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Wayne State University

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Feb 25 / RAS

Taxation with Proper Representation

Documentation of tax withholding is so in right now.  If you’re an employee of the university (or UPG), you’ve probably received your W2 by now (and if not, you can look it up in Academica under Employee Resources > Employee Self Service > Tax Forms).  If you are a research fellow (or if you have fellows in your lab), tax season is a little less clear.  Remember, fellows are not considered employees and are paid by stipend, which is not actual payroll.  In most cases, WSU does not withhold taxes for its U.S. citizen stipend recipients as there is no requirement to do so (the university DOES have withholding and reporting requirements for non-resident alien stipend recipients, however; country-specific tax treaties may apply, so know your country’s rules and take a look at the IRS requirements for international taxpayers if this applies to you).

 

Stipend monies may not be subject to withholding by the university, but that doesn’t mean they are not subject to taxation; they are: all income that doesn’t go directly to tuition, fees and benefits is taxable income.  As non-employees, stipend recipients will receive a Form 1099 instead of a W2.  If you or stipend recipients in your lab have not yet received a 1099, be sure to contact the office of Total Compensation and Wellness here at WSU.  If you have not already, check your quarterly tax reporting requirements.  Some stipend recipients may be subject to the payment of estimated taxes for the calendar year are due in four installments; April 15th, June 16th, September 15th and January 15 to avoid underpayment penalties.  If you’re unsure, check with an accountant to avoid future sanction.

Feb 18 / RAS

Point of Less Return

Last Wednesday afternoon, Wayne State University announced a new indirect cost allocation structure, effective on awards received on or after October 5, 2015.  The new breakdown for distribution is as follows:

 

  • Central Pool – 49%  Central Pool allocations are used to support general fund expenses that support research activities – such as utilities, depreciation and administrative operations.
  • Department – 8%  ICR allocations to the schools, colleges, and divisions are budgeted in the units, to accurately reflect the budgetary control of those resources.  Before 2009, departmental ICR allocations were budgeted from the Division of Research.
  • Research Stimulation – 24%  The Research Stimulation Fund allocation is recorded in a separate, specifically designated budget in the Division of Research.  The Provost has authority delegated by the President to commit these funds.
  • School/College – 5%
  • Investigators – 5%
  • Research Facilities – 9%  The Research Facilities Fund is recorded in Central Accounts; federal regulations require Wayne State University to spend an amount equivalent to the portion of ICR revenues based on faculty and equipment depreciation on the purchase, repair, acquisition, renovation or improvement of research facilities and equipment.

 

To see how this compares to the current indirect cost allocation, take a look at the Wayne State University FY 2015 Budget Book, “General Policies and Practices” on page G-3 (or 125 in the PDF page search function).   You’ll notice that the biggest increase to re-absorption of funds is in “Research Stimulation;” this adjustment was explained as being due to the determination that “Wayne State University was somewhat unusual in the formula that it uses for decentralized distribution of indirect cost funds associated with extramural research funding, which diluted its capacity to strategically reinvest in its research portfolio.” Further, as a whole, the new allocation formula is seen by its creators as reflective of “the commitment of the university to further support our research mission, invest in infrastructure and enable larger programmatic initiatives to tackle major issues facing our community and society at large…”

 

To better understand how and why indirect costs are distributed as they are, the Wayne State Policy manual addresses this in 03-5: Facilities and Administrative Costs Distribution Policy.

Feb 11 / RAS

Tips & Tools: Form and Function

As a reminder, this is the first month in which our new Tips & Tools meeting format will be enacted!  As the overwhelming majority of our attendees voted to put the meeting on a quarterly schedule, we will not have a physical meeting next week.  Our next meeting in Scott Hall will be held on April 15.

 

Can’t wait that long to get the lowdown on what’s new?  Never fear!  As promised, we will still send out a Research Administrator’s Digest on the third Wednesday of each month without a meeting.  Look for us in your inbox next week, and let us know if you have any questions or topics for highlighted discussion!

Feb 4 / RAS

Study Sections: Know Your Place

The NIH loves to have its funded experts confer their vast knowledge on various new perspectives.  After all, what is the point of all that investment without the benefit of leverage?  In order to remove any barriers to expertise, there are deadline privileges that are associated with giving your time to the NIH; but there are separate classifications of study section servitude, and the benefits of each are directly proportional to the amount of time and effort given.  This is extremely important because there is a common misconception that service on study section automatically lends the right to a late proposal review, but this is not so.  Take a look at the difference and know where you qualify before you plan on adjusting your proposal timelines:

 

SINGLE STUDY SECTION SERVICE

The privilege that comes with serving on a single study section is that the NIH considers this service a reason why a late application might be accepted, provided that the service was conferred in the two months preceding or the two months following the deadline; that is, the NIH will take into account service on the section in deciding whether or not to accept the application for review.  Specifically: 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 (examples include: serving on an NIH extramural review group, NIH Board of Scientific Counselors or an Advisory Board/Council). For the most recent clarifications on late submission policy and other reasons late submissions might be accepted, take a look at NOT-OD-15-039.

The important thing to note here is that a PI does not have an automatic right to acceptance for review after the deadline by virtue of participating on a study section.  Any reasons for late submission must be in relation to the individual(s) with the PD/PI role on the application; if the NIH does not see a causal link, the application will likely be denied review.

 

CONTINUOUS SUBMISSION

Continuous submission allows members of standing committees (as opposed to temporary or ad hoc) and members with “substantial service” to submit proposals for standing deadlines when they are fully developed.  Eligible for events for credit toward the continuous submission standard are membership in chartered standing study sections, NIH Boards of Scientific Counselors, NIH Advisory Boards or Councils, NIH Program Advisory Committees, and/or peer reviewers who have served as regular or temporary members six times in 18 months.  You can check your eligibility by looking for your name on the list that is updated and posted on the standing Continuous Submission information page.  You may also check your eligibility and meetings counted toward the 6/18 standard by logging into your eRACommons account, selecting the “Admin” tab, followed by the “Accounts” tab, and then searching your name.  A table will appear that will indicate in a column called “CS Eligibility Details” whether you qualify for continuous submission:

cs_elig_screenshot

 

Clicking on the “Yes” or “No” in the “CS Eligibility Details” column will give you details as to what was counted toward your eligibility, and what to do if any meetings are missing:

 

cs_detail_screenshot

 

If you’re not sure whether you qualify for continuous submission, we can help you figure it out!  Just remember: the NIH is under no obligation to review your submission if you submit late by reason of participation on a single study section, so don’t extend your timeline and create unnecessary stress!

 

 

Jan 30 / RAS

COFAR, So Good

Now that Uniform Guidance (2 CFR 200) has been in place for a good, solid month and proposal deadlines are looming large, here are few highlights to changes from the way things were previously done:

 

  • Administrative salaries [§200.413 (c)]They’re now allowable, even for non-“major projects,” as long as the cost is “integral” (read: the services are essential, vital, or fundamental to the project or activity)
  • Computing Devices [§200.343]These are now considered a “supply” when less than $5,000. They must be “essential and allocable,” but not necessarily solely dedicated, to the performance of a federal award
    • If the device is NOT solely dedicated, you must justify its use in the project and allocate costs appropriately
  • Cost sharing [§200.306 (a)]: Cost sharing (matching, not inclusive of over-the-cap salary payment) cannot be used during the merit review of proposals, unless specified in a notice of funding opportunity
  • PD/PI Disengagement [§200.308]: Prior approval is required for the disengagement of a PD/PI for more than three months, or a 25 percent reduction in time devoted to the project; project directors can be away from campus and remain engaged in the project at the proposed and awarded levels
    • The difference here is the term “disengagement” rather than “absence;” this recognizes that a PI/PD can be off campus and still engaged in the research, which would not require prior written approval
  • Publication Costs [§200.461 (3)]: Anticipated publication charges that will occur outside of the period of performance CAN be charged
  • Subawards [§200.332]: Fixed price subawards require prior approval and limit each subaward to $150,000

 

If you have any questions about how these changes may affect your award or your proposal, let us know.  We’re here to answer any questions you may have in developing your budget or award strategy!

 

 

Jan 21 / RAS

Knowing [Dates] is Half the Battle

How many of your grants are pending closeout?  Do you know which of your PIs have progress reports coming due?  Have you ever been completely surprised by the issuance of a NoGA?  You just may save yourself some frustration with the help of Commons Quick Queries.

 

Commons Quick Queries helps you to identify –

  • Grants Pending Closeout: Returns a list of NIH  grants due for closeout for the over the last number of days selected (you will need Wayne State’s complete complete IPF number: 9110501).  This list will not include NIH fellowships.  This report does, however, include no-cost extensions, and the date all final reports are due in compliance with the NIH Grants Policy Statement.
  • Commons Registered Organizations: Returns a list of all organizations registered in the eRA Commons (this can be helpful for subcontracting and patterning purposes).
  • Progress Report Search by IPF Number: Returns a list of progress reports that are due within the next 4 months for a selected grantee institution. To find an institution, you must enter the complete IPF number (Wayne State’s is 9110501; note that any record showing as “Yes” to SNAP is actually due on the 15th of the month instead of the 1st as shown in the query results). Notably NOT included: progress reports for Multi-year Funded awards (MYF), which are always due on or before the anniversary of the budget/project period start date of the award and are uploaded as a PDF through the eRA Commons.
  • IPF Number Search: Returns a list of grantee institutions based on a name search (again, helpful for partnering institutions, or if you are a sub on a project that will need a progress report from your portion).
  • Issued Notice of (Grant) Award: Returns a list  of all NoGAs issued in the over the last number of days selected (up to 90), based on the IPF.

 

These tools will help you stay on top of your (or your department’s) upcoming obligations to the NIH.  If you have any questions about what to do with the information you find, we’re here to help!

Jan 14 / RAS

Raising a Glass to Raising the Cap

Consider this post a virtual toast to the NIH for agreeing to cover more of your salary! In case you missed it last week, the NIH salary cap has been raised from $181,500 to $183,300.  This means that all proposals going out after January 11, 2015 should use the $183,300 cap, and all internal cost sharing should be calculated using this number as well.  Remember, NIH competing grant awards with salary levels below the new cap(s) that are issued on or after the January 11, 2015 effective date, are allowed to reflect adjustments to the current and all future years; that is, you may rebudget to accommodate the current Executive Level II salary level and contractors may charge at the higher level. Keep in mind, however, that your award amount will not increase and total estimated cost of the contract will not be modified.  For more information on applicability of the salary cap, see NOT-OD-15-049.

 

As always, if your investigator is over the salary cap, his or her department must absorb the difference.  Cost sharing must be requested and documented before the application is submitted, and the cost share form can be found here.  Here’s a calculation refresher for a PI with 10% effort and a $200,000 base salary:

[Non-Allowable Salary in a Year] = ( [Investigator Institutional Base] x [Investigator Project Effort] ) – ( [NIH Salary Cap] x [Investigator Project Effort] )

[Non-Allowable Salary in a Year] = ($200,000 x 10%) – ($183,300 x 10%)

= $1,670

And of course, don’t forget the fringes:

[Salary Cost Shared] x [Applicable Fringe Rate] = [Fringes Cost Shared]

[$1,670] x [26.6%]

= $444.22

 

For further details on the magic of cost sharing, take a look at our previous post entitled “Pop a Cap in Your Salary“; you may also find this over-the-cap calculator helpful.  If you need help with your calculations or figuring out which rates apply, drop us a line.  Cheers!

Jan 7 / RAS

Ch-Ch-Changes

Welcome back, SOM!  As we begin 2015, many of the federal administrative changes that you’ve been reading about are now officially in effect.  You’ve heard and seen (ad nauseam) that the OMB Uniform Guidance is officially official as of December 26, 2014; but there other impending changes that you should note as well:

 

  • December 4, 2014: Modification to identification of marked changes in resubmissions in effect [NOT-OD-15-030]
  • January 11, 2015: The NIH salary cap is increased to $183,300 [Salary Cap Summary]
  • January 25, 2015: New late submission policy is in effect [NOT-OD-15-039]
  • January 25. 2015: Implementation of the new genomic data sharing policy begins [NOT-OD-15-027]
  • End of January 2015 target: ASSIST will be an option for R03s and R21s [NOT-OD-15-044]
  • On or after May 25, 2015: New biosketch formats will be required (though they are encouraged now; this was changed from the original January 25 deadline) [NOT-OD-15-032]

 

For a more comprehensive look at the changes you can expect, take a look at the administration timeline created by the NIH here.  Feel free to reach out if you have any questions!

Dec 17 / RAS

Fringepocalypse Redux

The October 1 fringe rate adjustment has been rolled back to the pre-October rates.  That is, the 26.6% combination that was previously in place is now in place again, replacing the 21.4% combo that was temporarily in place.  This will remain (we think) until October 1, 2015, when the rate will be revisited again.  These rates have been in effect since November 17, so all proposals since that time period should use these rates (note that we are back to nine classes); any proposals that went out with the four-class rates will still be charged at the currently enacted rate, should they be funded.

 

Note that a BAO memo was released earlier this week, clarifying the steps taken to ensure rate adherence in the system.  The re-updated values have been entered into Banner to identify the rates for each corresponding e-class, effective October 1, 2014. This update has been done and should be reflected with Pay Period 25, so be sure your personnel are aligned to match their new/old classes.  Budget adjustments on affected indexes will also be enacted to make up for previous adjustments and reclassifications on the 4-class rate.

 

We know this can be confusing.  We’re happy to help you sort things out if you’re not quite sure what you are seeing on your accounts.  Give us a shout if you need us!

Dec 10 / RAS

Internal Affair

Many submissions have been initiated for the internal funding competitions sponsored by OVPR (Office of the Vice President for Research).  If you haven’t already, take a look at the existing funding programs and see if they align with your needs!

 

When you’re applying, keep these two important points in mind:

 

  1. Look carefully at the instructions.  It doesn’t jump out at you, but they do require that all applications be submitted as a single PDF file (uploaded into eProp, of course!)
  2. Your eProp completion date is NOT your submission date.  When reviewing applications, OVPR considers the date of submission the day that the eProp has cleared the queue and made it to the OVPR approver.  This means that all of your departmental approvals have to be obtained before the posted due date to be considered on time and eligible for consideration.

 

Most of the confusion experienced so far has stemmed from these procedural issues.  Let us know if we can help with further clarification!