The OMB Uniform Guidance: Key Issues for Universities
The Council on Financial Assistance Reform and the Office of Management and Budget (OMB) officially published the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” in the Federal Register.
The new OMB uniform guidance was released on December 26, 2013. The guidance, or Omni-Circular, consolidates eight OMB circulars into a single document and changes some fundamental concepts underlying the management of sponsored programs.
The Office of Sponsored Programs (OSP), in conjunction with Grant and Contract Accounting (GCA), will host a webinar sponsored by NCURA to disseminate vital information that universities need to understand regarding the new guidance, and how it will affect our current policies and business practices: Conflict of Interest, Subrecipient Monitoring, Fringe Benefits and other financial and non-financial administrative matters.
The new guidance is the single most significant change in research regulations in the last 50 years. Thus, OSP and GCA strongly encourage all central and unit-level pre- and post-award research professionals at AU to attend this webinar to get a general overview of the scope of impending changes to federal regulations that will influence the content of research-related work with AU faculty.
The final guidance will be located in Title 2 of the Code of Federal Regulations (CFR) Chapter I, and Chapter II, Parts 200, 215, 220, 225, and 230. In the meantime, click here for an overview of the OMB Uniform Grant Guidance.
NIH Changes Resubmission Policy
Background of previous Resubmission Policy:
In 2009, NIH revised its resubmission policy by limiting the number of resubmission applications from two (2) to one (1). The policy specified that if the resubmission application was not funded, the application had to be substantially different in content and scope in order to be eligible for submission as a new application.
New Resubmission Policy:
On April 17, 2014, NIH announced a change to the resubmission policy. While the new policy still allows a single resubmission per application, ideas that were unsuccessfully submitted as a resubmission (A1) may now be presented in a new grant application (A0) without having to substantially redesign the content and scope of the project.
Benefit and Impact of New Resubmission Policy:
The resubmission of an idea as new means the application will be considered without an association to a previous submission; that the applicant will not provide an introduction to spell out how the application has changed or respond to previous reviews; and reviewers will be instructed to review it as a new idea even if they have seen it in prior cycles. While there may not be major changes to the research direction of these previously reviewed ideas, NIH expects that applicants will nevertheless take advantage of previous reviewers’ comments to strengthen the applications for each submission.
NIH recognized that it may see an increase in the number of applications per the new policy but emphasized the new policy does not address the fact that NIH funding is still tight—that it will not be able to fund any more projects because of the policy. However, NIH stated it will closely monitor the impact and benefit of the new policy.
OSP is excited to present a brand new funding database called Grant Forward. Grant Forward houses a continuously growing inventory of federal and non-federal funding sources, and provides a truly intuitive and easy searching experience through its robust and sleek interface.
Perform basic searches via free search or choose from a list of pre-classified subject categories
Refine searches by applying specific filters such as sponsor type, funding type, applicant type, deadline date, etc.
Build 'Research Profiles' based on publications and/or keywords associated with research interests, and have those related funding opportunities e-mailed to you daily, weekly, or monthly basis
And much more
Because of these many benefits that Grant Forward offers, service for InfoEd Global (AKA SPINSMARTS) has been discontinued. Users with existing SPINSMARTS accounts however, have automatically been created with Grant Forward accounts. If you had an existing account with InfoEd Global, you should have received an e-mail with credentials for accessing your new Grant Forward account.
If you did not have an InfoEd account, or simply wish to sign up for one, please go here. Start your funding search now!
Fiscal Year End Cut-Off for New Award Set-Up
In consultation with Grants and Contracts Accounting (GCA) and the Controller's Office, a "cut-off" date of April 11, 2014 has been established to ensure timely set-up and reporting of new sponsored awards received in this fiscal year. Thus, all new sponsored awards must be received in OSP on or before April 11 in order to be counted in the 2013-2014 (current) fiscal year.
OSP and GCA will work to ensure all new sponsored awards received in OSP on or before April 11 will be processed and reported in the 2013-2014 fiscal year.
To ensure timely set-up, OSP and/or GCA may require assistance from PI's and their respective academic units to resolve award-related issues such as budget matters to process awards. Also, PI's and their respective academic units should forward all new awards (if received directly from sponsors) to OSP for immediate processing.
All new awards received after April 11 will be processed in the order received but will be reported in the 2014-2015 fiscal year.
Please contact OSP or GCA with any questions you may have.
New Federally Negotiated F&A (Indirect Cost) & Fringe Benefit Rates
Below are the new federally negotiated Facilities & Administrative (Indirect Cost) and Fringe Benefit Rates. Unless otherwise restricted by the sponsor, effective immediately - the new rates should be used on all grant and contract proposals:
Fringe Benefit Rate
For more information regarding the new agreement, click here.
NIH Salary Cap
The Department of Health and Human Services (HHS), including NIH, is operating under the Continuing Appropriations Act, 2014 (H.J. Res. 106) signed by President Obama on January 15, 2014. This Act (CR) continues government operations through January 18, 2014 at the FY 2013 post-sequestration level.
Continuing the procedures identified under NOT-OD-14-012 and consistent with NIH practices during the CRs of FY 2006 - 2013, the NIH will issue non-competing research grant awards at a level below that indicated on the most recent Notice of Award (generally up to 90% of the previously committed level). Upward adjustments to awarded levels will be considered after FY 2014 appropriations are enacted, but NIH expects institutions to monitor their expenditures carefully during this period. All legislative mandates that were in effect in FY 2013 (see NOT-OD-12-034 and NOT-OD-13-064) remain in effect under this CR including the salary limitation set at Executive Level II of the Federal Pay Scale. It should be noted, that the Executive Level II was increased by 1 percent from $179,700 to $181,500 by Executive Order 13655 that became effective January 12, 2014.
2015 Mileage Rates
Effective January 1, 2015, the standard mileage rates for a private automobile used for travel in the performance of a federal sponsored project is 57.5 cents per mile.
National Science Foundation (NSF) Updates Proposal & Award Policies (PAPPG) Changes and Clarifications
(a) Grant Proposal Guide (GPG) for guidance on the preparation and submission of proposals to NSF; and
(b) Award & Administration Guide (AAG) to guide, manage, and monitor the award and administration of grants and cooperative agreements made by the Foundation.
This new version of the PAPPG will be effective for proposals submitted, or due, on or after February 24, 2014. Significant changes include:
Addition to the certification regarding Conflict of Interest regarding the appropriate disclosure process;
Reiteration that indirect costs are not allowed on participant support costs;
Small-scale pilot of a new environmental impacts process with a few programs, prior to NSF-wide implementation;
Updated process for program income reporting; and
Numerous clarifications throughout the document.
A by-chapter summary of the changes is provided at the beginning of both the Grant Proposal Guide and the Award & Administration Guide to assist with identifying the changes.
The National Science Foundation (NSF) is transitioning annual, final, and interim project reporting from FastLane to Research.gov.
What do I Need to Know Now?
Principal Investigators (PIs) and co-PIs must stop submitting new project reports in FastLane starting on February 1, 2013. On March 18, 2013, NSF will transfer its current project reporting service from FastLane to Research.gov. You should pay particular attention to your reports that are currently in progress and reports previously submitted and returned by your NSF Program Officer.
Project reports that are in progress as well as those reports that are returned by NSF program officers should be revised and resubmitted prior to February 1. To assist the research community with this transition, the overdue dates have been extended for all project reports originally scheduled to become overdue between January 31 and April 30, 2013. Starting March 18, 2013, you can use Research.gov to submit project reports.
The National Science Foundation (NSF) has announced that it has recently signed a contract for use of new anti-plagiarism software. This new procedure is in addition to changes listed in the National Science Foundation’s Proposal and Award Policies and Procedures Guide (PAPPG), which went into effect on February 2014.
The new software will be used by NSF on all proposals that are submitted for review. NSF’s interest in the software grew out of an internal inspection carried out on all awards and proposals in fiscal year 2011.
Results of this audit showed that the incidence of "unattributed text" in proposals was high enough that the issue had to be addressed, and the new soft-ware is designed to do just that.
Please go here for more information regarding the new software contract.
As always, the Office of Sponsored Programs’ (OSP) pre-award staff will work with faculty to submit proposals in FastLane that are in compliance with the PAPPG.
FY13-14 Research Administration Certification (RAC) Program
The Office of Sponsored Programs, in collaboration with Grants and Contracts Accounting (GCA), is pleased again to announce the launch of its Research Administration Certification program at American University. RAC is a comprehensive training and certification program designed to assist AU departmental and school/college level staff with research administration and/or grant/contract development and management responsibilities. The RAC program provides pertinent information to enable participants to effectively manage sponsored awards.
The RAC program consists of eight (8) consecutive sessions that will be offered annually during the academic year (Sept - April). Each session lasts approximately 2 hours (depending on content), and will include topics covering proposal preparation, research compliance, financial management and reporting, as well as applicable regulations, policies, and guidelines governing sponsored grant and contract awards.
The following instructor-led sessions will be offered during the Fall 2013 - Spring 2014 semester:
Session 1: Overview of Research Administration (Pre-Award)
Time/Location: 10:00 - 12:00pm/Abramson Family Founders Room (SIS)
In addition, online sessions are offered as an alternative to the instructor-led sessions, and are ideal for those who need to make up RAC sessions that were missed during FY12-13. The online sessions also provide individuals who want a "refresh" on a particular RAC session. In addition, the online component is ideal for individuals who cannot attend the scheduled instructor-led sessions.
A certificate will be issued upon successful completion of all 8 RAC sessions and required quizzes.
A recent internal review of sponsored programs practices revealed an institutional noncompliance matter involving grant proposals submitted to PHS agencies (i.e. NIH, AHRQ, FDA, HRSA, etc.). Specifically, the Principal Investigator's (PI's) Assurance Statement was not obtained by the institution prior to proposal submission as required. The PHS-issued requirement that institutions obtain PI assurances went into effect in 2006 as per NOT-OD-06-054.
NOT-OD-06-054 specifically requires applicant organizations "to secure and retain at the organization a written assurance from the Principal Investigator (PI) prior to submitting an application to PHS." NOT-OD-06-054 also states that "this assurance must be available to the sponsoring agency or other authorized HHS or Federal officials upon request."
According to PHS guidelines, an applicant organization may secure a "written assurance from the PI in either a traditional handwritten format or through alternative methods such as:
1) An electronic or on-line review/approval system that distinctly captures the PI assurance
2) A scanned copy of a PI signature certifying to an assurance
3) A faxed copy of a PI signature certifying to an assurance
Regardless of the method chosen, the organization must be able to ensure the authenticity of the signature. As per NOT-OD-06-054, “such an assurance must include at least the following certifications: (1) that the information submitted within the application is true, complete and accurate to the best of the PI's knowledge; (2) that any false, fictitious, or fraudulent statements or claims may subject the PI to criminal, civil, or administrative penalties; and (3) that the PI agrees to accept responsibility for the scientific conduct of the project and to provide the required progress reports if a grant is awarded as a result of the application."
Because American University currently uses an electronic proposal review/approval process ("Cayuse"), the required PI Assurance Statement will be included on the proposal routing form attached in Cayuse. Because Cayuse is the institution's official proposal routing/approval system, the PI is deemed to have provided assurance when the PI approves his/her proposal in Cayuse at the time of proposal routing. Thus, no additional PI signatures will be needed.
If circumstances occur where the PI is not able to access Cayuse, the Office of Sponsored Programs (OSP) will make every attempt to obtain the PI's Assurance, including providing a hardcopy assurance statement via fax and/or e-mail for the PI's signature. However, per PHS policy, the PI cannot delegate his/her signature authority for the purpose of providing the required PI Assurance. Thus, a PI may not have someone else sign on his/her behalf and may not have someone else "approve" the proposal on his/her behalf in Cayuse.
Although the PI Assurance Statement is only applicable to PHS agencies, as a matter of consistent institutional practices, the PI Assurance will be required for all proposals prior to submission to funding agencies.
Project/Award Start-Up Meeting Criteria
To ensure proper administration and institutional compliance with sponsored awards, the Office of Sponsored Programs (OSP) has established new criteria for determining when Project/Award Start-up meetings will be required.
Effective September 4, 2012, Project/Award Start-Up meetings will be required when one (or combination) of the following applies:
The project is a first award to the Principal Investigator (PI)
The PI, Grant & Contracts Accounting, Research Compliance, Vice Provost or Dean has requested the meeting
When the sponsored award contains any of the following conditions:
Cost Share Commitments/Requirements
Effort reporting frequency differs from institutional policy
Special space requirements: when the project calls for leased space, off-campus space, private/project office space, etc.
Special Risk and Compliance Matters: involving human subjects, animals, biological material, export control considerations, foreign travel to known countries of risk, etc.
Special Publication Conditions: prior review, special acknowledgement, use of name/logo, etc.
Intellectual Property: where terms, though consistent with University policy, are unique or atypical.
Atypical project reporting requirements: technical, financial, supporting documentation, etc.
Awards requiring project activity/expenses to be tracked and reported separately.
Unusual Budget Restrictions (including special re-budget prior approval requirements).
Use of Subcontractors/Consultants when proposed payment or deliverable schedule will potentially impact AU's performance and/or payment obligation to Subcontractor/Consultant.
Other special terms and conditions governing PI's responsibility, project administration, and/or institutional compliance.
While the impact of the above new criteria may reduce the number of Project/Award Start-up meetings, the primary purpose for establishing the new criteria is to ensure a thorough understanding of select special terms and conditions governing the award, and special responsibilities of the PI and/or American University.
NIH grantees with Streamlined Noncompeting Award Process (SNAP) and Fellowship awards are now required to use the eRA Research Performance Progress Report (RPPR) Commons Module for awards with start dates on or after July 1, 2013 (due dates on or after May 15 and May 1, respectively). Progress reports for these awards submitted in any other format will not be accepted and must be resubmitted in the RPPR format. If a progress report has been initiated as an eSNAP, the format must be changed to the RPPR, with the help of the eRA help desk. It is important to be aware of these requirements because noncompliance with them will jeopardize the NIH's ability to issue timely awards.
Not sure if this requirement applies to your NIH grant? Your Notice of Award will specify whether an award uses SNAP. Awards routinely using SNAP are "K" awards and "R" awards. The RPPR requirement also applies to all fellowship ("F") awards as well. If you need additional help, you can find contact info for assistance in this NIH Guide notice, or get in touch with your grants management specialist. The RPPR page and Frequently Asked Questions also contain additional information to help you.
Get Informed, Get Ready to Learn, Get Registered for the NIH Regional Seminar on Program Funding & Grants Administration
Registration for the NIH Regional Seminar is now open! Don't miss this exciting opportunity for investigators, administrators, grant writers and others who are new to the NIH grants process or those wanting to hear the latest NIH grants policy and process information first-hand. The Seminar will take place June 25-27 at the Renaissance Baltimore Harborplace Hotel.
The Bureau of Justice Assistance Grant Writing and Management Academy
The Bureau of Justice Assistance (BJA) has established the Grant Writing and Management Academy for criminal justice practitioners and researchers that apply for or receive federal grants. This training provides an overview of project planning, management, administration, and assessment of federally funded programs. The training encourages participants to think strategically about how they develop and fund projects. Visit BJA's Grant Writing and Management Academy for the tools you need to apply for funding in FY 2013. BJA also recommends that you take a look at the Office of Justice Programs' Grants 101 training which also provides helpful advice on how to create and submit an application for funding.
How to Approach a Foundation
The Foundation Center is providing a free, recorded webinar here on how to build relationships with foundation prospects. It provides you insight into the grantseeking and grantmaking process and helps you increase your chances of winning a grant.
Serving on Scientific/Proposal Review Committees
Serving on scientific and proposal review committees is one of the best ways to learn first-hand how to develop and craft strong proposals. It also provides insight on the award decision-making process from the sponsor's perspective, and helps to understand the most common mistakes found in proposals. One of the essential benefits of serving on scientific and proposal review committees is that it affords an opportunity to build relationships with other colleagues and program officers.
Fortunately, federal agencies require thousands of reviewers each year, and are always seeking reviewers with applicable expertise. While some agencies collect the names of potential reviewers year round, others may put out calls for specific programs.
The following is a listing of opportunities to serve on review committees from various federal agency sites:
NATIONAL INSTITUTES OF HEALTH (NIH) - The NIH peer review system is the foundation of the NIH extramural research enterprise, and its continued excellence depends on the ability to recruit and retain the most accomplished, broad-thinking and creative scientists and experts to serve as peer reviewers. Such qualified individuals are needed to serve on scientific review groups in the initial peer review of applications.
How to become a reviewer: Individuals who possess expertise in areas supported by the NIH and who wish to volunteer to serve in the NIH peer review process should send an e-mail to the Enhancing Peer Review Mailbox (ReviewerVolunteer@mail.nih.gov) along with a brief description of their areas of expertise in the body of the e-mail (1-2 sentences) and a copy of their biosketch as an attachment.
NATIONAL SCIENCE FOUNDATION (NSF) - The success of the peer review process, which enables NSF to make wise investments in all fields of science and engineering research and education, depends on the willingness of qualified reviewers to share their time and expertise. Their experience and up-to-date knowledge provides helpful advice to NSF program officer on the merits of proposals and constructive comments to proposers that strengthen their projects. In making its decisions on proposals, the counsel of these merit reviewers has proven invaluable to the Foundation in the identification of meritorious projects.
How to become a reviewer: Send an e-mail to the NSF program officer(s) of the program(s) that fits your expertise letting them know that you are interested in becoming a peer reviewer. Include an up-to-date CV and current contact information. Click here to find the NSF Program Officer that best fits your expertise/field.
DEPARTMENT OF EDUCATION - The U.S. Department of Education, Office of Innovation and Improvement, is interested in individuals to serve as peer reviewers for future Investing in Innovation (i3) grant competitions.
How to become a reviewer: Reviewers must have expertise in at least one of the programs' priority areas or in educational evaluation. For details in those priority areas, click here. In addition to the expertise requirements, peer reviewers must generally be available for a 4-week time period and will work remotely and via teleconference. If interested, follow the directions in this link to register yourself in the DOE online peer reviewer database.
DEPARTMENT OF EDUCATION - The International and Foreign Language Education office (IFLE) of the U.S. Department of Education administers a variety of international education programs. IFLE continually seeks qualified individuals, in particular, world language and area/international studies specialists, to serve as readers for grant competitions.
Selected readers participate in a panel review of applications and are provided with modest compensation. Most reviews are conducted electronically via the Department’s G5 system and travel will not be necessary. In cases where travel is necessary, readers are provided with roundtrip travel, lodging, and per diem. The review process involves orientation, reading of applications, and regularly scheduled discussions with other panelists. Application scores are based on pre-determined selection criteria and any announced priorities for each program. Panel reviews normally last one to two weeks.
Individuals with the following qualifications are encouraged to apply:
Teaching, research, and practical experience in international education
Recent experience in administering international education programs, or programs of a similar nature
Research, and/or practical experience overseas in international education
Area studies and/or foreign language specialization
Generally, private foundations do not call for external reviewers as they typically use reviewers that are in-house. If information regarding external reviewers for private foundations becomes available, we will add it here.