Several departments currently have HRSA (Health Resources and Services Administration) funding, and should be aware that there is an upcoming to the log-in procedure for accessing the EHBs:
As of November 21st, 2014 you must use your EMAIL ADDRESS instead of your current EHB usernmame to log in to the system.
The HRSA Contact Center is available to help if are still having difficulty with access: 877-464-4772
As we draw nearer to the implementation of the Super Circular, our friends at NCURA continue to put out some very helpful vlogs (video logs) on some of the highlighted changes. There is a new rule for indirect cost rate negotiations, in fact, that now allows a one-time, four-year extension on current negotiated rates. This is governed by section 200.414 (linked, for your reading pleasure); you can check out the short NCURA video here:
The possibility of a rate extension theoretically saves universities (and other entities) time and negotiation resources by allowing for the postponement of the process. Of course, the costs associated with the preparation of the proposal for the extension itself are other other consideration factors. What is your opinion on the effect of this change; will it save administrative burden as intended? We’d love to hear your thoughts!
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!
Ah, the “Credential” field in the SF424. This little line has sent many an administrator scrambling at the last second, calling for hasty assigning of eRA Commons log-ins for unregistered key personnel:
Not including the credential/login for Senior/Key Personnel is, after all one of the most generated sources of error in electronic submission. In fact, it is so prevalent that NIH lists it as #3 on their “Ten Checks to Help Avoid Common Errors.” And when a subawardee is also a key person and doesn’t have a login, we set outside instutions to scrambling for IDs as well. But here’s a little secret: your suncontract key person doesn’t necessarily have to have an eRA Commons login to include him/her as a “Senior/Key Person.”
Shock! Scandal! No really, it’s true. On the “Frequently Asked Questions” page for Applying Electronically, NIH states in section I.C.6:
6. For consortium/subawards, do the sub-awardees need to be registered with eRA Commons and Grants.gov?
Sub-awardees are not required to register. However, we do encourage them to be proactive and register to be ready to serve as primary awardees in the future.
That said, you can’t leave the “Credential” field blank if your subaward key person doesn’t have a login; you will still trigger the error and this could prevent your application from being submitted by the deadline. If you find yourself with a subaward key person with no login, the easiest workaround is to enter the person’s first initial and last name in the “Credential” field, so the system does not trigger an error for a blank requirement. If, for instance, you have a subaward to Dr. Sam Samson from the University of Madagascar (many investigators from Madagascar, we have found, do not have eRA Commons log-ins), in his credential field you can enter “SSAMSON”:
Please note that this only applies to subcontracts/subawards; signing officials and the PD/PI(s) must be registered in the NIH eRA Commons in order to submit. And, in the case of multi-project applications, the component leads must also be registered. Give us a shout if you are unclear as to whether you can submit without an agency credential on a certain person; we’re happy to help you troubleshoot!
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:
- There are now only four fringe rate categories (reduced from the previous six).
- Employee classes are allocated by new role/function definitions.
- 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!
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!
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!
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 (RAS@med.wayne.edu) 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.
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.
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.