database is a tool that can be used to examine regulations within a country, and compare requirements across nations.  Search countries currently include Brazil, China, India, Kenya, Malawi, Peru, United Kingdom, Tanzania, South Africa, Thailand, Uganda, and the United States; there are plans in place to incorporate regulations from Mali, Mexico, Vietnam, and Haiti in 2014.  ClinRegs allows you to explore topic areas such as:  clinical trial lifecycle, competent authority oversight, ethical review, informed consent, investigational products, specimens, and sponsorship.


ClinRegs is soliciting feedback through a survey (linked in the upper-right corner of their home page) or using their “Contact Us” feedback email address.  Take it for a spin and let them – and us! – know what you think!


Sep 17 / RAS

No Agreement, No Rate, No Problem

When utilizing subcontracts on a proposal, occasionally we run into domestic institutions who have no negotiated federal rate agreement.  This means (among other things) that there is no F&A rate.  If the subcontracting institution doesn’t require administrative overhead in their role on the project, it’s not necessary to grant them these costs.  But what if they do require administrative costs?  Scientists gotta science, administrators gotta administer!


For cases like these, there is a minimal threshold set by the federal government for institutions with no negotiated rate: it has been 8%, but has been increased by the OMB Uniform Guidance to 10% for domestic institutions, effective December 26, 2014 (as stated in Section 200.110).  We have been successful here at using the 10% rate on proposals as of late.  To view the full text of the Final OMB Uniform Guidance regarding the increase of the de minimis threshold, take a look at Subpart E, 200.414 on the Federal Register site.  For a breakdown interpretation of the language (for this and other changes), check out the table produced by The Huron Consulting Group, or our post entitled “Super Circular, Super Fun“!


RAS is here to help if you have any questions on how to budget your subcontracts with no negotiated rate.  Feel free to reach out if you need us!

Sep 10 / RAS

Back to the Future

September has officially settled in, which means resuming our monthly Tips & Tools meeting! We hope everyone had a wonderful summer and are gearing up for a very productive fall.


For those of you who may be unaware, our School of Medicine Research Administrative Services (RAS) team hosts a regular meeting (Tips & Tools) on the third Wednesday of each month. At these meetings, we highlight changes and information coming down both internally at Wayne, and from external agencies.  Additionally – and perhaps most importantly – these meetings serve as a forum for research administrators to ask and answer each other’s questions, trouble-shoot, and give/request input on processes. These meetings began for the administrators of the departments at the School of Medicine, but we have many administrators attending from outside the SOM as well! If you are interested in attending, please send us a quick note expressing your interest ( and we’ll give you the details of time and place.


This month’s meeting will take place in one week (September 17, 2014) and will feature special guests Dr. Stephen Lanier (our new Vice President for Research at Wayne State; check out his Crain’s Q&A!) and Ms. Gail Ryan (Wayne’s Assistant Vice President for Sponsored Program Administration).  Come with your questions; they’ll both have answers!  We look forward to seeing you there.

Sep 3 / RAS

Farewell to Terri Larrew

Terri Larrew, long-time friend and administrator for Anatomy and Cell Biology, passed away this past Labor Day weekend. Terri was known not only for her keen ability to perform her job with competence and grace, but for her sense of humor and infectious laughter as well. Please keep Anatomy in your thoughts during this difficult time, and take a moment to remember Terri.

Aug 28 / RAS

25 is the Magic Number

The magic number for NIH seems to be “25%”.  Whether we’re talking about carry forward balances or effort devoted to a project, you have to be under the quarter mark or else have special permission.  Here’s how to determine whether you will need to communicate with your program officer (through your GCO, of course!):   CARRY-FORWARD If you find yourself with unspent funds at the end of a project, you can’t carry those funds forward to the next project period without permission, unless the leftover/unobligated funds equal less than 25%  current year’s total approved budget (including prior-year carryover).  If, for instance, your total approved budget for Year Two is $150,000 and you have monies left over going into Year Three, you must request permission from NIH to keep those funds to spend in addition to your Year Three budget IF you have more than $37,500 left over.  The formula to find your threshold is [Period Total Approved Budget] x [0.25].  If you find yourself with $23,000 at the end of Year Two, you’ll likely not need permission to carry it forward and spend it on top of your approved budget for Year Three.** Keep in mind, however, that if you should find yourself with a balance at the end of Year Three, you must include the Year Two carry-forward in calculating your threshold.  If your approved budget for Year Three is also $150,000, your threshold is calculated as follows:

  • [Period Total Approved Budget + Prior Period Carry-Forward] x [25%]
  • = [$150,000 + $23,000] x [0.25]
  • = [$173,000] x [0.25]
  • = $43,250

If you are carrying funds from Year Three to Year Four in this scenario, and you find yourself with a balance of $43,251, you will need to request permission from NIH to do so, or expect to have your award for Year Four reduced/offset by the unobligated amount.  Note: this means that you will still have the authority to spend at the originally-approved amount in Year Four, but the source of that funding becomes dual: part of your funds for Year Four will come from the left-over funds that remain in your account from Year Three, and NIH will send the remainder in the new period award.  In this example, if the Year Four approved budget was also $150,000, NIH would provide Year Four funds in the amount of [Year Four Approved Budget - Year Three Unobligated Balance], or [$150,000 - $43,251] = $106,749.  This does NOT reduce the Year Four budget to $106,749; rather, NIH expects you to spend at the approved $150,000 level using the unobligated funds from the year before and the new funds to make up the difference.  Had a carry-forward been both requested and approved, NIH would have sent a check for $150,000 and allowed the expenditure of the $43,251 on top of the originally-approved budget.



Bear in mind that “25%” is also the threshold for NIH permission for project effort level reductions.  This reduction threshold is seen as cumulative, i.e., the 25% threshold may be reached by the reduction of two or more efforts per individual in successive project periods that total 25% or more.  Let’s say that Dr. Alpha devotes 25% effort to a project, or 3.0 months.  His threshold for effort reduction is 25% of 3.0 months, or 0.75 months.  If Dr. Alpha reduces his effort in Year 2 by 20% (0.6 months) to 2.4 months, he does not need to request NIH permission.  If he reduces his effort again in Year 3 by 10% (0.24 months), he DOES need special permission at that point, because his effort has been reduced from the last approved level by 28%.

Note: once NIH has approved a reduction, all subsequent reductions are measured at 25% of the last approval (as opposed to consistent measurement against the originally-approved effort levels).   For further details on the 25% thresholds, be sure to read the Section 8 of the NIH Grants Policy Statement.  If you need some guidance on calculating your own thresholds, give us a shout!

** Remember, certain programs are routinely excluded from the ability to automatically carry forward, no matter the balance.  These include centers (P50, P60, P30, and others); cooperative agreements (U); Kirschstein-NRSA institutional research training grants (T); non-Fast Track Phase 1 SBIR and STTR awards (R43 and R41); clinical trials (regardless of activity code); and awards to individuals.

Aug 20 / RAS

Supplemental Form

Most NIH announcements at this point have required the use of the Forms-C package, with two notable exceptions: PA-12-149 “Research Supplements to Promote Diversity in Health-Related Research (Admin Supp)” and PA-12-150 “Research Supplements to Promote Re-Entry into Biomedical and Behavioral Research Careers (Admin Supp)”.


As of last week, both of these programs do, in fact, require the Forms-C set.  For more information, see NOT-OD-14-118.  If you need clarification or guidance on the Forms C set, see our prior post, “Forms “C” and Fringe Rates and Agents, Oh My!” or contact RAS with specific questions!

Aug 13 / RAS

You’re Late, You’re Late, for a Very Important Submission

It happens.  Sometimes your lab floods, or your building is on fire, or you have to flee the country, or you are inundated with paper by your study section.  And sometimes this happens very close to submission deadlines.  What to do?  Here’s what you must be aware of if you are under the gun:



  • An error free application is successfully submitted to by 5 p.m. local time on the due date.  This means that you must allow enough time to correct any errors that may be returned by 5:00pm on the deadline date; an application that was returned with an error at 4:55p and resubmitted with corrections at 5:02p is late and will not be accepted.
  • When due dates fall on a weekend or Federal holiday, they are extended to the next business day. Free time!
  • Permission to submit late is never granted in advance.
  • On EXTREMELY RARE OCCASIONS, late applications may be accepted when accompanied by a cover letter that details compelling reasons for the delay.  The NIH will decide what is “compelling.”  Specific detail about the timing and cause of the delay should be provided so “an informed, objective decision can be made.”  Only the explanatory letter is needed; no other documentation is expected. This letter is available only to NIH staff who have a “need to know” (such as those with referral or review responsibilities); it is not available to reviewers or other staff.
  • Examples of “compelling” reasons include: death of an immediate family member of the PD/PI, sudden acute severe illness of the PD/PI or immediate family member, or large scale natural disasters. Also, recent temporary or ad hoc service by a PD/PI that required a commitment of time that could have been used to prepare an application may be an acceptable reason (i.e.: serving on an NIH extramural review group, NIH Board of Scientific Counselors or an Advisory Board/Council).

  • Examples of unacceptable reasons for late submissions: failure to complete required registrations in advance of the due date, heavy teaching or administrative responsibilities, relocation of a laboratory, ongoing or non-severe health problems, personal events, review service for participants other than a PD/PI, participation in review activities for other Federal agencies or private organizations, attendance at scientific meetings, or having a very busy schedule. For electronic submissions, correction of errors or addressing warnings after the due date is not considered a valid reason for a late submission. However, if the problem is with or eRA Commons, grounds will be considered on a case-by-case basis.  Be sure to follow the directions for documentation given be the NIH here.

  • Late submissions to the NIH are are governed by NOT-OD-11-035.


Other Agencies

  • Most agencies follow policies similar to NIH.  Check your RFP for specific details, or contact us to help you figure out specific guidelines for your agency.


WSU School of Medicine

  • Any proposal submitted with fewer than the required internal three days lead time is considered late, and a late submission form is required to be filed with the SOM Office of Research.
  • Proposals considered “late” by the School of Medicine that are still before the agency deadline may still be submitted; the late submission form serves as documentation of understanding of responsibility for outcomes.  Assistance with late submissions by the RAS office is entirely dependent on volume of on-time submissions.
  • The policy and late submission form for the School of Medicine can be found here.


Sponsored Program Administration (SPA)

  • Proposals must be submitted to SPA a full three business days before the agency deadline.
  • Proposals submitted less than three full University business days before the agency’s deadline will be handled on a first-come, first-served basis, following the completion of proposals submitted on time.
  • Successful submissions of proposals submitted to SPA AFTER the three day window cannot be guaranteed.
  • SPA’s policy is provided on their website, here.


Give yourself some space to breathe: allow yourself enough time to account for the unaccountable! If you have an emergency and you don’t know what to do, contact RAS – we’ll do our best to help you through!