Many of you who read these entries attend our Tips and Tools meetings each month, and for you we have a resource from last month’s meeting: the Grant Math slides. As you may recall, these slides reviewed common calculations for salary cap calculations, indirect costs on subcontracts, and rebudgeting between categories. Whether or not you were able to attend the meeting, please feel free to contact us if you have any questions about the calculations (or any calculations at all!). In today’s meeting, we’re discussing PMCID compliance, so you may also wish to download our PMCID Primer.
For those who are not yet aware, the RAS office holds “Tips & Tools” meetings on the third Wednesday of each month, from 9:00a-10:00a. These meetings generally take place in 1358 Scott Hall and are open to all department administrators to whom grant management information is helpful. We discuss everything in the realms of both pre-award and post-award, highlighting recently-released information that is changing the landscape of the world of research projects. This meeting is a great opportunity to not only learn what is new, but to hear about methods and implements that other administrators have to share that have made their jobs easier. If you are interested in attending or having your name added to the distribution list, please send us an email at RAS@med.wayne.edu!
You’re responsible. You’re conservative. You’re great with money. You get to the end of the year on your NIH project, and you have only spent $220,000 of your $300,000 budget! Joy! Rapture! New cell lines for all in Year 2! You have a carryover! But not so fast… sometimes being frugal doesn’t pay; in fact, if not done right, it could lead to penalty.
Carryover (or carry forward) is the transfer, at the end of a budget period to the next budget period, of any unobligated balance or over expenditure of funds which remains (except in the final year of a grant; and NIH allows carryover between competing awards: see NIH Grants Policy section 184.108.40.206.). Overexpenditures carried forward are a debit (including the prior year’s indirect cost rate) from the total funds available for the current year. Keep in mind when calculating: there is a difference between unliquidated obligations and unobligated balances. Unliquidated obligations are commitments of the recipient and are considered to be obligations and, therefore, should not be reported as unobligated balances. This affects your carryover percentage.
Wayne State University is a Federal Demonstration Partnership (FDP) university. As such, automatic cumulative carryover is allowed up to 25% of the current year’s total budget. Any estimated unobligated balance (including prior year carryover) that is greater than 25% of the current year’s total budget on more than $250,000 must be explained in the non-competing continuation applications. To ensure carryover, the Financial Status Report (FSR) must be received by the agency no later than 90 days after the close of the budget period. This means that the Principal Investigator must work with SPA to ensure that the FSR is received by the agency within the 90-day period.
So back to our original hypothetical: what happens if you really DO only spend $220,000 of the $300,000 budget? The $80,000 in unspent/unobligated funds amounts to 26.7%, which means an explanation is required (unless specifically stated otherwise in your Notice of Award). If you find yourself in need of approval for a carry forward, here is the information you will need to provide:
- A detailed budget by direct cost category with the F&A cost information (base and rate) for the proposed use of the carryover funds. In general, carryovers to the following year will be approved using the F&A rate that was in effect at the time of initial award. However, actual expenditures will still be based on the rate applicable when the cost is incurred. Note: if personnel costs are requested, include a detailed breakdown of personnel costs, including base salary, salary requested and effort to be spent on the project during the extension.
- A scientific justification for the use of funds.
- The reason for the unobligated balance.
For more information on carryover procedures and requirements, see NIH Grants Policy sections 220.127.116.11 (Carryover of Unobligated Balances) and 18.104.22.168.1 (Modified Annual Progress Reports), and let us know if you need assistance!
Before you read on to determine the best way to handle your consultant during the pre-award period, be sure you really DO have a consultant: check out “Show Us What You’re Working With: Consultants, Collaborators and Co-Is” to be sure your classification is correct!
Consultants are entities (individuals or companies) that recieve a portion of the funds from your grant as an expert advisor or provider of goods and services. They are paid by the hour or day for the work they do on the project, unless they are not paid at all. Consultants do not maintain rights to intellectual property or authorship for published work from the sponsored project. While a consultant may contribute their expertise on a project, they cannot be named as a Co-PI or Co-Director, nor can they be considered as “key personnel.” Consultants should only be external to Wayne State; in rare instances a consultant may be employed by the University, but the chances are very high that if you are listing Wayne State University faculty, they should not be classified as “consultant.” Don’t forget, there are parameters for any WSU employees to receive compensation for consulting services on sponsored projects. The Office of Technology Commercialization provides a seven-point list on staying within bounds.
If required, all Conflict of Interest disclosures and any training from consultants must be submitted prior to the proposal deadline. See the WSU Division of Research Conflict of Interest page for details.
What to Include in the Proposal for Consultants
When listing a consultant in the proposal budget, include all their travel expenses and supplies as line items under the “consultant” subheading if these elements are part of their agreement. Since they are not employed by Wayne State, their travel and supplies cannot be listed under the normal “travel” and “material and supplies.” Consultants fees are generally listed as a daily/weekly rate or a flat fee for services.
Unless the sponsoring agency guidelines require any forms or letters related to consultants be included with a proposal, proposals are typically not required to include any additional forms related to consultants listed on those proposals. Once a grant is awarded, consultant expenses are treated as any other expense on the award.
If you have questions about how to properly classify personnel on your grant, don’t hesitate to contact us! To learn more about the parameters for defining roles, check out Part II of the NIH Grants Policy Statement. “Consultant Services” are well defined in the table at 7.9.1, about half-way down the page.
One of the more difficult awards to navigate is the fellowship. Fellowships are awards that come with lots of prestige and the opportunity for excellent research pursuits, but they aren’t without their hardships for the recipient (and often for the administrator as well). Federal policies have a significant impact on the policies and practices of research institutions, and Wayne State University is no exception. If you have a pre- or postdoc in your department who has been offered a fellowship, it is very important to have a conversation with him or her so s/he fully understands both the benefits and consequences of accepting a fellowship. Here are some points that potential fellows need to understand:
- Fellows are not employees. They are not employees of the university, and they are not employees of the agency awarding the fellowship. Legally, fellows are considered “trainees” or “stipendees” performing independent research, and therefore not subject (or entitled) to the same set of standards and benefits as an employee. There is an excellent article in Science Magazine from several years ago that discusses how this has come out in the courts, for better or worse.
- Medical and dental benefits come out of the fellowship payment, not provided by the university or the granting institution. This is related the above point, as perhaps the most difficult concept to grasp for many fellows. The fellow can enroll in a university health care plan, however the premium is at a higher rate. Most fellowship stipends provide for this in the explanation of the award’s intent; NIH provides for this as an “institutional allowance”, a defined part of the award specifically meant to defray the costs of healthcare. This means that for a fellow, when selecting health care coverage from the university options, a higher-cost plan will mean more money out of pocket, but whose pocket? Some departments choose to help their fellows by picking the excess costs from departmental funds, but are under no obligation to do so and often do not. The burden of responsibility for health care costs is a very important conversation to have with your fellow.
- When administrators are reconciling fellowship accounts, check the FRIGITD and PHICHEK screens for the correct account codes: 6223 indicates Medical Insurance and 6224 indicates Dental Insurance. It is important that these codes show the correct proportions of the fellowship stipend dedicated to satisfying the charges associated with these coverages. In many cases, administrators have found either incorrect deductions, or no deductions at all. Ensuring that the account codes are correctly entered when the account is initially established will prevent not only future deficit, but the painstaking steps necessary to correct them.
For documentation of Wayne State University’s definition of a fellowship status, check out the Administrative Policy and Procedure Manual (APPM) section 1.3.4; section 4.0 specifically discusses procedure for establishing the correct payment line. If you are specifically working with an NIH F32 award, PA-06-373 details the required allotment for stipend funds in section II.2. (Note: if you are APPLYING for an F32, don’t forget to use the new codes from the reissue!) For help in deciphering your award, contact us anytime!
Many of you know that the RPPR (Research Performance Progress Report) format is now required for most NIH progress reports (specifically Streamlined Noncompeting Award Process (SNAP) and Fellowship awards). Note that NIH has discontinued the use of the PHS 416-9, NRSA Individual Fellowship Progress Report for Continuation Support, and requires use of the RPPR for all Fellowship progress reports. (As a side note, did you know that all of the NIH Fellowship Award Announcements are being reissued under new numbers? If you or one of your students is in the process of applying, be sure to look for your new announcement number.)
To help you navigate the RPPR process, here are a selection of the top ten things you’ll want to know to understand the behavior of the report form:
- Your RPPR is populated with information from your last report. This information appears in a gray font, which may lead you to think that you can’t edit, but much of it you can! There will be an “edit” link toward the right side of your screen that will allow you to change the pre-populated information; you don’t need agency approval to do this.
- Your selection of references comes from you NCBI bibliography. If you do not see a publication that you wish to include, go to your NCBI account to add it manually. Once you have done this, you will be able to add it to your RPPR.
- RPPR does NOT automatically save information that has been entered or uploaded when the user navigates to a different component or a different Commons page. Be sure to use the “save” button often, which appears at the top and bottom left of each screen.
- The Recipient ID field is for YOUR, use, not NIH. This field allows you to record an internal tracking number or identifier WSU use. It is not a mandatory field and NIH will disregard the information, so don’t panic trying to find what number goes here.
- “Major goals of the project” are the same thing as your “Specific Aims.” If NIH approved changes to the goals prior to award or during the reporting period, list the revised goals and objectives and explain any significant changes in approach or methods from the agency approved application or plan; you will only be able to edit these directly in Year 1. If you are in Year 2 or later, checking the box indicating that goals have changed will yield a new box for your new goals. In this case, both your original Specific Aims and your revised goals will be displayed.
- NIH’s recommended length is up to one page for each section, even though the physically allowable amount is the equivalent of three pages.
- The maximum size for PDFs uploaded to the RPPR is 6MB.
- All publications arising from an award during the reporting period must be reported regardless of the public access status of the publication. You must, then, report your publications even if they appear in your NCBI bibliography as “noncompliant.” If you submit with a noncompliance publication, you will receive a warning message, and an email requesting compliance verification no later than two weeks prior to the start date of the next budget period. It’s surely a pain, but you have to report all of your publications. Remember, you only need to report a publication one time per award so if you’ve already reported a pub in a previous progress report, you don’t need to do it again on subsequent reports.
- When reporting effort, person months are now rounded to the nearest whole month. This is the new federal standard promulgated for interim progress reports by OMB in the RPPR Final Format. For interim reporting purposes, however, the new standard allows a reasonable variance of 0.5. Although by NIH definition PD/PI effort must be greater than zero, in instances where the PD/PI has 0.4 person month or less, you will need to report zero person month in the RPPR.
- When preparing “Other Support” for the RPPR, include the effort for the next year of the current grant. The effort listed in the RPPR for “Personnel”is retrospective, while effort included in the “Other Support” should be prospective.
Many times a project that has received funding will need to begin operations before the promised money has actually arrived at the University. When this happens, don’t fret: WSU has a mechanism in place to ensure that you (or your investigator) can begin research in a timely manner: it is called a Provisional Fund Request (PFR), also commonly referred to as a “puffer form.” This form requests that an account be established prior to the final signing of any contract or notice of award, against which project expenses can be charged. A few things to note when establishing a PFR:
- You will need to reference the eProp number associated with the proposal for the forthcoming award
- Written proof that the project has been awarded is necessary
- You must provide a valid indirect cost recovery account (ICR) as “collateral”
- The period of time for a provisional account or extension is 4 months
- Both the PI and the department chair (or authorized representative thereof) must approve with signatures
- The PFR form will be submitted to your GCO
As somewhat indicated in the bullets above: if for whatever reason approval for the project falls through, the responsibility for any premature expenditures will fall to the PI and/or the department. Sponsored Projects (SPA) has detailed, step-by-step instructions to guide you in completing your PFR; they also provide the form on their website. If you have any questions about getting ready to submit your PFR, RAS is always here to help!
Strictly-speaking, we’re speaking of the removal of information in a document appendix, of course. The “Appendices” section of the SF424 cannot be used to get around the page limits of other sections (the most popular? Research Strategy, which is limited to 12 pages for an R01 in case you’re counting along). Information that *is* allowed as appendices includes:
- Up to 3 of the following types of publications (any exceptions will be noted in your announcement):
- Manuscripts and/or abstracts accepted for publication but not yet published
- Published manuscripts and/or abstracts only when a free, online, publicly available journal link is not available
- Patents materials directly relevant to the project
- Surveys, questionnaires, data collection instruments, etc.
- Clinical protocols
- Informed consent documents (as necessary)
Information that is NOT allowed in the appendix is:
- Published manuscripts and/or abstracts that are publicly available in a free, online format
- Note: you can reference these in the application, and URLs and PMCID numbers can be included in the References Cited section. There is no limit on the number of references you can site, but applicants are encouraged to be “both judicious and concise.”
- Graphic images of gels, micrographs, photographs, etc. These may be included in your research plan and are therefore subject to the page limit. The SF 424 (R&R) Application Guide sets forth guidance as to size and resolution of images that you may include in your plan
- Note: there are some liberties that may be taken with PAPER SUBMISSIONS ONLY. If you are planning on submitting via paper application, please contact RAS and we will clarify your latitude.
Most people know by now that the NIH cap on compensated salary has been raised to $181,500, and that all new proposals should reflect this number in their budgets. Budgets, though, have two distinct fields that rely on this number; what exactly do you do with it?
- The “Institutional Base Salary” field. You have your choice on how to handle this field. You may enter the actual institutional base salary (even if over the current NIH salary cap) OR, if your investigator would prefer not to reveal actual salary, you can input the cap number ($181,500) and add an asterisk (*). If you use an asterisk, provide an explanation in the budget justification that the researcher has elected not to include actual salary information and a statement that the institutional base salary exceeds the salary cap (if applicable). If this option is selected, PIs must still submit one copy of the application to NIH that does include the institutional base salary. SPA prefers that you state the actual salary in your explanation if you elect not to include it in the budget worksheet, as this satisfies the requirement.
- The “Salary Requested” field. If your investigator is over the salary cap, your salary requested is the effort percentage multiplied by the salary cap. For instance, if your investigator’s institutional base salary (note: do NOT include attachment or additional assignment amounts) is $200,000 and s/he will be devoting 10% effort to the project, your salary requested is [10% x $181,500] = $18,150.
This, of course, brings us to voluntary uncommitted cost sharing. If your investigator is over the NIH salary cap, this means that his or her department must absorb the difference; this is known as mandatory cost share. Cost sharing must be requested and documented before the application is submitted, and the form can be found here. To calculate how much your will need to request in cost sharing in a single year, you will need to determine the investigator’s institutional base salary (from Banner NBAJOBS screen) and the amount of effort the investigator will be devoting to the project:
[Non-Allowable Salary in a Year] = ( [Investigator Institutional Base] x [Investigator Project Effort] ) – ( [NIH Salary Cap] x [Investigator Project Effort] )
So, using the example numbers from above for an investigator with an institutional base of $200,000:
[Non-Allowable Salary in a Year] = ($200,000 x 10%) – ($181,500 x 10%)
Don’t forget to request the applicable fringes in each year as well; these are also considered to be above the NIH salary cap. In our example above, we would request the department to pick up the the Wayne State University fringe rate 26.8% in addition to the salary over the cap. Fringes, then, would be calculated as $1,850 x 26.8% = $495.80 The departmental cost share request for the year we just calculated, then, would be $1,850 salary + $495.80 fringes, for a total amount of $2,345.80 in that year. This downloadable spreadsheet may help you in your calculations; don’t forget to calculate each year of the project separately if you have included projected salary increases or adjustments in effort percentages in different years.
Well, sweat the details a little bit.
Modular submissions to NIH calls for proposal are very attractive, especially due to the perceived lower level of scrutiny thee budgets receive (and, of course, the “25% Rebudgeting Rule” doesn’t apply to modular grants!). If you have a project requesting $250,000 or less in direct costs in all years, your project is likely qualified for a modular submission (otherwise known as the “PHS398 Modular Budget component”). Keep in mind, however, that you will still need to submit a detailed budget to SPA at the time of proposal submission; this is for accounting and set-up purposes once the project is awarded.
What do you need to know about submitting a modular budget?
A few things to keep in mind:
- A modular budget is not accepted for SBIR and STTR grant applications.
- There are only two justifications required for a modular budget:
- You must include a personnel justification, including the name, role, and number of person-months for every person on the project. Note: salary and fringes are not to be discussed in the justification.
- If you have a consortium or subcontract, you must have a corresponding justification which includes the total costs (direct + F&A), rounded to the nearest $1,000, for each consortium/sub. Any personnel should have roles and person-months defined. If the consortium is foreign, be sure to identify it as a foreign component.
- While not always required, you may also need to include an “Additional Narrative Justification” to explain any variations in the number modules requested annually. Also use this section to describe and direct costs that were excluded from the total direct costs (equipment, tuition, etc) and any work being conducted off-site.
Why does SPA require a detailed budget if NIH only requires a modular for my project?
There are many reasons SPA requires a detailed budget in all instances, and why it’s a good thing for the PI:
- Certain budgetary detail helps in determining exclusions from the base when calculating facilities and administrative (indirect) costs.
- The PI can ensure that adequate resources are being requested for the proposed research activity.
- Agencies can (and have) come back to ask for details; it’s good to have them at the ready.
- Your detailed cost categories and amounts are used for budgeting loading once the project is awarded.
Modular budgeting saves time, effort and (oftentimes) agency scrutiny, but it doesn’t completely negate the need for detailed preparation. For more detailed assistance on preparing a budget, check out the WSU-SOM Office of Research’s Proposal Prep page, or contact RAS for more specific guidance.