NIH eSubmission Items of Interest – April 15, 2015
eRA Commons Profile Animal Welfare Assurance Numbers to be Automatically Populated from OLAW Database
In order for an institution to conduct animal activities supported by NIH grant funding, it must have an Assurance on file with the Office of Laboratory Animal Welfare (OLAW). For many years, OLAW has maintained a system to keep the negotiated assurances. That system, however, has never been linked with the eRA Commons institutional profile. Instead, Signing Officials (SOs) have had to manually enter assurance numbers in their institution profiles. Without any checks and balances to ensure the data is entered in the correct format and that it matches the information captured by OLAW, using the data in eRA Commons institution profiles has been problematic. How do we improve the accuracy of the profile information and the efficiency of our award processing? You guessed it – link the information between the two systems.
The eRA team will release several changes with the April 16 software release related to assurance numbers. The eRA Commons institution profile will be updated to support multiple assurance numbers and will pull assurance number information directly from the OLAW database. If there is a discrepancy between the information on file with OLAW and the data entered in the institution profile, then both numbers will show in eRA Commons. SOs will no longer be responsible for entering the Animal Welfare Assurance Numbers in the institution profile; in fact, the field will no longer be editable in eRA Commons. Changes will need to go through OLAW.
In addition to the institution profile changes, a new business rule to warn applicants if the Animal Welfare Assurance Number on an application is not among those listed in their organization’s eRA Commons profile will be added to the validations done against incoming grant applications. This warning will help improve the accuracy of information associated with specific applications. To avoid the warning, applicants are encouraged to check their institution profiles and type the assurance number in their application exactly as it appears in the profile.
Later this year, OLAW will be changing their format for assurance numbers (they are running out of numbers). The University of Maryland – College Park with a current assurance number of A3270-01, for example, will be issued a new number with the format ‘D15-xxxxx’ where ‘xxxxx’ is a unique, sequential number. With the eRA changes already in place, the transition to a new number format should be pretty straightforward. The new number will be automatically added to the institution profile and applicants will be asked to begin using their new assurance numbers on applications. A notice in the NIH Guide will be issued once the new assurance number format is implemented.
New PHS Additional Indirect Costs Form in Multi-project Applications
Shortly after rolling out our solution for electronic multi-project applications, we identified an issue with our composite budget calculations. The premise of collecting budget data in the various components where the work is carried out and systematically rolling that data up to create the overall application budget is sound. However, without a budget form in the Overall component, we did not have a place for the applicant organization to apply the first $25,000 of a subawards total costs to their indirect cost base when that subaward was an entire component led by a collaborating organization.
You will now find an optional PHS Additional Indirect Costs form in the Overall component of all multi-project opportunities to address the data collection gap (NOT-OD-15-081).
The Multi-project Annotated Form Set has been updated to include the new form and the Electronic Multi-project Application Image Assembly document has been updated to include the adjustment to the composite application budget calculation.
Straight Talk About Application Requirements
I manage a small support team called Grants Info responsible for responding to grant-related email and phone inquiries. Team members spend the better part of their day helping folks navigate through our many grant resources and matching ‘people who have questions’ with ‘people who have answers’. One of the most popular inquiries we receive is “What exactly do you mean by ‘required’?” This question can, of course, apply to any policy or guidance we put out. Most recently, it has been asked in the context of the new biosketch.
NIH expects applicants and grantees to follow all documented policies and instructions. When completing your grant application you must follow announcement clarification and policy notices posted in the NIH Guide, follow instructions in the Funding Opportunity Announcement and follow the guidance in the application guide and supplemental instructions. I know (better than most) that is easier said than done. The NIH puts out A LOT of grant information keeping my team very busy.
So, when we say NIH “requires use of the new [biosketch] format for applications submitted for due dates on or after May 25, 2015” (NOT-OD-15-032), we mean…
All biosketches included in applications submitted for due dates on/after May 25, 2015 must be formatted per the instructions in the application guide (and repeated in online resources), including:
• Completing each section (A – Personal Statement; B – Positions and Honors; C – Contributions to Science; D – Research Support or Scholastic Performance)
• Including no more than 5 contributions to science with no more than 4 citations per contribution
• Ensuring that if you include the optional link to a full list of your published work in a site like My Bibliography that the URL is public, accessible without providing any login or personal information, and doesn’t link to websites that may violate page limit rules
• Refraining from including information, such as preliminary data, that belongs elsewhere in the application
• Following NIH guidance on font type, font size, paper size, and margins (See section 2.6 of application guide)
• Using PDF format for your biosketch attachments
• Limiting the length to 5 pages or less
The new biosketch policy is “required’ –officially compulsory, or otherwise considered essential; indispensable. Failure to follow the policy means NIH may withdraw your application from consideration (NOT-OD-15-095). The majority of the requirements listed above (all except the 5-page limit) would not be flagged until your application has already moved forward to NIH. If you don’t follow the instructions and our staff manually identifies a biosketch in your application as being non-compliant, then you won’t have the opportunity to correct it before the due date. In that context, is it really worth not following the instructions?
What is Uniform Guidance?
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) were released on December 26, 2013. The Uniform Guidance streamlines and supersedes guidance that was previously contained in eight different OMB Circulars. Included in the new guidance are definitions, uniform administrative requirements (both pre- and post- award), cost-principles, and audit requirements. From the university perspective, the Uniform Guidance will supplant OMB Circulars A-110, A-21, and A-133 as the definitive resource for administrative issues.
When is Uniform Guidance in effect?
The Uniform Guidance administrative requirements and cost-principles will apply to new and incremental funding awarded after December 26, 2014. Existing Federal awards will continue to be governed by the terms and conditions under which they were awarded.
Subpart F, Audit Requirements, will apply to audits on non-Federal entity fiscal years beginning on or after December 26, 2014. For Wayne State University, this will be Fiscal Year October 1, 2015 – September 30, 2016.
Where can I find more information?
The Council on Governmental Relations (COGR) has done extensive work to analyze the guidance, and a link to its “COGR Guide” document is provided (see Related Links). The Federal Demonstration Partnership (FDP) has done analysis and partnered with COGR to produce white papers on various Uniform Guidance topics (see Related Links).
Additional information regarding Uniform Guidance is available at the Council on Financial Assistance Reform (COFAR) website, which contains background information, FAQs, and links to the Uniform Guidance and supplemental materials.
How is WSU implementing the Uniform Guidance?
Wayne State University is working as part of the Council on Governmental Relations and the Federal Demonstration Partnership to analyze and understand the potential impacts of the Uniform Guidance. Wayne State University is awaiting Federal agencies’ final implementing guidance. Federal agencies were to submit draft implementing guidance to the Office of Management and Budget by June 26, 2014 and are expected to implement the requirements by December 26, 2014. In the interim, Sponsored Program Administration is working with WSU Fiscal Operations to identify the major areas of impact. Implementation plans are underway and will be communicated to the various stakeholders as they become available.
For questions or comments related to Uniform Guidance or WSU‘s implementation of Uniform Guidance, please contact Gail Ryan, Assistant Vice President, Sponsored Program Administration,email@example.com; 577-6595.
Known Issues with NIH Multi-project Applications & Dealing with System Issues
There are a couple of known software issues impacting electronic multi-project applications that we’d like to bring to your attention…
Character Limitation for Project Titles of Components
We are currently unable to process applications where the ‘Descriptive Title of Applicant’s Project’ field on the SF424 (R&R) cover form used within multi-project application components is over 75 characters. Although you can use up to 200 characters for your main project title in the Overall component, you can only use 75 characters for the project titles of all other components. This limitation is the result of an issue with how we are generating the Table of Contents within our multi-project assembled application images.
If you are using ASSIST, then this issue may also impact your ability to successfully generate an application preview. If your attempt to generate a preview results in a ‘Failed’ status, check the length of each component project title before trying again.
The fix to this issue will be available on August 8, 2014. Until then, please limit the project titles of your components (other than Overall) to 75 characters or less.
This issue does not impact single-project applications (i.e., you can still include project titles up to 200 characters for your R01 and other single-project submissions.)
Multiple Editors and the Delete Application Action in ASSIST
One of the nice features of ASSIST is that you can have multiple people simultaneously working on your application. However, this also poses some challenges from a system’s perspective. When implementing the new Delete Application feature, we did not correctly handle the scenario when one user attempts to delete an application when another user is editing it.
Currently, the system is working like this…Mary is editing a form in the application. John attempts to execute the Delete Application action, but receives an error indicating that a form in the application is locked by Mary. Mary gets out of the form so John can delete the application. On John’s subsequent attempt to delete the application, he still receives a message indicating that the form is locked by Mary. John must log out of ASSIST and log back in in order to complete the action without errors.
We are scheduled to release a fix to this issue on October 17, 2014. This tiny glitch shouldn’t cause too much worry in the meantime since it only impacts applications that you want to delete.
What to do if you encounter a ‘System Issue’
Experiencing a system issue with ASSIST, Grants.gov, SAM, or eRA Commons that you believe threaten your ability to submit on time? Don’t panic. NIH will not penalize applicants who experience confirmed system issues that are beyond their control. However, it is imperative that you follow our Guidelines for Applicants Experiencing System Issues. This process includes contacting the eRA Commons Help Desk by the due date to report your issue and your good-faith effort to submit on-time. Once it is confirmed that a system issue exists, the help desk will work with you to determine the best path forward. In many cases, the eRA production support team can reprocess your application without any additional action on your end. In other cases, they will provide guidance on changes that must be made to the application in order to process it. Either way, the first step to resolution is contacting the eRA Commons Help Desk.
Applicants that fail to document their issues on or before the submission deadline or that do not have a confirmed system issue will be subject to the standard NIH Policy on Late Submission of Grant Applications.
As always, the eRA Commons Help Desk is available to clarify any of the above items.
Your day is most likely filled with constant communication. Weblog Mind Tools (via Lifehacker) offers a communication checklist to help ensure that your emails, phone calls, and meetings are always productive.
According to the 7 Cs, your communication should always be:
- Clear: Make the goal of your message clear to your recipient. Ask yourself what the purpose of your communication is.
- Concise: Your message should also be brief and to the point. Why communicate your message in six sentences when you can do it in three?
- Concrete: Ensure your message has important details and facts, but that nothing deters the focus of your message.
- Correct: Make sure what you’re writing or saying is accurate. Bad information doesn’t help anybody. Also make sure that your message is typo free.
- Coherent: Does your message make sense? Check to see that all of your points are relevant and that everything is consistent with the tone and flow or your text.
- Complete: Your message is complete when all relevant information is included in an understandable manner and there is a clear “call to action”. Does your audience know what you want them to do?
- Courteous: Ensure that your communication is friendly, open, and honest, regardless of what the message is about. Be empathetic and avoid passive-aggressive tones.
Think about the 7 Cs every time you need to communicate something and you’ll always know you’re delivering the clearest message possible.
“If you drop a computer on your toe, you will have megahertz.”
Dear Dr. Llama,
I am nearing the end of my project and need to purchase a computer and the Sponsored Programs office is giving me grief about this. I’ve got my eye on this sharp new Macintosh and want to get it. Now. Any advice?
Dr. Jona Licious
Dear Dr. Licious,
Computer purchases in the final months of a project period raise audit concerns. What is the benefit to the sponsored project? Obtain documentation and keep for audit purposes. All charges to a project, particularly in the last 90 days of the project period, must be allowable and allocable as a direct cost, and be reasonable and necessary for the conduct of remaining project activities. If the computer is expected to be used beyond the project expiration date, the cost should not be allocated 100% to the expiring project unless continuation funding from that same sponsor is expected.
And remember, purchases to just use remaining funds at the end of a project are not appropriate!