You may occasionally ask yourself, “I wonder what’s up with the Federal Register these days?” Well is this the post for you! On March 14, that bastion of registries federal posted the Final Notice of Research Terms and Conditions (RTC) To Address and Implement the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Issued by the U.S. Office of Management and Budget (OMB), and man, is it ever widely applicable. Except to the Department of Defense. They march to their own drummer.
- Department of Agriculture / National Institute of Food and Agriculture (June 1, 2017)
- Department of Commerce (October 1, 2017)
- Department of Energy (April 3, 2017)
- Department of Health and Human Services / National Institutes of Health (April 3, 2017)
- Department of Homeland Security (to be determined)
- Department of Transportation (October 1, 2017)
- Environmental Protection Agency (December 2017)
- National Aeronautics and Space Administration (October 1, 2017)
- National Science Foundation (April 3, 2017)
Again, notice DoD is not on this list. They fully intend to comply UG in their own way, and they can do that presumably because of the “you and what army” rule.
The RTCs will make all awards from the above agencies subject to the administrative requirements, cost principles, and audit requirements set forth by the UG. If you’ve been preparing for this moment since 2014, congratulations on your big day: it’s finally arrived.
Be on the lookout! In addition to the RTCs, three companion resources will be developed: Appendix A, Prior Approval Matrix; Appendix B, Subaward Requirements Matrix; and Appendix C, National Policy Requirements Matrix. Questions about how this affects your award management going forward? Your GCO will help you find answers!
With so many research opportunities to sift through, it’s no wonder that some agencies try to be as focused as possible in the projects they consider. One method used is the “limited funding opportunity,” in which the potential funder will only consider a finite number of applications from any given institution (often, that finite number is “one.”)
Here at Wayne State University, Sarah James is your go-to person for limited funding opportunity administration. In order to ensure the highest likelihood of proposal acceptance, it is Sarah’s office in the Division of Research that ensures the best-fit candidate from Wayne State is matched with the limited opportunity, and prevents extra work from being done on an opportunity that has already been claimed. Many limited submission opportunities are listed on a dedicated website, but the list is by no means exhaustive: if you run across an opportunity that limits the number of applications from a single university, you must contact Sarah James before you submit, whether the opportunity is listed on WSU’s site or not.
If multiple parties from WSU are interested in a limited opportunity, the Division of Research will hold an internal competition to consider whether a pre-proposal meets all eligibility requirements specified by the funding organization RFA, are scientifically and technically strong, and promote the greater WSU research mission. Every situation is unique, so don’t waste your time: contact the Division of Research right away if you find a limited submission of interest!
(This post is the first of a featured series entitled “Kontracts Korner,” accessible as a heading in the Categories menu to the right.)
So you met someone. You just know in your heart that this person completes you. Maybe they have a piece of equipment that would send your research to soaring heights, perhaps it is a like-minded researcher that could accelerate a project idea. Or maybe someone just wants to validate your existence with money for your time. You, friend, have reached the point of calling the Contract Services division of SPA. The contracts administration division evolved from the need for a specialized group to devote resources and time to contract processing. Contract processing can be a very lengthy and cumbersome process, and Contracts Services is here to shorten it. No one wants to wait when they’ve found their business soulmate.
Certainly you have questions! But how do you know what you don’t know? What to ask? How to go forward? Let’s take a look at few definitions to get your thoughts headed in the right direction:
(The following apply at WSU, and are adapted from “Management Reporting Standards for Educational Institutions: Fund-Raising and Related Activities” issued by the National Association of College and University Business Officers and the Council for the Advancement and Support of Education.)
- Grant: A contribution received by the University for either restricted or unrestricted use in furtherance of the institution’s mission that typically comes from a corporation, foundation or other organization, not an individual. Grants normally fall into two categories, both of which are considered philanthropic in nature and thus countable in annual giving or comprehensive campaign reports:
- Non-specific grants – A grant received by the university that did not result from a specific grant proposal. The university does not commit specific resources or services and is not required to report to the donor on the use of the funds. It is this type of grant that many institutions may opt to designate as a gift for internal accounting purposes. Grants of this nature will be administered by Wayne State University’s Development and Alumni Affairs’ office.
- Specific grants – A grant received by the institution resulting from a grant proposal submitted by the university. The university commits resources or services as a condition of the grant, and the grantor often requests an accounting of the use of funds and of results of the programs or projects undertaken. The grantor’s requirement of regular status reports or other reports does not negate the philanthropic (and countable) nature of a specific grant. Grants of this nature will be administered by Wayne State University’s Sponsored Program Administration office.
- Contract: An agreement between the institution and another entity to provide an economic benefit for compensation. The agreement is binding and creates a quid pro quo relationship between the institution and the entity. The University’s responsibility under a contract normally involves the generation of some product or service, such as a report of research by the Office of the Vice President for Research, and generally subject to certain standards of performance and the expectation of tangible benefit on the part of the contractor. The difference between a grant and contract may be judged on the basis of the intention of the awarding party and the legal obligation incurred by an institution in accepting the award.
Source: University Policy 04-05-Approval, Stewardship, and Reporting of Gifts, Grants and Contracts (formerly known as Executive Order 87-2, §2.1).
We know that the realm of contracts encompasses a whole host of situations, and yours may be unique. We have assigned target areas that can help you get to the heart of your issue more quickly. The following are the members of the contracts team can help you in their areas of expertise:
- Patty Yuhas Kieleszewski, Manager
Ph: (313) 577-9227 Email: firstname.lastname@example.org
– Master agreements
– PRB (Perinatology Research Branch) NIH contract
- Liane Lehto, Grant & Contract Officer III
Ph: (313) 577-7945 Email: email@example.com
– Clinical trial agreements
– Confidentiality disclosure agreements for clinical trials
– Investigator-initiated agreements
- Kate Althouse, Grant & Contract Officer III
Ph: (313) 577-0192 Email: firstname.lastname@example.org
– Non-clinical trial agreements
– Federal pass-through contracts
– Confidentiality disclosure agreements for all others
- Mike Maher, Grant & Contract Officer III
Ph: (313) 577-9490 Email: email@example.com
– Subcontract Agreements
– Risk Assessment Questionnaires
- Lawanna Dean at (313) 577-2294 or firstname.lastname@example.org for questions concerning:
– Processing of all subcontract invoices
– Processing of requisitions and change purchase order requests for all subcontracts
Give us a call. We’re here for you during this very exciting time in your life!
Ask not for whom the bell tolls, it tolls for the FPR. That’s right: the Final Progress Report (FPR) is going the way of various previous forms iterations to be replaced by the F-RPPR. No big surprise, right? This is part of a government-wide transition to a standard reporting format for all research federally-funded; we were warned with the implementation of the RPPR back in October 2014 that the FPR would eventually be swallowed up, too. The end is nigh: the F-RPPR is officially mandated for required use as of January 1, 2017.
Forms changes are usually met with a collective eye-roll (and usually for good reason), but this is actually good news. Since we’ve been using the interim RPPR for quite some time now, we’re all familiar with the format. It’s much more structured than the FPR, as it is a fillable webform module in eRACommons with pointed questions (rather than the “best of luck on your upload” PDF format that is in current play). Further, not all of the sections from the FPR will be included on the F-RPPR: for example, Section D – Participants; Section F – Changes; and Section H – Budget will not be part of the Final RPPR. Hooray for brevity!
Remember, any final progress report submitted after January 1, 2017 will need to be submitted as a Final RPPR. Any other submission format will be rejected will require resubmission in the Final RPPR format. Check out NOT-OD-17-022 for the official announcement.
And while we have your attention, don’t forget that the new Evisions system will be replacing EPROP(COEUS) effective January 3, 2016. Training is still available if you haven’t gotten there quite yet!
Hey Wayne State. We need to talk.
Have you ever had that restless yearning to seek the unknown? To see if there is something else out there for you? Of course you have, Wayne State – you’ve been around the block more than a few times. Heck, you probably wrote the book – I mean, you essentially exist for people to forge futures for themselves, am I right? You know, the whole wanderlust thing. The “I’m going to school to better myself” thing. The “shaping the minds of tomorrow’s leaders” thing.
Hmm? What’s that, Wayne State? Why am I rambling? Well… this is going to hurt me more than it’s going to hurt you but, I think we need to break up. No, we definitely need to break up. I want to see other universities. It’s not you, it’s me and I hope we can part as friends. Really? You’re OK with that? That’s it? Wow Wayne State. I mean, I kind of expected a different reaction is all. No, no – I’m good.
I was wondering, though, if you don’t mind giving me some advice as I really don’t know what lies next for me. Yeah, I know I have “that restless yearning”. I just thought you wouldn’t mind helping me out a little before I go – we have been through a lot together after all. You will? Thanks Wayne State – you truly are one of a kind. Whoa — you already had something prepared? You have been around, haven’t you Wayne State?
Change of PI or Institution
Once a Principal Investigator (PI) has decided to leave the institution, a decision must be made as to whether or not Wayne State wishes to retain the project. If the project is to remain here, then someone else must be identified as the PI on the project. Different agencies have different requirements as to the notification and approval process to accomplish this. The appropriate Grant & Contract Officer should be notified to coordinate the change.
The transfer of awards for new and existing faculty can be a daunting task. Be sure to devote as much time as possible! Transfers should be initiated as soon as a new faculty member accepts a job offer, and as soon as a current faculty member submits a resignation. Please note that transfers are not guaranteed – the sponsor must be willing to agree to transfer the funds and Wayne State University has the right to retain the award and assign a new Principal Investigator. If the award document does not mention the transfer process, contact SPA for assistance.
Once a WSU Principal Investigator (PI) accepts a position at another institution, notification should be given to his or her Department Chair and Administrator. The PI should work with the department and SPA to determine if active awards may be transferred. The Sponsor Program Official for each award should also be notified about the impending transfer. SPA will review the appropriate award documents to see if a transfer is allowable and assist in contacting the awarding agency for permission to transfer the award.
If there are any active NIH awards, the department will need to complete an Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant (form PHS 3734). This form will require submission of a Financial Status Report (FSR) and the approval of SPA.
Once a new faculty member accepts a position at WSU, the department should contact SPA with a list of awards that are to be transferred. The PI should notify contact the Program Official about the impending transfer. The Program Official will be able to provide instructions for facilitation.
If there are any active NIH awards, the award will need to be relinquished by the PI’s current institution. The PI should contact the cognizant NIH Program Official about the transfer. SPA will contact the Grants Management Official at the NIH if additional information is required. Typically, the department is expected to provide a transfer packet, as outlined in the NIH Grants Policy Statement, Section 18.104.22.168 Change of Grantee Organization. For additional reference, please see Change of PI or Institution on SPA’s webpage.